1.We will not spam users, but we may provide you with notices from time to time that we feel are necessary to the operation of the website. We may also make suggestions to you about new courses that we think might interest you.
2.We will not give your Personal Information to anyone who we reasonably believe will spam you.
3.We won’t give, rent, or sell your personal information to anyone.
4.As long as we hold your information, we will make our best efforts to keep it safe, but we cannot control the use, transmission, storage and/or retention by other people, including other users.
5.When you deactivate your account, we’ll delete your personal information permanently.
1. Our Promise
Homburg is committed to protecting user privacy. We understand that users of the Website are concerned about their privacy, and the confidentiality and security of any information and content that is provided.
2. The Policy
This policy is effective as of 16 May 2013.
3. Collection of Information
3.1 All Users
Whenever Users visit the Website, our servers automatically record information for statistical purposes about their usage of the Website such as: (a) the type of browser used; (b) the referring URL; (c) the IP address; (d) the number and type of pages viewed; (e) the date and time of visits; and (f) the exit URL.
This information we collect about you is not considered Personal Information and remains anonymous. We will use that information to monitor our traffic statistics. We do not link the anonymous information to any other Personal Information unless you have either registered as a Member or logged on as a Member at the time of use. Accordingly, if you have not identified yourself on the Website, such as by registering as a Member or logging on as a Member, we will not link a record of your usage of our Website to you personally.
Upon your registration as a user we collect information about you in order to provide you with the benefits of the website. We collect non-identifying information as well as Personal Information from you directly when you first register and also from time to time thereafter if you provide us with additional information. Personal Information which may be collected includes, without limitation: your full name, and your email address.
User Content, and Personal Information, may be utilized by us for the following purposes:
To provide information or services that a User has requested;
To service a User’s account;
To improve Homburg On Demand’s services;
To develop and/or inform Users of additional products or services we think will be of interest and benefit to Users; and
To answer questions Users may have.
We use “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the Website. A cookie does not identify you personally but it does identify your computer. You can set your browser to disable cookies or to notify you when you receive a cookie and provide you with an opportunity to either accept or reject it in each instance. If you disable cookies, you may not be able to access certain areas or features on our Website.
4. Use and Disclosure
We shall not use or disclose any Personal Information about you for a secondary purpose unless: you would reasonably expect us to use or disclose the Personal Information for the secondary purpose; you have consented to the use or disclosure; we reasonably believe that the use or disclosure is necessary to lessen or prevent serious or imminent threat to an individual’s life, health or safety or a serious threat to public health or public safety; we have reason to suspect that unlawful activity is being engaged in and we use or disclose the Personal Information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities; the use or disclosure of the Personal Information is required or authorized by or under law; we reasonably believe that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of the police or other enforcement body: (i) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; (ii) the enforcement of laws relating to the confiscation of the proceeds of crime; (iii) protection of public revenues; (iv) the prevention, detection, investigation or remedy of seriously improper conduct or proscribed conduct; (v) the preparation for or conduct of proceedings before and court or tribunal or implementation of the orders of a court or government official.
5. Data Security
We will take reasonable steps at the time that we collect, use, or disclose Personal Information from Users to secure the Personal Information we hold from misuse and loss, unauthorised access, modification, or disclosure.
To protect the Personal Information we shall:
(a) adopt measures to prevent unauthorized entry to our premises, systems to detect unauthorized access, and secure containers for storing paper based Personal Information;
(b) adopt measures to protect our computer systems and networks for storing, processing and transmitting Personal Information and to protect from unauthorized access, modification and disclosure;
(c) protect communications via data transmission including emails from interception and preventing unauthorized intrusion into our computer networks;
(d) adopt procedural and personnel measures for limiting access to Personal Information except by authorized staff approved for the purposes, and adopt controls to minimize security risks to our information technology systems; and,
(e) undertake such other security measures as we consider reasonable.
6. Destruction of Information
We will destroy Personal Information in a secure manner when a User deactivates his or her account.
8. Correction of Information
We do not hold information that is not under the control of the individual User. If the information about you is inaccurate, it is your responsibility to correct it. If for any reason you are unable to do so, you may ask for our help by emailing firstname.lastname@example.org and we will take reasonable steps to help you to correct the information so that it is accurate, complete and up to date.
8.1 Access and Correction
We shall provide you with access to the information held by us in relation to you except to the extent that providing access would pose a serious and imminent threat to the life or health of any individual; or providing access would have an unreasonable impact upon the privacy of other individuals; or the request for access is frivolous or vexatious; or the information relates to existing or anticipated legal proceedings between us and you and the information would not be accessible by the process of discovery in those legal proceedings; or providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations; or providing access would be unlawful; or denying access is reasonable or authorized by or under law; or providing access would be likely to prejudice an investigation of possible unlawful activity; or providing access would be likely to prejudice: i) the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of prescribed law; or ii) the enforcement of laws relating to the confiscation of the proceeds of crime; or iii) the protection of the public revenue; or iv) the prevention, detection, investigation o remedy of seriously improper conduct or prescribed conduct; or v) the preparation for or conduct of proceedings before any court or tribunal or implementation of its orders; vi) the preparation for or conduct by or on behalf of the police or an enforcement body; or vii) an enforcement body performing a lawful security function asks us not to provide access to the information on the basis that providing access would be likely to cause damage to the security of a country, territory, or violate an ‘ordre public’.
8.2 Request for Access
To request access to the information held by us about you, you must contact us using the contact details provided, following which we shall contact you within 14 days from our receipt of your request and either provide you with that information, or notify you when we shall provide you with the information. In any event the information requested will be provided not more than 30 days after our receipt of your request unless we decide not to provide you with access to the information in which case we will advise you of the reasons for such decision.
Unless there is a practical or legal reason to require identification, you may transact with us anonymously to the extent that it is practical.
10. Transborder Data Flows
In the event that we transmit data across borders it will always be done in conformity with the laws of Canada or it and if we believe that the recipient is subject to a law, a binding scheme or a contract which effectively upholds principles for the fair handling of the information that are substantially similar to those in Canada.
11. Complaint Handling Process
11.2 Our Response
Within 30 days of receipt of your complaint form we shall notify you in writing as to what action we propose to take in relation to your complaint and shall provide you with details of what further action you can take if you are not satisfied with our response.
12. Filing Formal Complaints
If you believe you have a complaint under the Privacy Act or The Personal Information Protection and Electronic Documents Act (PIPEDA), the Office of the Privacy Commissioner of Canada is at the following address:
112 Kent Street
Place de Ville
Tower B, 3rd Floor
And may be contacted at:
Phone: (613) 995-8210
Fax: (613) 947-6850
TTY: (613) 992-9190
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