Last Revised: April 27, 2018
TSPS has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.
Information TSPS Collects
Personal Information that TSPS collects includes, but is not limited to:
- name, e-mail address, address, date of birth, usernames, passwords, phone numbers, and mailing address;
- Billing and payment information, including credit card information and bank account details;
- Device information
- IP address;
- Geo-location information;
- Any other Personal Information that You may provide when You use the Services, or when you contact TSPS with questions and/or inquiries;
- Technical support records;
- Service requests and inquiries; and
- Any information that TSPS collects from You that is intended to improve and personalize TSPS’s Services.
Please note that Personal Information does not include information that is aggregated or anonymized in such a manner that it cannot be connected to You or any of other Users. Such information by itself or together cannot be tracked to a specific individual’s Personal Information.
How does TSPS use Personal Information?
TSPS collects Personal Information for the following purposes:
- to provide Services to You and other Users;
- to facilitate transactions between You and TSPS and to establish and maintain responsible commercial relations and to communicate with You in order to provide the Service;
- permit or payment processor(s), current Paypal and Stripe, to provide payment processing services;
- to respond to any correspondence You may direct to TSPS;
- to understand TSPS’s Users’ needs and preferences;
- to enforce TSPS’s Terms of Sales and Service;
- to provide You with Service or administrative messages;
- to meet legal and regulatory requirements;
- to prevent, detect and mitigate illegal, fraudulent, or counterfeit activities;
- to improve the Services; and
- for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
TSPS uses NPI in an ongoing effort to better understand and serve the Users of TSPS’s Services, to provide the Services and to improve the content and functionality of the Services.
For instance, TSPS uses NPI to monitor traffic and to collect statistical data.
The NPI collected is used to monitor traffic, provide the Services, and conduct internal research on TSPS’s Users’ to better understand and serve them, including Users’ size, usage patterns, demographics, interests and behaviors.
The Services may automatically receive and store certain types of information about Users’ use of the Services and their devices, including IP address, browser type, web pages viewed, date and time, device unique identifier, mobile network information, mobile stored information and files, and device phone number, as well as how users interact with TSPS.
In addition, TSPS uses different types of technology to collect this information, such as log files, embedded scripts, cookies, web beacons, and pixel tags.
You may disable cookies using Your browser’s settings. Please consult Your browser’s help function for information on how to disable cookies. Note that if You disable cookies, certain features of TSPS’s Services may not function to their fullest potential.
TSPS respects Your privacy and, unless otherwise required by law, TSPS will not collect, use or disclose Your Personal Information without Your prior consent. Your consent may be expressed or implied. You may expressly give Your consent in writing, verbally or through any electronic means. In certain circumstances, Your consent may be implied by Your actions. For example, providing TSPS Personal Information to register for TSPS’s Services is implied consent to use such information to provide You the associated Services.
Where appropriate, TSPS will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when TSPS wants to use information for a purpose other than those identified above). In obtaining consent, TSPS will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by TSPS may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, TSPS shall take into account the sensitivity of the Personal Information and the reasonable expectations of TSPS’s Users. TSPS will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to TSPS in writing.
Limiting Use, Disclosure and Retention
In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, TSPS will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.
Subject to the foregoing, only TSPS’s and TSPS’s Affiliates’ employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about TSPS’s Users. All such employees will be required as a condition of employment to contractually respect the confidentiality of TSPS’s Users’ Personal Information.
TSPS will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by TSPS.
TSPS will disclose Personal Information without Your knowledge or consent if TSPS receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If TSPS receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, TSPS’s policy is to provide the requested information.
Links to Other Services
You may be able to access third-party websites and services through links available on TSPS’s Services.
You may create links between TSPS’s Services and social media online services. If You do so, TSPS may be able to publish updates about TSPS’s Services to Your social media service accounts through the links that You establish. You may terminate those links at any time by modifying Your social network account.
Storage Outside of Canada
Your Personal Information will not be used or stored by TSPS or TSPS’s service providers outside of Canada. TSPS requires that TSPS’s service providers safeguard Your Personal Information.
Children and Minors
TSPS’s Services are not directed to children under the age of 13 years. TSPS will not knowingly collect Personal Information about a child under the age of 13. TSPS does not allow minors (persons who are under the age of majority in their place of residence) to make purchases.
How can I Access my Personal Information?
Upon request, TSPS will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. TSPS will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, TSPS may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. TSPS will provide the reasons for denying access upon request.
TSPS protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. TSPS will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
TSPS’s methods of protection include:
- Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to TSPS’s place of business in general and to internal offices as well;
- Organization measures, such as security clearances and limited access on a need to know basis; and
- Technological measures, such as the use of passwords, firewalls and encryption.
Inquiries; Challenging Compliance
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If TSPS finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact TSPS’s Privacy Office as follows:
Mail: 8 Sampson Mews, Suite 201 ,Toronto, Ontario M3C 0H5, Canada
Tia Slightham – Parenting Solutions