Adopted: April 2012
Last updated: July of 2012
Privacy Officer
privacyofficer@peekaboogiftclub.ca

1. Peekaboo Gift Club is committed to complying with the relevant Federal and Provincial legislation and regulations regarding privacy and the protection of personal information.

Every province and territory has privacy legislation governing the collection, use and disclosure of personal information held by government agencies, similar to the “Privacy Act” at the federal level. These acts provide individuals with a general right to access and correct their personal information.

Individuals are protected and commercial activities governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), hereinafter referred to as the “Act”. It sets out ground rules for how private sector organizations may collect, use or disclose personal information in the course of commercial activities. The law gives individuals the right to access and request correction of the personal information these organizations may have collected about them.

PIPEDA applies to all organizations engaged in commercial activities unless the federal government exempts an organization or activity in a province that has substantially similar legislation to the Act.

British Columbia, Alberta and Quebec are the only provinces with laws recognized as substantially similar to PIPEDA. These laws regulate the collection, use and disclosure of personal information by businesses and other organizations and provide individuals with a general right of access to, and correction of, their personal information. Ontario, meanwhile, has adopted privacy legislation to protect personal health information which has been recognized as substantially similar.

Oversight of both federal Acts rests with the Office of the Privacy Commissioner of Canada who is authorized to receive and investigate complaints.
See http://www.priv.gc.ca for relevant detailed information.

2. Where the present “Privacy Policy” of Peekaboo Gift Club diverges from the “Act”, the “Act” shall have precedence, at all material times.

3. In particular, Peekaboo Gift Club is committed to complying with the ten Principles for the protection of personal information set out and explained at http://www.priv.gc.ca/leg_c/p_principle_e.cfm#contenttop.
These principles will be interpreted and further defined as they apply to Peekaboo Gift Club in numbered attachments to the present “Privacy Policy” of Peekaboo Gift Club, as and when needed.

4. Peekaboo Gift Club may have personal information as of the date of adoption of its “Privacy Policy”, as defined by the act. This information may include all forms of contact information for system users / clients and possibly at some given point in time, credit or debit card information, which is used for processing of a client requested transaction ONLY and immediately thereafter destroyed, once the transaction is successfully completed or an error in such processing is recognized and resolved.

Personal financial information is not maintained within any Peekaboo Gift Club system after a client requested transaction is completed.

Non-financial, basic contact information is maintained by Peekaboo Gift Club systems and may apply to past and current clients. Each client’s basic contact information such as name, address, email address and/or telephone number will ONLY be supplied to a given third party, namely a specified Peekaboo Gift Club Sponsor, with the consent of the client. Such basic contact information is provided to the specified third party under STRICT contractual agreement that the information is for their SOLE use in informing the client of additional future offerings regarding their own specific and named products and/or services.

Otherwise, such basic contact information will not be distributed by Peekaboo Gift Club in any manner, but rather remain and be kept strictly confidential to and for the client’s use of the system.

Any other information, including but not necessarily limited to financial information will remain protected and strictly confidential at all times during and after the processing of any client requested transaction.

5. Peekaboo Gift Club will continue to collect personal information after the date of adoption of its “Privacy Policy”, as defined by the act. Any new information collected may include all forms of contact information for system users / clients and possibly at a given point in time, credit or debit card information, which is used for processing of a client requested transaction ONLY and immediately thereafter destroyed, once the transaction is successfully completed or an error in such processing is recognized and resolved.
Personal financial information is not maintained within any Peekaboo Gift Club system after a client requested transaction is completed.

Non-financial, basic contact information is maintained by Peekaboo Gift Club systems for past and current clients. Each client’s basic contact information such as name, address, email address and/or telephone number will ONLY be supplied to a given third party, namely a specified Peekaboo Gift Club™ Sponsor, with the consent of the client. Such basic contact information is provided to the specified third party under STRICT contractual agreement that the information is for their SOLE use in informing the client of additional future offerings regarding their own specific and named products and/or services.

Otherwise, such basic contact information will not distributed by Peekaboo Gift Club in any manner, but rather remain and be kept strictly confidential to and for the client’s use of the system.
Any other information, including but not necessarily limited to financial information will remain protected and strictly confidential at all times during and after the processing of any client requested transaction.

6. Peekaboo Gift Club will only retain personal and transactional information (without credit card number) for as long as is required by the system or dictated by Federal and Provincial Laws.

Contact information is maintained online in perpetuity; UNLESS and UNTIL, the user / client specifically requests in writing (email from the registered email address being acceptable) or by verifiable telephone contact via the “1-800” / toll free telephone number to remove his or her records. At this time, the client’s record is red flagged to any Sponsor having access as “Please Remove – No Further Contact!” and after one (1) complete monthly cycle, permanently removed from the Peekaboo Gift Club systems.

Users / clients of the systems may also elect to “Opt-Out” of the Peekaboo Gift Club Sponsor contact for additional future offerings by specifically requesting same in writing (email from the registered email address being acceptable) or by verifiable telephone contact via the “1-800” / toll free telephone number. Again, the client’s record is red flagged to anyone having access as “Please Remove – No Further Contact!” but the record remains within the system for the client’s own access and use.

Finally, Users / clients of it’s the systems may choose not to receive “Newsletters” by email or otherwise through changing their User Record on the website.

7. Upon a verifiable verbal or written request from any user / client of the systems being received by a staff member or other duly authorized third party of the Peekaboo Gift Club, the “Privacy Policy” will be thoroughly reviewed and explained by a senior manager of the Peekaboo Gift Club and to a level, so that the decision of the requesting party to collaborate with respect to protected information is well-informed, and does not compromise the interests of the requesting party.

8. Upon a verifiable verbal or written request from any user / client of the systems, email from the registered email address being acceptable, to remove their respective personal information from any and/or all Peekaboo Gift Club systems, Peekaboo Gift Club will remove any such information, reference or references from active system files and as permitted by Federal and Provincial Laws, remove any and all information, reference and references whether in archives or not.

9. Peekaboo Gift Club undertakes to adopt, absorb and learn, as fundamental to its “Privacy Policy”, the ten (10) Principles for the protection of personal information set out and explained at http://www.priv.gc.ca/leg_c/p_principle_e.cfm#contenttop.

All staff members, consultants and related parties of Peekaboo Gift Club will be required to become familiar with the “Privacy Policy” and these ten (10) underlying Principles.

Each will be required to sign the “Record of Familiarization” which forms part of the “Privacy Policy” for Peekaboo Gift Club.

10. Any staff members, consultants and related parties of Peekaboo Gift Club, who may have a need to know or access to personal and protected information from time to time, will be required to become familiar with the “Privacy Policy” and the ten (10) underlying Principles.

Each will be required to sign the “Record of Familiarization” which forms part of the “Privacy Policy” for Peekaboo Gift Club.

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