Morewave Communication Inc.
Personal Information Protection Policy
At Morewave Communication Inc. (“Morewave”), we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual, for example, such information as their name, home or business address, phone number and email address. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Morewave complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 What information we collect or process: Morewave process and in certain situations collects personal information as needed to deliver its Products and Services and manage its business.
1.2 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.3 We will only collect client information that is necessary to fulfill the following purposes:
- To verify identity
- To better determine which of our services might better fulfil the clients’ needs
- To deliver requested products and services
- To establish and provide ongoing services
- To meet legal and regulatory requirements
1.4 What Information we collect or process may include:
- Indirect end user phone contact information. Specifically, only when enabled via system permission on Morewave Mobile (Android of iOS), Morewave Mobile shows personal contacts within the respective application. When the user sends an SMS message to one of their phone contacts, or when the user initiates a call to one of their phone contacts, the phone number is sent securely through Morewave’s API. Morewave does not store this number with any other PII, and it cannot be directly or indirectly attributed to any person or persons; Morewave stores only the phone number and pertinent metadata so as to be compliant with all applicable provincial and federal laws, and Morewave does not share this data with any advertisers or third parties under any circumstances. A user can revoke phone contact access on his/her mobile device at any time, and his/her app experience is not hindered or interrupted.
- Morewave Mobile (Android and iOS) also uses Gravatar, only when enabled via Settings, which is a service that provides avatar images linked to the MD5 hash of the user’s email address. This means that, only when Gravatar use is enabled, we hash each contact’s email address and send it to Gravatar to try and retrieve an avatar image. MD5 hashes cannot be directly or indirectly attributed to any person or persons, and we only send the MD5 hash to Gravatar, never the email address in plain text. As with phone contacts, a user can revoke Gravatar access at any time in Settings, and their app experience is not hindered or interrupted.
Policy 2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, electronically, or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for the marketing of new services or products and the client does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Morewave to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.
2.5 We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- When the personal information is available from a public source (e.g., a telephone directory);
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection. Within a reasonable time after the purpose has been satisfied, your sensitive information will be destroyed or made anonymous. Unless express consent is given, all information kept by Morewave regarding the customer, other than the customer’s name, address, and listed telephone number, is confidential and may not be disclosed by Morewave to anyone other than:
- the customer;
- a person who, in the reasonable judgement of Morewave, is seeking the information as an agent of the customer;
- another telecommunications company for the purpose of efficient and cost-effective provisioning of telecommunications services and disclosure is made on a confidential basis with the information to be used only for that purpose; or
- an agent retained by the company to evaluate the customer’s credit worthiness or in the collection of the customer’s account, provided the information is required for and is to be used only for that purpose.
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks b maintaining industry standard security safeguards. Excluding when they are in use by authorized personnel, paper-based files containing personal information are secured within a restricted area and electronic data containing personal information is restricted to authorized users only.
6.2 We will use appropriate security measures when destroying client’s personal information.
6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Morewave’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding Morewave’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Morewave’s Privacy Officer: email@example.com