“Grip” means Grip Limited and its affiliates engaged in the provision of advertising products, services and resources, and includes any service providers acting on behalf of such organizations. You can obtain a current list of Grip’s affiliates and/or service providers upon request, where appropriate.
179 John St., 6th Floor
Attention: Ron Dunstan, Chief Privacy Officer
Tel: 416 204 7710
Fax: 416 340 7776
GRIP’S COMMITMENT TO PRIVACY
Commitment #1: Accountability
Commitment #2: Identifying Purposes for Collecting Personal Information
Grip will, either directly or through a client, identify to an individual the purposes for which it collects, uses and discloses personal information (the “Purposes”), before or at the time the information is collected, or where the information is to be used or disclosed for a new purpose, before that use or disclosure. The Purposes may include:
(a) understanding, developing and administering the Website, Big Orange Slide and other products, services and resources that meet individuals’ and clients’ advertising-related needs, including by operating, maintaining and improving the features and functionality of the Website and Big Orange Slide; processing any User Submissions, ombudsman inquiries or other communications individuals send via the Website or Big Orange Slide; and distributing such Big Orange Slide feeds or weekly updates as may be requested by individuals;
(b) communicating with individuals in connection with the purposes in (a);
(c) offering individuals and/or their organizations new advertising-related products, services and resources that may be of interest to them (provided that such individuals have not opted out of receiving, or having their organizations receive, such offers); and
(d) monitoring overall traffic on the Website and Big Orange Slide and composing and analysing aggregate traffic data and statistics, in each case, on an anonymized basis.
Commitment #3: Obtaining Consent
Grip will make a reasonable effort, either directly or through a client, to advise an individual as to how personal information will be used or disclosed by Grip. Generally, Grip or a client, on behalf of Grip, will obtain the individual’s consent to the collection, use and disclosure of personal information for the Purposes before or at the time it collects the information. An individual’s consent may be express or implied, depending on the sensitivity of the information.
An individual may withdraw or vary his or her consent on reasonable notice to Grip, subject to legal or contractual restrictions. Grip will generally be able to give effect to such withdrawal or variation on thirty (30) days’ notice, and will, if it has not already done so, advise the individual of the implications of his or her withdrawal or variation.
Commitment #4: Limits on the Collection of Personal Information
Grip will limit the personal information it collects to information necessary for the Purposes. Grip will only collect personal information by fair and lawful means. Grip will not collect personal information from any third party (other than a client acting on behalf of Grip) without an individual’s consent unless the collection is clearly in the individual’s interest and Grip is unable to obtain consent in a timely way, or as otherwise permitted by law.
Grip will not, as a condition of supplying a product, service or resource, require an individual’s consent to the collection, use or disclosure of his or her personal information beyond that reasonably required to supply the product, service or resource, to comply with its obligations under applicable law or for related internal business or management or legal purposes.
Commitment #5: Limits on the Use, Disclosure and Retention of Personal Information
Grip will only use, disclose and retain personal information for the Purposes. Grip will identify any third parties to whom personal information will be disclosed at the time of collection and obtain individuals’ consent to such disclosure. For example, Grip may:
(a) disclose personal information to an individual’s organization for the purposes of understanding and administering products, services and resources that meet the organization’s advertising needs, and communicating with the organization for that purpose, and/or offering the organization new products, services and resources that may be of interest to it (provided that the individual has not opted out of having his or her organization receive such offers);
(b) make some information about an individual available to other users of the Website and Big Orange Slide. This may include an individual’s name, website and User Submissions, for instance, when the individual engages in certain activities such as posting or submitting comments or other information or materials using Big Orange Slide. An individual’s email address will not generally be made available to other users; or
(c) transfer personal information to third parties for processing (e.g., data processing or hosting), pursuant to contractual agreements that provide a level of protection for the personal information comparable to that provided by Grip, as well as assurances that such third parties will not use or disclose the personal information for any purpose other than processing.
Under certain statutory exceptions, Grip may have a legal duty or right to disclose personal information without individuals’ consent. Examples of permitted disclosures of personal information to non-affiliated third parties may include disclosures required to comply with a subpoena or warrant, made pursuant to a request by a government institution, made to an investigative body or government institution where Grip has reasonable grounds to believe that the information relates to a breach of an agreement or law or disclosures otherwise required by law.
Grip will use, disclose and retain personal information only for as long as is necessary to fulfil the Purposes or as otherwise permitted or required by law. User Submissions will be archived on Big Orange Slide only so long as the relevant Grip post is archived. Grip has established minimum and maximum retention periods and procedures for retaining and destroying personal information.
Commitment #6: Accuracy of Personal Information
Grip will use reasonable efforts to keep personal information as accurate, complete and up-to-date as necessary for the Purposes. That said, Grip will not routinely update personal information unless necessary. Grip expects individuals, from time to time, to inform Grip of any updates that may be required by contacting Grip using the contact information above.
Commitment #7: Safeguarding Personal Information
Grip is committed to protecting the security of personal information. Grip uses security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and limiting access on a “need to know” basis and technological measures, such as the use of passwords, encryption and other secure methods by which to verify the identity of individuals.
Grip’s staff are made aware, through orientation and refresher training programs, of the importance of maintaining the confidentiality of personal information. Grip conducts periodic internal and independent audits of its security safeguards and any breach of Grip’s security safeguards is a disciplinary matter. Grip’s security safeguards extend to the destruction of personal information.
Grip remains responsible for all personal information transferred to third parties for processing. As such, Grip ensures that all third parties engaged to perform services on Grip’s behalf are required to provide a level of protection for personal information comparable to the level of protection provided by Grip, and that such third parties are prohibited from using or disclosing personal information for any purpose other than processing.
Commitment #8: Availability of Information about Grip’s Policies and Practices
Commitment #9: Access to Personal Information
Upon written request, Grip will generally tell an individual what personal information it has, what it is being used for and to whom it has been disclosed and will grant the individual access to the information. Grip will make such information available to an individual in a form that is generally understandable, including by explaining any abbreviations or codes or by employing an alternative format, if required. Written requests, including the individual’s name and contact information, should be sent to Grip’s Chief Privacy Officer using the contact information above. Grip will make every reasonable effort to respond to written requests within thirty (30) days of receipt and will advise individuals in writing if for any reason this time limit cannot be met.
Grip may request individuals who submit written requests to provide sufficient information to enable Grip to verify their identity. Any such information will be used only for the purpose of identification.
Grip will not assess any costs to individuals for accessing their personal information without first providing individuals with an estimate of such costs, which will be minimal, if any. Individuals are asked to confirm their wish to proceed in writing within the thirty (30) day notice period set out in any estimate. If an individual does not notify Grip in writing of his or her wish to proceed within such notice period, then Grip will deem the individual to have withdrawn his or her request for access and will provide him or her with a written notice to that effect.
An individual may challenge the accuracy and completeness of personal information and request that it be amended. Grip will, if appropriate, amend the information and advise third parties to whom the information as been disclosed of the amendment.
Commitment #10: Handling Complaints and Questions
Prior to making a complaint to the Chief Privacy Officer, or if a complaint is not resolved to the individual’s satisfaction, the individual may also make a complaint to the applicable Privacy Commissioner.