Privacy Policy

How we collect your personal information and what we do with it

Date last modified: December 2nd, 2019

Do you need to read this?

Probably! This Privacy Policy describes how personal information is collected and processed by Connect The Dots Fibre Communications Inc ("CTD" or "us" or "we" or "our") in relation with its operating program and activities when:

• You sign up for a services

• You apply for a credit

• You accept and use any pre-authorized payment option (e.g. Credit Card payments)

• You use our online services. For example, if:

  • You visit our website

  • You subscribe to our newsletter

  • You make an online payment

  • You use your Customer Portal

However, this Privacy Policy does not apply to the collection and processing of CTD’s employees' personal information.

1. Our commitment for your privacy

Because protecting your personal information is important to us, we at CTD have adopted strong principles in that respect.

1. We don’t sell your personal information to anyone.

2. We tell you why we use your personal information, and we don’t use it for anything else.

3. We limit how much personal information we collect, use, communicate and store to what is necessary for our purposes.

4. Sometimes, our service providers need access to your personal information. They are only allowed to use your personal information to provide services on our behalf. The only exception is when they have a legal obligation to disclose your personal information to the authorities.

5. We give you the option to control your personal information. We will respond to your privacy concerns, by contacting our office which gives you access to your personal information and implements the corrections that you have requested.

6. We may communicate your personal information to the authorities without your consent where permitted or required by law.

2. Types of information we collect

2.1 Personal information

Personal information is information about an identifiable individual.

The personal information we collect may include:

• Identification information: Like your name, ID card with or without photo, date of birth, gender, citizenship status

• Contact information: Like your phone number, personal address, email address

• Financial information about you: Like your income, employment situation, salary, personal assets and liabilities, financial statements

• Habits and preferences information: Like data which relates to your use of our products and services, data from your interactions with us, our website, our apps

• Education and employment information: Like résumé, level of education, employment, interview notes, remuneration, references

• Customer Mangement (Portal) activities information: About your activities when you are logged in to your Customer Portal

2.2 Data considered to be personal information

We collect information about how you use our website. Even though this information is not linked to your identity, it can be in certain circumstances by using cookies. This is why we consider this data to be personal information as well when linked to your identity. The data we collect includes:

• The pages of our website viewed

• The date and time when those pages were viewed

• The region where you are connecting from (geolocation)

• How long each page was viewed

• The web browser used (Chrome, Edge, Firefox, Internet Explorer, Opera, etc.), browser settings and the type of device used (Mac or PC, mobile or desktop, etc.), AdWords used and references from which websites, applications or social media you come from before your visit

3. When and how we collect your personal information

3.1 We collect personal information when you give it to us directly

For example:

• When you apply for services

• When you apply for credit

• When you fill in an online form

• When you subscribe to one of our newsletters

• Whenever you use online tools and give information about yourself or your business

3.2 We also collect personal information obtained from sources other than yourself

For example:

• From our services providers for web analytics or ads

• From websites/social media pages containing information made public by you

• From databases made publicly available by third parties

3.3 When you are logged in to your Customer Portal, we record your activities

We keep an electronic log of all your activities so that we can detect and review any suspicious activity on your account.

3.4 When you browse our website, we use cookies that track your activities

How we track your activities

When you browse our website, we track your activities to infer your interests based on pages you have visited. We may match this information to your specific user profile as soon as you identify yourself on our website by using cookies. We may do so to know what your interests are, to promote our products and services to you, and to offer you products or services that are more relevant to you.

What cookies are and what we can do with them

Cookies are files that a website automatically creates and stores on your computer to collect information on your web browsing activities. We use first-party cookies to improve your user experience (most websites do).

Our website creates first cookies that allow us to:

• Recognize you the next time you visit our website

• Personalize our website, application, newsletters and emails for you

For example, we can know if you have already completed a survey so we do not ask you to do it again. These cookies are called persistent cookies, because they stay in your browser after you have closed your session.

We also use Google Ads, Double Click and other third-party cookies for marketing purposes. With marketing and remarketing cookies, we can:

• Automatically create lists about our users' interests based on pages they have visited, not only within the CTD website, but also with other websites

• Use this information to target users with specific ads

• Analyze how well our ads perform for a specific audience

For example, if you visit a page about Internet Services, an alphanumeric code that identifies you will be added to a list of users who are interested in Internet Services. This code will also be stored in a cookie on your computer. As a result, you may see a CTD ad about Internet Services on a different website.

3.5 We use Google Analytics to collect data about how you use our website (web analytics)

We use Google Analytics to analyze how users utilize our website.

Google Analytics makes your data anonymous by removing part of your IP address.

Google Analytics relies on cookies to collect information. Cookies used by Google Analytics will expire two years after your last visit to our website. For more information, consult the Google Analytics website and its privacy policy.

3.6 This policy does not cover personal information you give to social media companies or online payment providers

When you interact with us through social media, for example on our Facebook page, you give information to social media companies and not to us. This information is covered by their own privacy policy. Keep in mind that information you publish on social media can be made public.

When you pay online for our services, you give your payment information to an online payment provider. This information is processed by the online payment provider and it is covered by its own privacy policy.

4. Why we collect and use your personal information

We only collect your personal information if it relates directly to operating programs or CTD’s activities and for the following purposes:

4.1 For business purposes

To identify you

We use your personal information to identify you.

To register you

We use your personal information to register you, notably for an event.

To communicate with you

We use your personal information to communicate with you and to answer your questions about our products or services.

To advise you when you request our products or services and to improve your experience

We use your personal information to provide tailored advice and direct you towards the most appropriate resources, products and services upon request. This way, we make sure our advice, resources, products and services are best suited to your profile.

To protect you and us against errors or fraud

When you use your Customer Portal, we keep a log of all your activities. This allows us to detect suspicious activity on your account.

4.2 For web analytics purposes

To analyze how you use our website and improve your experience

We collect and analyze data about web traffic and visits on our website. This is called web analytics. Web analytics allow us to:

• Understand how users utilize our website

• Improve our website

• Further develop our business and operations

4.3 For marketing purposes

To promote our products and services to you

We send you promotional emails only if you have specifically agreed to receive them. For example, if you have subscribed to our newsletter.

We also use cookies to publish ads that target our users based on pages they have visited. You may see our ads when you browse the Web even though you never subscribed to anything.

To offer you products and services that meet your needs

We use your personal information to offer you personalized advice and financing opportunities.

5. How we store your personal information

5.1 Where we store it

Your personal information WILL NOT be stored outside Canada because we believe Canadian Data should remain in Canada!

5.2 How we keep it secure

We take stringent measures to ensure that your personal information is protected and handled properly.

5.3 How long we store it for

We do not store your personal information forever. But we do have to follow certain requirements in the Canadian Privacy Act.

Thus, we store your personal information for only as long as needed as required for business and compliance needs. Usually, for only 1 year after you are no longer a CTD Customer.

After that, we destroy, erase or dispose of your personal information.

6. To whom we communicate your personal information

6.1 Our employees or representatives may view your personal information on a need-to-know basis

Our employees or representatives may view your personal information for their work or for the reasons why we collected this information in the first place.

They will not view your personal information for any other reason.

6.2 Our service providers may process your personal information

Our service providers may need to access or process your personal information. They are not authorized to disclose your personal information for any reason other than providing the services we ask from them, or if they have a legal obligation to do so.

We obtain the following services from our service providers:

• Processing credit verification

• Conducting web analytics

• Processing your payments

• Advertising our products and services

• Manage email delivery

• Distribute useful content

6.3 We may communicate your personal information in certain circumstances

In exceptional cases, we may communicate your personal information to others without your consent:

1. If we are legally required to do so. For example, if we receive a court order to communicate your personal information.

2. If it is impossible to get your consent and privacy laws allow us to communicate your personal information. For example, if it is necessary for the protection of public interest or to collect money you owe us (overdue accounts).

7. Things you can do to control how we process your personal information

7.1 You can revoke your consent

Whenever you have specifically given your consent, you can revoke your consent at any time. For example, you can always opt out of one of our newsletters.

You may request that we erase your personal information in our control. In some cases, we cannot erase personal information we have already collected. This is usually due to legal or technical reasons.

To revoke your consent or request erasure of your personal information, please the office.

7.2 You can disable cookies

You can control cookies in the following ways:

• Disable cookies in your browser’s settings. You will still be able to access our website, although some features may not work properly.

• Opt out of Google Analytics by installing this add-on on your browser.

7.3 You can access your personal information and ask us to correct any error

You can access your personal information at any time

To do so, please contact the office.

In some exceptional cases, we might be unable to give you access to your personal information. For example, if we cannot dissociate your personal information from:

• Other persons’ personal information

• Our own proprietary information

• Information covered by solicitor-client privilege

You can ask us to correct any error or omission

You can ask us to make corrections to personal information that we have that is not accurate. If we do not make these corrections, you can ask us to add annotations to your personal information to explain why certain corrections you asked were not made. Finally, you can ask us to notify certain persons about these corrections or annotations. To do so, please the office.

7.4 You can express your privacy concerns and file a complaint

You can express your privacy concerns by calling us or writing to us.

To do so, please contact the office.

To file a privacy complaint, you must send an email to our privacy coordinator

This ensures that we keep a record of your complaint. Our staff will respond to you as soon as possible.

Note that your complaint must be about your privacy or about how we deal with your personal information.

If you are not satisfied with how we respond to your complaint, you can contact the Office of the Privacy Commissioner of Canada.

8. Congratulations for getting so far!

We did our best to make this policy as easy to read and understand as possible. Here are a few more things you should know:

8.1 We may change this policy at any time

Because privacy concerns, business and legal requirements continually evolve, we may need to change this policy in the future. We will provide notice of material changes to this policy, for example, by posting a notice on our website explaining that the privacy policy has been updated.

What if the policy has changed since your last visit?

If you visit our website or use our online services after our privacy policy has changed, you will be governed by the updated version of the privacy policy.

8.2 How to read and interpret this Privacy Policy

This policy is governed by the laws of Ontario and Canada. This policy complies with the Privacy Act of Canada.

8.3 Contact us with any question

Feel free to contact us:

• For questions or comments about this policy

• For more information about how we deal with your personal information

• To access or modify your personal information

Here is how you can contact us:

• Call us at 226-909-4464

• Send us an email: This email address is being protected from spambots. You need JavaScript enabled to view it.

• Mail us a letter: Connect The Dots Fibre Communications Inc, 134 Margaret Street, Meaford, Ontario N4L1C1

Note: The masculine is used without prejudice and only for the sake of readability.