Cloudwifi is a connectivity solutions provider. We serve our customers with Internet, managed Wi-Fi, TV, and digital phone services.
Identifying the purposes for Personal Information collection
Limiting the collection of Personal Information
Limiting the use, disclosure and retention of Personal Information
Keeping Personal Information accurate
Safeguarding Personal Information
Being open about policies and practices
Providing access to Personal Information
Frequently Asked Questions
Q1: What type of Personal Information does Cloudwifi collect?
Customer’s Personal Information:
If you wish to obtain any of Cloudwifi’s products and/or services, Cloudwifi will collect information about you when you subscribe for any of these products and/or services. The type of information we collect varies based on the service you have requested. The Personal Information most often collected and maintained in a Customer file may include (but is not limited to) name, address for service, mailing address, phone number, a piece of acceptable identification, alternate contact information, banking or credit card information for payment, and/or email address.
Collection and Use of Personal information in connection with Cloudwifi Internet:
In order to access Cloudwifi Internet services, you will be requested to provide your Cloudwifi userid or email address, password, and certain other information that may be requested from time to time. Cloudwifi will also automatically collect certain information such as device location, device type, and general usage information associated to the Media Access Control (“MAC”) address associated with your device (the “Device Information”). The Device Information is used to deliver the Cloudwifi service, monitor and improve network traffic, improve your Cloudwifi Internet experience, and for research and statistical purposes.
Employee’s Personal Information
The personal Information most often collected and maintained in an Employee or applicant for employment file may include, as appropriate, (but is not limited to) Business Contact Information, home address, home phone number(s), emergency contact information, date of birth, Social Insurance Number, banking information, past employment information, resumes, reference letters, earnings information, performance reviews/letters, and dependant and beneficiary information.
Web Site User Personal Information
The Personal Information that may be collected in relation to Web Site Users through an online form typically includes (but is not limited to) name, phone number, email address.
During a Web Site User’s interaction with one of Cloudwifi’s websites, Cloudwifi may use a browser feature called a “cookie” to collect information anonymously and track user patterns on Cloudwifi’s websites. A cookie is a small text file containing a unique identification number that identifies a Web Site User’s browser – but not the Web Site User personally – to Cloudwifi’s computers each time a Web Site User visits one of the Cloudwifi websites using cookies. Cookies tell Cloudwifi which pages of its websites are visited and how many people visited each web page. This helps Cloudwifi understand consumer interests and enhance the on-line experience of visitors to the Cloudwifi websites. Cookies also serve to identify your computer so that your preferences can be saved for future visits and advertising based on your previous interaction with the site, Cloudwifi works with third parties that use these cookies to help us with such traffic management, research and analytic.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously using a tool created by the Network Advertising Initiative located at http://www.networkadvertising.org/managing/opt_out.asp. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Q2: Why does Cloudwifi collect and use Personal Information?
Customer Personal Information
Cloudwifi collects and uses Customer’s Personal Information for the following purposes, to:
establish and maintain a responsible commercial relationship with you;
for research and statistical purpose, to understand your needs as a Customer and your eligibility for products and services;
recommend particular products, services and opportunities to its Customers;
provide information to you about developments and new products;
develop, enhance and market products and services and/or provide products and services to its Customers;
process billing and collect fees for the Cloudwifi products and services you have purchased and/or subscribe to;
perform or order credit checks;
deliver its products and/or services to its Customers, including providing you with the programming content corresponding to your location;
provide customer support; and
meet Cloudwifi’s legal and regulatory requirements.
Employee Personal Information
Cloudwifi collects and uses Employee’s Personal Information for the following purposes, to:
administer payroll and benefits;
administer personnel and employment programs;
document an Employee’s file in the normal course of the employment relationship (i.e. performance reviews, etc.); and
provide references regarding current or former employees in response to requests from prospective employers.
Web Site Users Personal Information
Cloudwifi collects Web Site User’s Personal Information for purposes generally identified on the Cloudwifi website at the time of collection. These purposes may include to:
send you information, updates you’ve requested, or answer your questions;
register your participation to a contest; and
register you in an encrypted secure zone.
When Cloudwifi chooses to use Personal Information for a purpose not previously identified, Cloudwifi will identify the new use. Unless such new use is required or permitted by law, in accordance with PIPEDA, the consent of the Customer, Employee or Web Site User is required before the Personal Information can be used for that new purpose.
Q3: How does Cloudwifi obtain your consent?
Consent is generally required for the collection of Personal Information and the subsequent use or disclosure of the Personal Information. Consent can be either express or implied. The form of consent sought by Cloudwifi may vary, depending upon the circumstances and the type of Personal Information. In determining the form of consent to use, Cloudwifi takes into account the sensitivity of the information and your reasonable expectation, so that you understand the nature, purpose and consequences of the collection, use and/or disclosure of Personal Information. Cloudwifi generally seeks express consent when the Personal Information is likely to be considered sensitive. Implied consent is typically appropriate when the Personal Information is less sensitive.
Business Contact Information can be used by Cloudwifi without consent solely for the purpose of facilitating communication between Cloudwifi and an employee, in relation to his/her employment, business or profession.
In addition, in exceptional circumstances, as permitted by law, Cloudwifi may collect, use and/or disclose Personal Information without a Customer’s, Employee’s or Web Site User’s knowledge or consent.
Consent may be obtained in any one of the following ways:
an application form may be used to seek consent, collect Personal Information and inform the Customer of the use that will be made of the Personal Information. By completing and signing the form, the Customer is giving consent to the collection and the specified uses;
a check-off box may be used to allow the Customer to request that their names and addresses are not given to other organizations. Customers who do not check the box are assumed to consent to the transfer of their information to third parties;
orally when information is collected over the telephone; or
at the time a Customer uses a product or service.
Consent may be withdrawn by Customers, Employees and Web Site Users at any time, subject to legal or contractual restrictions and upon providing Cloudwifi reasonable notice. If you wish to withdraw your consent to certain collection, retention, use or disclosure of Personal Information, please contact Cloudwifi at email@example.com. Please note that if you refuse or withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact on you at the time, to help you with your decision.
Q4: When and how does Cloudwifi disclose Personal Information?
Internally, only Cloudwifi Employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information of Cloudwifi’s Customers, Web Site Users and Employees.
Customer Personal Information
Cloudwifi may disclose Customer’s Personal Information to:
third parties who are acting on Cloudwifi’s behalf as our agents, suppliers or service providers who are subject to confidentiality requirements;
a company who will be involved in supplying the Customer with communications or communications directory-related products and/or services;
a company or individual who is acting on Cloudwifi’s behalf for the development, enhancement, promotion, marketing, sale or provision of any of Cloudwifi’s current products and/or services or for any new products and/or services of Cloudwifi, including authorized resellers and sales agents, etc. subject to confidentiality requirements;
in conjunction with special offers or programs to program partners, or third party agents responsible for administering such offers or programs. Any such disclosure is made on a confidential basis;
an agent used by Cloudwifi to evaluate the Customer’s credit worthiness or to collect the Customer’s account;
a credit reporting agency; and
a third party, where the Customer has given Cloudwifi consent to such disclosure or if disclosure is permitted or required by law, in accordance with PIPEDA.
Employee Personal Information
Cloudwifi may disclose Employees’ Personal Information to:
a third party for payroll and benefits administration;
a third party to administer personnel and employment programs, and
a third party, where the Employee has given Cloudwifi consent to such disclosure or if such disclosure is permitted or required by law, in accordance with PIPEDA.
Web Site User Personal Information
Cloudwifi may disclose Web Site User’s Personal Information to:
a third party or parties, where the Web Site User has given Cloudwifi consent to such disclosure or if disclosure is permitted or required by law, in accordance with PIPEDA.
Disclosure of Personal Information to government organizations, including law enforcement agencies:
Cloudwifi routinely receives requests from government organizations, including law enforcement agencies. These requests are individually and carefully vetted internally by a team of experts. Cloudwifi will only disclose Personal Information in response to these requests when permitted by law, in accordance with PIPEDA.
Q5: Who does Cloudwifi share Personal Information with?
Cloudwifi does not sell Personal Information about its Customers, Employees and/or Web Site Users. Cloudwifi may share Customers’ Personal Information with its partners, associates and third party service providers as provided in Question Q4, in order to fulfill the purposes identified in Question Q2. In such cases, the relationship with the partner, associate or third party is governed by strict confidentiality standards and policies to ensure the Customer’s Personal Information is secure and treated in accordance with PIPEDA and with the utmost care and respect.
Except as required or permitted by law, when disclosure is made to a third party other than a Cloudwifi partner or associate, or a third party service provider, the consent of the individual shall be obtained and reasonable steps shall be taken to ensure that any such third party has Personal Information privacy procedures and policies in place that are comparable to those implemented by Cloudwifi. Such third parties are provided only with such information as is necessary in the circumstances. Personal Information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.
Q6: How does Cloudwifi safeguard your Personal Information?
The nature of the safeguards varies depending on the sensitivity of the Personal Information, the scope of the Personal Information, and the method of storage of that information. More sensitive types of Personal Information will be safeguarded by a higher level of protection, including encryption. Personal Information is predominantly stored in Canada and the United States, under strict confidentiality standards, as per Question Q5. Data is routed domestically and may be routed outside of Canada for service provision purposes as described in Question Q5.
Q7: How long does Cloudwifi retain your Personal Information?
We retain your personal information for as long as it is needed to fulfill the purpose(s) for which it has been collected. Our general retention guideline is a 7-year period, which extends to all our corporate records including our customer & billing database. This allows us to meet our financial accountability and SOX audit obligations. Outside of the 7-year period, retention is defined based on length of time information is needed to meet the purpose(s) for which it has been collected and takes into account the sensitivity of the personal information. For example, we keep records of IP address leases for 1 year after a lease expires.
Q8: How do I access Cloudwifi’s policies and procedures?
Cloudwifi makes available to Customers, Employees and Web Site Users specific information about its policies and procedures relating to the management of Personal Information, on our corporate and community websites.
Cloudwifi is open about its policies and procedures with respect to the management of Personal Information. Customers, Employees and Web Site Users are able to inquire about Cloudwifi’s privacy policies and procedures and obtain an account of the Personal Information Cloudwifi holds about them at a minimal cost and without unreasonable efforts on their part. This information is available by writing to Cloudwifi’s Privacy Offer at P.O. Box 27005, Kitchener, ON, N2E 3K2.
Q9: How do I access my Personal Information?
You may access and verify your Personal Information held by Cloudwifi by submitting a request in writing to Cloudwifi’s Privacy Officer at P.O. Box 27005, Kitchener, ON, N2E 3K2. A response will be mailed to the address on your account or file.
Cloudwifi will respond to a Customer’s, Employee’s or Web Site User’s request within a reasonable period of time and at minimal or at no cost.
In certain circumstances, Cloudwifi may not be able to provide access to all the Personal Information it holds, for example, when the disclosure would reveal confidential business information; if the Personal Information is protected by solicitor-client privilege, or if the Personal Information was collected during an inquiry into a breach of contract or violation of a federal or provincial law.
Q10: How can I challenge compliance and offer suggestions?
Cloudwifi will investigate all complaints and respond to all questions asked by its Customers, its Employees and/or Web Site Users. If a complaint is found to be justified, Cloudwifi will take appropriate measures to resolve the complaint, which may include amending its policies and procedures.
If Customers, Employees or Web Site Users are not satisfied with Cloudwifi’s response, they may contact the Office of the Privacy Commissioner of Canada, at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Your role in protecting your Personal Information:
Cloudwifi does its best to protect and safeguard Personal Information and we believe there are safeguards you should take as well. Do not share your Personal Information such as bank card numbers, credit card numbers, associated pin numbers or Social Insurance numbers unless you clearly understand the purpose of the request and you know with whom you are dealing. Do not keep sensitive Personal Information in your email inbox or on Webmail.
Whenever you are asked to assign passwords, we recommend use a combination of letters (upper and lowercases), numbers and symbols and do not use words that can be easily associated with you (example: do not use the name of a family member or pet). We also suggest you change your passwords regularly.
If you are suspicious of any telephone, mail or email promotional campaigns that appears to be coming from Cloudwifi or you suspect fraudulent activity, please contact us at firstname.lastname@example.org to verify that the campaign is a legitimate Cloudwifi activity.