Luna Geospatial Inc. (hereinafter “LunaGeo”) is committed to protecting the personal information of its employees, clients and users. This personal information is managed in accordance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable laws.
In order to ensure consistency with privacy policy best practices, LunaGeo’s Privacy Policy is guided by ten internationally recognized privacy principles, contained in Schedule I of PIPEDA. The policy applies to LunaGeo and to any person providing services on its behalf.
What is the definition of personal information?
Personal information is information about a particular, identifiable person. For example, a person’s name, address, phone number and financial information are considered personal information.
How is personal employee information defined?
Personal employee information is information about an employee that is collected, used, or disclosed only for the purposes of an employment relationship. Personal employee information may include a Social Insurance Number or a performance review of an employee.
Accountability
LunaGeo is responsible for personal information in its custody or control, including personal information that is shared with persons operating on its behalf (ie. information technology providers). LunaGeo requires all its employees and service providers to sign confidentiality agreements to ensure that personal information is protected in compliance with this Policy and the law.
LunaGeo has designated a Chief Privacy Officer ultimately responsible for ensuring LunaGeo’s compliance to this Privacy Policy. The Chief Privacy Officer can be contacted at privacy@lunageo.com, or by mail at PO Box 67033, RPO Sunningdale, London, Ontario, N6G 0V5. All correspondence should be directed to the attention of the Chief Privacy Officer.
Purposes for collecting information
Employees, clients, and users are informed prior or during the collection of personal information of the purposes of its collection. This information is made available through this Privacy Policy and on LunaGeo’s website.
LunaGeo will not collect, use, or disclose personal information for a new purpose that was not previously identified without explaining the new purpose and obtaining consent, unless otherwise permitted by law.
LunaGeo collects and uses personal information directly from clients and users in order to assist in developing, improving, or enhancing its services.
LunaGeo may collect, use, or disclose personal employee information in order to:
- Establish training and development requirements;
- Assess performance and management performance issues if they arise;
- Administer pay and benefits;
- Process employee work-related claims (ie. benefits, workers compensation, insurance claims); and
- Compliance with applicable laws (ie. Canada Income Tax Act, provincial Employment Standards Act).
After an employee relationship is terminated, LunaGeo may be contacted by other companies and asked to provide references. It is LunaGeo’s policy not to disclose personal information about any employees to other individuals or companies who request references without consent. The personal information generally provided in a reference includes:
- Confirmation of employment, including the position, and dates of the employment; and
- General information about an individual’s job duties and information about the employee’s ability to perform tasks and success in the employment relationship.
Collection limitations
LunaGeo collects only the personal information needed for the purposes of providing services to clients and users. Personal information is generally collected directly from the clients or users. With the consent of clients and users, LunaGeo may collect information from other persons with consent or as authorized by law.
Consent
LunaGeo asks for consent to collect, use, or disclose client and user personal information, except in particular situations where collection, use, or disclosure without consent is authorized or required by law.
LunaGeo assumes it has client and user consent to continue to use and, where applicable, disclose personal information that has already been collected, for the purpose for which the information was collected.
LunaGeo asks for express consent for some purposes and may not be able to provide certain services if there is an unwillingness to provide consent to the collection, use, or disclosure of certain personal information. Where express consent is needed, LunaGeo will normally ask to provide consent in writing.
Consent to the use of personal information can be withdrawn at any time for the following purposes:
- Marketing initiatives for services;
- Collecting personal information from personal referrals;
- Direct contact through an approved third party to administer surveys.
These uses and disclosures can be opted out of by contacting LunaGeo’s Chief Privacy Officer. Once the opt-out request is received, LunaGeo shall process it within TEN (10 ) days.
LunaGeo may collect, use, or disclose personal information without consent only as authorized by law.
LunaGeo can collect, use and disclose personal employee information without consent only for the purposes of establishing, managing, or ending the employment relationship. Employees will be provided with prior notice about what information is collected, used, or disclosed and the purpose for doing so.
Employees consent to collect, use, and disclose their personal information for purposes unrelated to the employment will have to be obtained.
Limiting the use, disclosure, and retention of personal information
LunaGeo uses and discloses the personal information of employees, clients and users only for the purpose for which the information was collected, except as authorized by law.
If LunaGeo wishes to use or disclose personal information for any new business purpose, it will ask for specific consent. LunaGeo may not seek consent if the law permits the use or disclosure.
LunaGeo retains personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.
Use of service providers internationally
At LunaGeo, there are organizations that provide hosting and other services on its behalf that may process or store personal information outside of Canada. These organizations process or store personal information for the purposes of database management and hosting. The Chief Privacy Officer can be contacted to obtain more information about LunaGeo’s use of service providers outside Canada, including, for example, the location of the provider, and how the information is collected, used, stored and protected.
Accuracy of personal information
LunaGeo makes every reasonable effort to ensure that personal information is accurate and complete. It relies on immediate notification as soon as possible if there is a change to any personal information. If there is an error in LunaGeo’s information, LunaGeo must be informed so that the information can be corrected wherever possible. A written request may be required.
Safeguards
LunaGeo protects personal information in a way appropriate for the sensitivity of the information and every reasonable effort is made to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information.
LunaGeo protects personal information in its custody and controls it in the following ways:
- Administrative Safeguards: Administrative safeguards are employed, such as this Privacy Policy and confidentiality agreements, to make sure that LunaGeo employees access personal information for authorized purposes only. Employees are trained to understand the Privacy Policy and employees are regularly reminded of their privacy responsibilities;
- Technical Safeguards: Technical safeguards are employed, such as passwords, encryption, and role-based access controls for information systems from which personal information may be accessed; and
- Physical Safeguards: Physical safeguards are employed to protect personal information by locking filing cabinets, restricting physical access to offices and data centres, and shredding paper records no longer needed.
Openness and transparency
LunaGeo makes available to its employees, clients and users the specific information about policies and practices regarding the management of personal information. This information is available in this Privacy Policy or by contacting the Chief Privacy Officer.
This information describes, for example:
- The nature of the personal information in LunaGeo’s custody or control;
- How personal information is collected, used, and disclosed, and its purposes;
- How LunaGeo protects personal information in its custody and control;
- How access can be gained to, and personal information be corrected;
- How to opt out of specific uses and disclosures of personal information; and
- How to contact LunaGeo’s Chief Privacy Officer with questions or complaints.
Individual access
Individuals have a right to access their own personal information in a record that is in the custody or under the control of LunaGeo, subject to some exceptions.
If LunaGeo refuses a request in whole or in part, motives for the refusal will be provided. Sometimes where exceptions to access apply, LunaGeo may withhold that information and provide the remainder of the record.
A request may be made for access to personal information by completing the Access and Correction Request Form and submitting it to the Chief Privacy Officer. Appropriate detail must be provided in the request to allow LunaGeo to identify the information that is sought.
In the case where Information is requested regarding LunaGeo’s use of personal information, or a request for the correction of an error or omission may be made, LunaGeo may respond or implement the necessary changes, where possible.
Requests will be responded to within THIRTY (30) days, unless an extension is granted. A small fee may be charged to provide information, but not be charged in the case of correction(s) to personal information. Fees will not be charged when the request is for personal employee information. Employees, clients, and users will be advised of any fees that may apply before beginning to process the request.
Google AdWords
LunaGeo may use Google AdWords Remarketing to advertise LunaGeo across the Internet, in particular on the Google Display Network. AdWords Remarketing will display ads based on what parts of LunaGeo or LunaMap Enterprise have been viewed by placing a cookie on web browsers.
The cookie does not in any way identify the client or user or give access to their computer or mobile device(s). The cookie is used to indicate to other websites that the client or user visited a particular page, so ads relating to that page are displayed.
Google AdWords Remarketing allows LunaGeo to tailor its marketing to better suit client and user needs and only display ads that are relevant to them.
If the client or user does not wish to see LunaGeo ads they can opt out of Google’s use of cookies by visiting Google’s Ads Settings, or opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.
Questions or complaints
Any questions or concerns about any collection, use or disclosure of personal information by LunaGeo, or requests for access to personal information can be sent to LunaGeo’s Chief Privacy Officer.
Any employee, client or user who is not satisfied with the response received can contact the Office of the Privacy Commissioner of Canada by phone (1.800.282.1376) or by filling out a complaint form available at www.priv.gc.ca/en/report-a-concern/ and submitting the completed form by mail to:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B
3rd Floor
Ottawa, ON K1A 1H3