Confidentiality Policy

1. Introduction

The right to privacy is of the greatest importance at Komutel Inc. (hereinafter referred to as “Komutel”) and we care about any question related to the confidentiality of the personal information provided to us. Our safety, privacy and confidentiality policy aims to inform you about our practices regarding your personal information.


2. Personal Information

 Any information about an individual that identifies him or her, such as financial, lifestyle or health information, but not their name, title or business address, telephone or email.Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.Collecting information about you is necessary in order for us to provide you with high quality services. The nature and sensitivity of the information we collect about you varies according to the services we provide you.The purposes for which we collect personal information about you are identified at or before the time of collection.


3. Consent

 When we collect personal information from you, we obtain your consent to use the information for the purposes collected. We will obtain your consent for any additional use or collection, or if the purpose of using the information is changed.We generally seek your express written consent in order to collect, use or disclose personal information. Where appropriate, for less sensitive information, we may accept your verbal consent. Occasionally, we may imply consent where we can infer consent from your action or inaction.You may withdraw your consent at any time, subject to legal or contractual restrictions. We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or process a request. If you choose not to consent, we will record the decision in our file.In limited circumstances, we have the right (or obligation) to collect, use or disclose personal information without your knowledge and consent. This occurs when legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking consent might defeat the purpose of the information collection.Similarly, seeking consent may be impossible or inappropriate when you are a minor, seriously ill or otherwise incapacitated.


4. Limits to collection, Use and Disclosure

 We limit the collection of your personal information to what we need in relation to the purposes identified to you.We collect the information directly from you unless you allow us to collect information from a third party or in accordance with the law.We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use or share your personal information for other purposes or to anyone without your consent, except as required by law.Your personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties, whom have committed in writing to comply to the present policy including the Code of ethics of the CWTA/ACTF of September, 1st, 2004.You have the right to know, on request, to whom the information was disclosed. Only in rare instances are we prevented by law from making such disclosure. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.We will occasionally share your personal information with service providers or agents to ensure the proper administration of products, or to provide you with the services you require. These service providers or agents must agree to comply with privacy legislation before receiving any personal information.In certain circumstances, we may use service providers outside Canada. We are responsible for the service provider’s compliance with our Privacy Policy and will ensure that the level of protection of personal information is comparable to that provided by us. Any questions concerning the collection, transfer or use of personal information outside Canada can be forwarded to the Privacy Officer at


5. Retention

We only retain your personal information for as long as needed for the purpose it was collected. We must destroy this information in accordance with the law. When we destroy your personal information, we make sure that confidentiality is secured and that no unauthorized person can access the information during the destruction process.


6. Google Analytics

 This site uses Google Analytics, a website analytics by Google Inc. Google Analytics uses cookies, which are text files placed on your computer, to help Komutel analyze the use of this site by its visitors. Data generated by cookies about your use of this site (including your IP address) will be transmitted and stored by Google on servers located in the United States. Google will use this information to evaluate your use of this site, compile reports on the activity of this site to its publisher and provide other services related to Internet activity and use. Google may disclose this data to third parties in the event of a legal obligation or when these third parties process this data on behalf of Google, including the publisher of this site. Google will not cross-reference your IP address with any other data held by Google.By using this site, you expressly consent to Google’s processing of your personal data under the conditions and purposes described above.If you don’t want us to keep this information, your browser’s Help module shows how to prevent new cookies from being accepted. However, if you decide to refuse cookies, you may not be able to take advantage of certain products and/or services on this site.


7. Client list

We do not sell client lists to third parties.



 We are responsible for your personal information in our possession or control, including information that may be transferred by us to third parties for processing. We require such third parties to keep personal information under strict standards of privacy and protection.We adhere to legislated and self-imposed rules, aimed to safeguard your privacy. The rules are established by this Privacy Policy.Our staff is trained on these processes and procedures and is provided with information about privacy laws, safety and confidentiality of personal information.


9. Security

 We have implemented and continue to implement rigorous safeguards so that your personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Protection methods include organizational measures such as requiring security clearances (at the time of the hiring by Komutel) and limiting access to a “need-to-know” basis, physical measures (e.g. secured access to the buildings of Komutel, off-site Cloud backups and archiving with a security provider on site), and technological measures such as the use of password and encryption (e.g. the use of routinely changing passwords, firewalls and segmented operator access).


10. Request for Access to Information and Amendments

 You have the right to be informed whether we hold personal information about you and to see that information. You also have the right to enquire as to how we collected your information, how we used it and to whom it may have been disclosed.This information will be provided to you within a reasonable time from the date we receive your written request. We may charge a reasonable fee for processing your request.In certain limited and specific circumstances, we may refuse to provide to you the requested information. Exceptions to your access right can include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege.You may challenge the accuracy and completeness of your personal information. We will respond to an amendment request within a reasonable time.Officer in charge of the protection of personal information Komutel at


11. Complaints and Concerns

 Our employees and representatives are trained to respond to your questions or concerns about personal information. Should you be unsatisfied with our employee’s or representative’s response, you may contact the Privacy Officer at the address mentioned above.Complaints concerning the protection of personal information should be addressed to the Privacy Officer at the address provided above.

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