Internet Marketing

advertising, promotion, account verification); (c) to identify customer needs and/or preferences; (d) to meet legal and regulatory requirements; (e) to administer and manage its business operations 2.2 Startec Canada will provide notice of the identified purposes either orally, electronically or in writing prior to or at the time of collection of the personal information. 2.3 Persons collecting personal information will be able to explain to individuals the purposes for which the information is being collected, or will refer the individual to a designated person at Startec Canada who will explain the purposes. 2.4 When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, Startec Canada will obtain the consent of the individual before information is used for that new purpose. Occasionally, Startec Canada will communicate to you special bonus and new product offers that we think may be of value to you. If you wish to opt-out of receiving targeted communications from Startec Canada in electronic, printed or verbal format (other than information included with your monthly bills), simply inform us in writing at Startec Global Communications c/o Privacy Officer, 7361 Calhoun Place, Rockville MD 20855 III. Consent The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate. 3.1 In certain circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when there is an emergency threatening the individual life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. Moreover, Startec Canada may provide personal information to its lawyer or agent to collect a debt, comply with a subpoena, warrant or other court order, government institution requesting the information upon lawful authority, or as may be otherwise required by law. 3.2 Startec Canada will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Startec Canada wants to use information for a purpose not previously identified). 3.3 Startec Canada will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed. 3.4 Startec Canada will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfil the explicitly specified and legitimate purposes. 3.5 The form of consent sought by Startec Canada may vary, depending upon the circumstances and the type of information disclosed. In determining the form of consent to use, Startec Canada will take into account the sensitivity of the information and the reasonable expectations of the individual. An authorized representative (such as a legal guardian or a person having power of attorney) can also give consent. Startec Canada will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate when the information is less sensitive. The use of services or products by a customer or the acceptance of employment by an employee will be considered implied consent to collect, use and disclose personal information for all identified purposes. 3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Startec Canada will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to Startec Canada in writing. 3.7 With respect to personal information already collected by Startec Canada prior to the publication of this Privacy Policy, this Policy will constitute reasonable notice to Startec Canada current customers and employees of the purposes and uses for which such personal information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to Startec Canada in writing. IV. Limiting Collection The collection of personal information will be limited to that which is necessary for the purposes identified by Startec Canada. Information will be collected by fair and lawful means. 4.1 Startec Canada collects personal information from its customers and employees for the purposes described under Principle #2. 4.2 Startec Canada may also collect personal information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information. 4.3 In connection with its Internet business, Startec Canada may use a eookie to collect certain information which it uses to track user patterns on its web site(s). A Cookie is a text file containing a unique identification number that identifies a user browser, but not a particular individual. A Cookie does not identify an individual. Furthermore, Startec Canada does not use Cookies in combination with other information to obtain personally identifiable information. If an individual does not wish to use Cookies, he or she can re-set their browser to either provide notification or refuse to accept Cookies. V. Limiting Use, Disclosure, and Retention Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. 5.1 Startec Canada may collect, use or disclose personal information without the individual knowledge or consent in certain circumstances as described in Principle #3.1. 5.2 Startec Canada may disclose a customer personal information to: (a) another telecommunication company for the provision of telecommunications services to that customer; (b) a company involved in providing communications directory services; (c) a person involved in the development, promotion, marketing or enhancement of Startec Canada services; (d) a credit collections agency; (e) emergency services in an emergency situation; (f) a person, who, in the reasonable estimation of Startec Canada, is an agent of the customer; (g) any other third party, upon receiving the consent of the customer or as required by law. 5.3 Startec Canada may disclose an employee personal information in the following circumstances: (a) in the administration of that employee benefits; (b) in providing references to prospective employers, upon receiving the consent of the employee; (c) as may be required by law. 5.4 Certain Startec Canada employees may be given access to customer and/or employee information in so far as their duties require access for business purposes. Startec Canada employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes. 5.5 Startec Canada will retain personal information for only as long as required to fulfil the identified purposes or as required by law. 5.6 Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Startec Canada. VI. Accuracy Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. 6.1 The extent to which personal information will be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual. 6.2 Startec Canada will not routinely update personal information unless such a process is necessary to fulfil the purposes for which the information was collected. 6.3 Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out. VII. Safeguards Personal information will be protected by security safeguards appropriate to the sensitivity of the information. 7.1 Startec Canada will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage. 7.2 Startec Canada protects all personal information regardless of the format in which it is held. The methods of protection include: (a) physical measures, such as locked filing cabinets and restricted access to offices; (b) organizational measures, such as security clearances and limiting access on a eed to know basis; (c) technological measures, such as the use of passwords and encryption 7.3 Startec Canada makes their employees aware of the importance of maintaining the confidentiality of personal information. Startec Canada employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes. 7.4 Startec Canada will use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. VIII. Openness Startec Canada will make readily available to individuals specific information about its policies and practices relating to the management of personal information. 8.1 Startec Canada will make its policies and practices with respect to the management of personal information easily comprehensible and accessible, by providing upon request: (a) the name, title, and address of the Privacy Officer accountable for Startec Canada's policies and practices and to whom complaints or inquiries can be forwarded; (b) the means of gaining access to personal information held by Startec Canada; and (c) a description of the type of information held by Startec Canada and/or its subsidiaries, including a general account of its use. 8.2 Startec Canada will make this Privacy Policy available online, by mail, or in a brochure format at its place of business. Furthermore, Startec Canada Customer Services Representatives will be trained to answer requests at Startec Canada toll-free customer service telephone number. IX. Individual Access Upon request, an individual will be in monebaggasse