Privacy Policy

1.     POLICY PURPOSE

• telMAX (the “Company”) is committed to protecting the privacy and security of personal information it handles in the course of its business, and with ensuring its ongoing compliance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”). This Privacy Policy (the “Policy”) describes how telMAX collects, uses, discloses and protects personal information.
• In general, this Policy is intended to ensure that the Company obtains an individual’s consent when it collects, uses or discloses that individual’s personal information, and that people have the right to access their personal information held by telMAX. Personal information will only be used for the purposes for which it was collected, and if telMAX wishes to use it for another purpose, consent for that purpose will be obtained. The Company will ensure that personal information is protected by appropriate safeguards.
• telMAX will only use personal information in accordance with this Policy unless otherwise required by applicable laws. As a federally regulated organization, PIPEDA and this Policy also apply to the Company’s employees’ personal information.

2.     SCOPE

• This Policy is based upon the ten inter-related fair information principles set out in Schedule 1 of PIPEDA. The principles are:

1. Accountability
2. Identifying purposes
3. Consent
4. Limiting collection
5. Limiting use, disclosure and retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual access
10. Challenging compliance

• This Policy applies to the Company’s management of personal information in any form, including electronic, written, oral, or presented on a website or social media platform. In addition to these principles, PIPEDA requires that any collection, use, or disclosure of personal information must only be for purposes that a reasonable person would consider appropriate in the circumstances. For clarity, this Policy applies, without limitation, to all information provided by customers, team members, or users of telMAX’s websites. The application of the Policy is subject to the requirements of any application legislation or other determination of a court or other lawful authority, including the CRTC.

3.     DEFINITIONS

• Customer: An individual who uses or applies to use telMAX products or services or otherwise provides personal information to telMAX.
• Personal Information: Any factual or subjective information about an identifiable individual, recorded or not. For a customer or potential customer, it may include billing and credit information, or records of disputes. For an employee or other staff, it could include employee files, compensation information, performance evaluation, or benefits details. Personal information does not include aggregated or anonymized information that cannot reasonably be associated with a specific individual, or the name, title, and contact details (email and business telephone numbers) of an employee of an organization.
• Team Member: A former, current, or prospective employee, agent, or contractor providing services to telMAX.

4.     PRINCIPLES

4.1  ACCOUNTABILITY

• The Executive Committee of telMAX, comprising the CEO, CRO, COO, CFO, and the VP of Business Enablement and People, is responsible for enforcing this Policy. The VP of Business Enablement and People oversee compliance with both this Policy and PIPEDA and can be contacted at privacy@telmax.com. Delegated staff may assist the Privacy Officer or handle daily personal information processing.
• telMAX is responsible for all personal information in its possession or control, including information that has been transferred to a third party for The company will use appropriate means, including contractual obligations, to ensure a comparable level of protection while information is being processed by a third party (see Principle 7).
• telMAX has implemented policies and practices to give effect to this Policy, including (i) implementing procedures to protect personal information and to oversee team members’ compliance with the Policy; (ii) establishing procedures to receive and respond to inquiries or complaints; (iii) providing training to team members about this Policy and practices; and (iv) making available public information to explain telMAX’s policies and practices, including posting this Policy on its website.

4.2  IDENTIFY PURPOSE

• The Company shall identify the purpose for collecting personal information to customers or team members at or before the time the information is If requested, team members shall explain the purpose to the customer or team member (or obtain the assistance of another team member who can explain.
• As examples, telMAX collects personal information for the following purposes:
  • To establish and maintain customer accounts and commercial relationships, and to maintain services to customers
  • To understand customers needs, interests, and preferences
  • To develop, market, and provide products and services to customers
  • To maintain records for team members, including personnel and employment matters
  • To otherwise manage and develop the business, and
  • To ensure compliance with legal and regulatory requirements
• telMAX uses analytics tools on its websites to the purposes of analyzing how customer use the sites. These statistics are anonymized and assist in website personalization and support tasks. The analytics tools may place cookies on customer devices, but customers may opt out of receiving cookies.
• telMAX collects limited networking information for devices the company manages for analytical and troubleshooting purposes, such as analyzing wi-fi issues, and to perform remote management. These activities will not expose any customer traffic or content.
• Customers may contact telMAX on different channels (call centre or chat, for example) for support or information, and telMAX may record such interactions for training and analytics purposes. In some cases, artificial intelligence and/or chatbots may be used to expedite interactions with support representatives.

4.3  OBTAIN CONSENT

• The company is generally required to obtain consent for the collection, use, and disclosure of personal information, for each specified and legitimate purpose. Individuals can withdraw their consent at any time and with reasonable notice, subject to legal or contractual restrictions and reasonable notice.
• In obtaining consent, telMAX will use reasonable efforts to ensure that the customer or team member is advised of the purpose for which personal information will be used or disclosed, and that the purpose can be reasonably understood.
• telMAX will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of its product or services if this information is necessary to fulfill the requirements of the product or In general, the use of the product or services by a customer, or acceptance of employment or benefits by a team member, constitutes implied consent for the collection, use and disclosure of the related personal information
• express consent shall be obtained for the collection, use and disclosure of sensitive information, when the collection, use and disclosure may be outside the reasonable expectations of the individual, or when the collection, use or disclosure crates a residual risk of significant harm

4.4  LIMIT COLLECTION

• The Company shall collect only the personal information needed to fulfill legitimate identified business purposes. Personal information shall be obtained by fair and lawful means. Personal information is typically collected from customers and team members but may also be obtained from sources including credit bureaus, personal references, or other third parties which represent they have the right to disclose the information.

4.5  LIMIT USE, DISCLOSURE, AND RETENTION

• telMAX will only use or disclose personal information for the purpose for which it was collected and shall only retain the personal information for as long as it is needed to fulfill such purpose. Any unneeded personal information shall be destroyed, erased, or permanently anonymized.
• The use of customer personal information may include but isn’t limited to:
  • Activating or disconnecting services of both telMAX and third-party infrastructure
  • Providing notifications regarding service changes
  • Responding to billing or technical support inquiries
  • Initiating trouble tickets
  • Collection of delinquent accounts
  • As required by law, for example in response to a valid subpoena or to protect an individual’s safety
• The use of team member information may include but isn’t limited to:
  • Payroll processing
  • Benefits administration
  • Disclosure required by law
• The use of personal information within the business shall be limited and monitored.
• All company devices, including computers and mobile phones, shall have any personal information securely removed prior to re-assignment or disposal.

4.6  ACCURACY

• Personal information shall be maintained to ensure ongoing accuracy and completeness for its purpose.
• Team members and customer shall be requested to update their personal information when it changes, and telMAX shall update its records in a timely manner upon notification.

4.7  SAFEGUARDS

• telMAX has implemented and will maintain appropriate physical, technical, and organizational security measures designed to secure personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition,
• telMAX limits access to personal information team members and other third parties that have a legitimate need for such access. Access to personal information shall be managed in part through the use of user security on all business applications which provide access to personal information, and by ensuring restrictions on distribution of reporting which includes personal information.
• telMAX requires all team members and third-party service providers, by written contract stipulating the confidentiality of the personal information, to implement appropriate security measures to respect and protect customer and team member personal information consistent with telMAX’s policies, including data security obligations.

4.8  OPENNESS

• telMAX will make this policy and supporting practices relating to the management of personal information available to customers and team members. This policy shall be available on telMAX websites and mobile applications, and available by email or other means if requested. Team members providing customer service to customers shall have sufficient training to be familiar with this Policy and be able to explain our procedures regarding inquiries about personal information (such as how to access personal information, what information has been retained, how to complain, what information we share with others)

4.9  INDIVIDUAL ACCESS

• Customer and team members shall be able to access their personal information that has been retained by the Company. They are entitled to challenge the accuracy and completeness of their personal information, and have it amended as appropriate.
• Upon request, the Company will advise customers and team members about the personal information held, explain how it is being used, and if and to whom it has been disclosed. The information shall be provided in a timely manner and at minimal or no cost. If personal information cannot be disclosed for any reason, telMAX shall provide the reason for denying access. Unless there are unusual circumstances which are communicated to the requestor, requests shall be responded to within thirty (30) days.
• The Company will correct or complete any personal information that a customer or team member has identified as being inaccurate. If requested, personal information can be deleted, however some services may not be available without some personal
• Customers can obtain information about their personal information by contacting a customer services representation at 905-233-7377 using a “contact us” form on the telMAX website, or by emailing support@telmax.com.
• Team members can obtain information about their personal information by speaking with their manager or a member of the People Operations team.
• Customers or team members can also contact the Privacy Officer at 1-844-483-5629 or by emailing privacy@telmax.com.

4.10   CHALLENGING COMPLIANCE

• Individuals shall be able to challenge telMAX’s compliance with these fair information policies and this Policy. They can address their challenge to the Privacy Officer, or any member of the telMAX Executive Committee.
• telMAX shall manage a simple complaint and response process, by recording all complaints and details, acknowledging receipt, and ensuring the complaint is investigated in a timely manner. External advice shall be obtained when appropriate.
• Any individual making a complaint under this policy shall receive a written response, indicating the findings, and the actions taken to correct information or amend policies and/or practices.

5.     Policy Revision

• This Policy will be reviewed from time to time, but at least every year, to reflect changes in legal or regulatory obligations, or to reflect changes in best practices for managing personal information. Updated versions will be available on our websites and from us directly. By continuing to be customers and team members, individuals agree that their personal information will be managed under the current Policy.