Objective & Scope of Policy
The Comfy Cow is dedicated to maintaining high standards of confidentiality with respect to protecting personal information that is provided to us. This policy statement has been prepared to affirm our commitment to maintaining the privacy of our clients and others and to inform you of our practices concerning the collection, use and disclosure of Personal Information collected by The Comfy Cow.
The Comfy Cow Commitment
We are governed by the British Columbia Personal Information Protection Act, which imposes obligations regarding the way private sector organizations within Alberta collect, use and disclose personal information. The Comfy Cow will protect your privacy, and in particular your personal information, in accordance with the 10 Principles of Privacy which have been established by the Government of Canada and the Government of Alberta: Accountability: The Comfy Cow is responsible for personal information under its control. The Comfy Cow will designate one or more persons who are accountable for compliance with the 10 Principles of Privacy:
- Identifying purposes: The Comfy Cow will identify the purposes for which personal information is collected at or before the time the information is collected.
- Consent: Consent is required for The Comfy Cow collection, use or disclosure of personal information, except where required or permitted by law.
- Limiting collection: Personal information collected will be limited to that which is necessary for the purposes identified by The Comfy Cow.
- Limiting use, disclosure and retention:The Comfy Cow will not use or disclose personal information for purposes other than those for which the information was collected, except with your consent or as required by law.The Comfy Cow will retain personal information only for as long as is necessary to fulfill the purposes for collecting such information.
- Accuracy: Personal information will be maintained by The Comfy Cow in an accurate, complete and up-to-date form as is necessary to fulfill the purposes for which the personal information is to be used.
- Safeguards: The Comfy Cow will protect personal information with security safeguards appropriate to the sensitivity of the information.
- Openness: The Comfy Cow will make readily available its policies and practices relating to the management of personal information.
- Customer access: Upon request, The Comfy Cow will inform you of the existence, use and disclosure of your personal information and you will be given access to your personal information, subject to any legal restrictions. You may verify the accuracy and completeness of your personal information, and may request that the information be corrected or updated, if appropriate.
These obligations apply to all professionals, franchisees, employees, contractors and agents who provide services in connection with delivery of services to our clients For the purposes of this Policy, “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. Personal information can include your name, address, telephone number (home and business), email address, date of birth, place of employment, and the nature, frequency and type of The Comfy Cow services used by you.
This policy does not cover any information, recorded in any form, about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”). The Comfy Cow retains the right to use Aggregated Information in any way that it determines appropriate.
Using contractual or other arrangements, The Comfy Cow shall ensure that franchisees, agents, or contractors, who may receive Personal Information in the course of providing services to The Comfy Cow clients, protect that Personal Information in a manner consistent with the principles articulated in this Policy Statement.
Why The Comfy Cow collects personal information and how your personal information is used.
The Comfy Cow is committed to providing superior service. The Comfy Cow collects your personal information so that The Comfy Cow may maintain your client file and provide you with the services (or products) you have requested. Your personal information is used to understand your needs and preferences, determine whether The Comfy Cow services meet your needs, develop or improve products and/or services, and to deliver services and products that you have requested.
The collection, use & disclosure of personal information
The Comfy Cow does not sell, trade, barter or exchange for consideration any Personal Information it has obtained. Unless permitted by law, no Personal Information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information.
Personal Information will be collected, to the extent possible, directly from the individual concerned.
The Comfy Cow does not knowingly collect Personal Information from anyone under the age of 18 and does not use such information if it discovers that it has been provided by a minor. The Comfy Cow may disclose Personal Information to franchise operators that perform services on its behalf. Personal Information will only be provided to such operators if they agree to use such information solely for the purposes of providing services to The Comfy Cow clients and under the instruction of The Comfy Cow and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where The Comfy Cow is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or other government tribunal;
- Where The Comfy Cow believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect money owing to The Comfy Cow;
- Where it is necessary to permit The Comfy Cow to pursue available remedies or limit any damages that The Comfy Cow may sustain; or
- Where the information is public.
- Where obliged or permitted to disclose information without consent, The Comfy Cow will not disclose more information than is required.
The Comfy Cow endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which The Comfy Cow uses that information.
The Comfy Cow keeps Personal Information only as long as it is required for the reasons it was collected. The length of time information is retained varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will only be for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for The Comfy Cow ’s purposes, we have procedures to destroy, delete, erase or convert it into anonymous form.
The Comfy Cow endeavors to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of Personal information.The Comfy Cow further protects Personal Information by restricting access to it to those franchisees and/or employees that the management of The Comfy Cow has determined need to know that information in order that The Comfy Cow may provide services. The Comfy Cow franchisees and employees are informed of the importance of protecting your privacy and are expected to maintain the confidentiality of The Comfy Cow client information at all times.
In terms of communicating Personal Information to The Comfy Cow , you may wish to note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted.
As do many organizations, The Comfy Cow attempts to strike a reasonable balance between security and convenience. In communicating with clients and others, The Comfy Cow often requests the right to use a method of communication that is less secure than some of its less convenient alternatives. An example of this is email. At this time, when we use email, it may be sent as unencrypted plain text. We do this because The Comfy Cow believes that many of our clients and others cannot readily process encrypted email. This is done for the convenience of our clients but has the security concern that, if miss routed or intercepted, it could be read more easily than encrypted email.
The Comfy Cow website
Information collected to date
The Comfy Cow would like to have your consent to continue to collect, use and disclose your personal information for the purposes identified above. The Comfy Cow is operating on the understanding that The Comfy Cow has your consent to collect, use and disclose your personal information collected to date. You may refuse or withdraw your consent at any time, subject to legal or contractual restrictions and providing The Comfy Cow with reasonable notice of the withdrawal of your consent. If you choose to withdraw consent or not provide certain personal information, your decision may limit the services The Comfy Cow can offer.
Requests for Access to Personal Information
The law permits individuals to submit written requests to us to provide them with:
Their Personal Information under our custody or control; Information about the purposes for which their Personal Information under our custody or control has been and is being used by us; and The names of persons to whom, and the circumstances in which, their Personal Information has been and is being disclosed by us. The Comfy Cow will respond to requests in the time allowed by the Personal Information Protection Act and will make reasonable efforts to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits us to charge.
An individual’s ability to access his or her Personal Information under our control is not absolute. The law provides that we must not disclose Personal Information where: The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request; The disclosure would reveal personal information about another information; or The disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity. The law further provides that we may choose not to disclose Personal Information where: The Personal Information is protected by any legal privilege; The disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information; The Personal Information was collected by us for an investigation or legal proceeding; He disclosure of the Personal Information might result in similar information no longer being provided to us when it is reasonable that it would be provided; The Personal Information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act Under an agreement, Under an enactment, or By a court; or The Personal Information relates to or may be used in the exercise of prosecutorial discretion.
The Personal Information Protection Act indicates that it is not to be applied so as to affect any legal privilege. We will not disclose information that is privileged where the applicant is not the client in whom the privilege is vested.
Requests for correction of Personal Information
The law permits individuals to submit written requests to The Comfy Cow to correct errors or omissions in their Personal Information that is in our custody or control. We will: Correct the Personal Information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; Decide not to correct the Personal Information but annotate the Personal Information that a correction was requested but not made.
Contacting or Communicating with The Comfy Cow
If you have any questions with respect to our policies concerning the handling of your Personal Information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact:
2221 Frankfort Ave
Louisville, KY 40206