Al Ghanem Net is committed to
principles of internet security and respect for your privacy. This
privacy policy explains why and when personal information is
collected and why this information is needed by Al Ghanem Net or a
third party.
Under The Personal Information
Protection and Electronic Documents Act which governs the collection,
use and disclosure of personal information in the commercial sector,
Al Ghanem Net is required to adhere to 'Ten Privacy
Principles' set out in the National Standard of Canada, Model
Code for the Protection of Personal Information effective January 1,
2001. It governs the behavior of employees and agents acting on Al
Ghanem Net behalf when dealing with personal information. The purpose
in which information is collected and used. It provides procedures
for an individual's access to and correction of personal
information.
Ten Privacy
Principles:
- Accountability
- Identifying
Purposes
- Consent
- Limiting
Collection
- Limiting Use, Disclosure and
Retention
- Accuracy
- Safeguards
- Openness
- Individual Access
- Challenging
Compliance
1.
ACCOUNTABILITY
Al Ghanem Net is responsible for
personal information under its control and will designate an
individual or individuals who are accountable for the
organization's compliance with the following
principles.
1.1 Accountability for Al Ghanem
Net compliance with the principles rests with the senior management
of Al Ghanem Net and the person or persons designated by senior
management as Privacy Officer, even though other individuals within
the organization may be responsible for the day-to-day collection and
processing of personal information. In addition, other individuals
within the organization may be delegated to act on behalf of senior
management or the Privacy Officer.
1.2 Al Ghanem Net senior
management has designated the following person to act as Privacy
Officer to oversee the organization's compliance with the
principles:
Attention:
Al Ghanem Net Legal Department c/o Privacy Officer
ISQ Solutions Inc.
130 Spadina Avenue, Suite 602
Toronto, Ontario, CanadaM5V 2L4
Facsimile: (416) 703-4802
2. IDENTIFYING
PURPOSES
Al Ghanem Net will identify the
purposes for which personal information is collected at or before the
time the information is collected.
2.1 Al Ghanem Net collects
personal information only for the following purposes
(“identified purposes”):
- to provide service(s) and/or
products to its customers;
- to maintain commercial
relations and to communicate with its customers (which will
include, but not be limited to: billing, collection, advertising,
promotion, account verification);
- to identify customer needs
and/or preferences;
- to meet legal and regulatory
requirements;
- to administer and manage its
business operations
2.2 Al Ghanem Net will provide
notice of the identified purposes either orally, electronically or
writing prior to or at the time of collection of the personal
information.
2.3 In order to open a hosting
account or to register a domain name at Al Ghanem Net an individual
is required to provide corporate or personal information by way of an
electronic online form. To register a domain name corporate or
personal information is required by the relevant registry of the TLD
(top level domain) for which the individual apply to register a
domain name through Al Ghanem Net. This information may include but
not be limited to company name, full name, mailing address, email
address, contact information, registrant, billing, administrative,
technical contacts and credit card details.
2.4 Use of personal information
by third parties or as required by the relevant TLD registries, the
Internet Corporation for Assigned Names and Numbers (ICANN) the
international governing body for TLDs (Top Level Domains) requires
that registrars must make available the corporate or personal
information collected from the individual when the individual apply
to register a domain name to the public through the publicly
accessible database known as the Whois Database. This is a public
policy adopted by the domain name industry as a whole.
2.5 On occasion, Al Ghanem Net
may engage third party companies or individuals to perform services
on our behalf. Our relationships with such third party companies are
governed by our contracts with them. Those companies are required to
hold your personal information strictly confidential.
2.6 Al Ghanem Net will use
personal information to advise its customers of any information
relating to the services provided to them through Al Ghanem Net. This
includes but is not limited to notices for renewal of services, of
system upgrades or any information relevant to the product and
service. Occasionally, Al Ghanem Net will communicate to the customer
special bonus and new product offers that we think may be of value to
the customer. If the customer wishes to opt-out of receiving targeted
communications from Al Ghanem Net in electronic, printed or verbal
format (other than information included with their renewal notice or
monthly billing), simply inform Al Ghanem Net in writing at Privacy
Office, ISQ Solutions Inc., 130 Spadina Avenue, Suite 602, Toronto,
Ontario, CanadaM5V 2L4 or by fax to 416-703-4802.
2.7 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, Al Ghanem Net will obtain the
consent of the individual before information is used for that new
purpose. 3.
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's 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, Al Ghanem Net 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 Al Ghanem Net 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 Al Ghanem Net wants to use
information for a purpose not previously identified).
3.3 Al Ghanem Net 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 Al Ghanem Net 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 fulfill the explicitly specified
and legitimate purposes.
3.5 The form of consent sought by
Al Ghanem Net may vary, depending upon the circumstances and the type
of information disclosed. In determining the form of consent to use,
Al Ghanem Net 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.
Al Ghanem Net 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. Al Ghanem Net will inform the individual of the
implications of such withdrawal. In order to withdraw consent, an
individual must provide notice to Al Ghanem Net in
writing.
3.7 With respect to personal
information already collected by Al Ghanem Net prior to the
publication of this Privacy Policy, this Policy will constitute
reasonable notice to Al Ghanem Net 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 Al
Ghanem Net in writing.
4. LIMITING
COLLECTION
The collection of personal
information will be limited to that which is necessary for the
purposes identified by Al Ghanem Net. Information will be collected
by fair and lawful means.
Al Ghanem Net collects personal
information from its customers and employees for the purposes
described under Principle #2.
4.2 Al Ghanem Net 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, Al Ghanem Net may use a ‘Cookie' 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's browser, but not a
particular individual. A Cookie does not identify an individual.
Furthermore, Al Ghanem Net 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.
5. 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 Al Ghanem Net may collect,
use or disclose personal information without the individual's
knowledge or consent in certain circumstances as described in
Principle #3.1
5.2 Al Ghanem Net may disclose a
customer's personal information to:
- another web hosting provider
or internet service provider for the provision of services to
that customer;
- a person involved in the
development, promotion, marketing or enhancement of Al Ghanem Net
services;
- a credit collections
agency;
- emergency services in an
emergency situation;
- a person, who, in the
reasonable estimation of Al Ghanem Net, is an agent of the
customer;
- any other third party, upon
receiving the consent of the customer or as required by
law.
- Al Ghanem Net may disclose an
employee's personal information in the following
circumstances:
- in the administration of that
employee's benefits;
- in providing references to
prospective employers, upon receiving the consent of the
employee;
- as may be required by
law.
5.4 Certain Al Ghanem Net
employees may be given access to customer and/or employee information
in so far as their duties require access for business purposes. Al
Ghanem Net 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 Al Ghanem Net will retain
personal information for only as long as required to fulfill the
identified purposes or as required by law.
5.6 Personal information that is
no longer required to fulfill the identified purposes will be
destroyed, erased or made anonymous according to the guidelines and
procedures established by Al Ghanem Net.
6.
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 Al Ghanem Net will not
routinely update personal information unless such a process is
necessary to fulfill the purposes for which the information was
collected.
6.3 You have the ability to
correct or change your personal information in our records, such as
your address and contact information. The process for changing your
information begins in the account area of your control panel. You may
change this information at any time and as often as necessary. If you
need assistance or have questions about changing, updating or
correcting information, you can contact us via e-mail at
support@isqsolutions.com.
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.
7.
SAFEGUARDS
Personal information will be
protected by security safeguards appropriate to the sensitivity of
the information.
7.1 Al Ghanem Net 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 Al Ghanem Net protects all
personal information regardless of the format in which it is held.
The methods of protection include:
- physical measures, such as locked filing cabinets and restricted
access to offices;
- organizational measures, such as security clearances and limiting
access on a “need to know” basis;
- technological measures, such as the use of passwords and
encryption.
7.3 Al Ghanem Net makes their
employees aware of the importance of maintaining the confidentiality
of personal information. Al Ghanem Net 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 Al Ghanem Net will use care
in the disposal or destruction of personal information to prevent
unauthorized parties from gaining access to the information.
8.
OPENNESS
Al Ghanem Net will make readily
available to individuals specific information about its policies and
practices relating to the management of personal
information.
8.1 Al Ghanem Net will make its
policies and practices with respect to the management of personal
information easily comprehensible and accessible, by providing upon
request:
- the name, title, and address of the Privacy Officer accountable for
Al Ghanem Net policies and practices and to whom complaints or
inquiries can be forwarded;
- the means of gaining access to personal information held by Al
Ghanem Net; and a description of the type of information held by Al
Ghanem Net and/or its subsidiaries, including a general account of its
use.
- 8.2 Al Ghanem Net will make this Privacy Policy available online,
by mail or at its place of business. Furthermore, Al Ghanem Net
Customer Services Representatives will be trained to answer requests at
Al Ghanem Net toll-free customer service telephone number.
9. INDIVIDUAL
ACCESS
Upon request, an individual will
be informed of the existence, use, and disclosure of his or her
personal information and will be given access to that information. An
individual will be able to challenge the accuracy and completeness of
the information and have it amended as appropriate.
9.1 Upon request, Al Ghanem Net
will inform an individual whether or not the organization holds
personal information about the individual, and will provide that
individual with a reasonable opportunity to review the
personal.
9.2 Al Ghanem Net will allow the
individual access to his or her personal information and to correct
or change personal information in our records, such as their address
and contact information. The process for changing information begins
in the password protected account area of the individuals control
panel. The individual may change this information at any time and as
often as necessary. If assistance is needed, or for answers to
questions about changing, updating or correcting information, the
individual can contact Al Ghanem Net via e-mail or
telephone.
9.3 Al Ghanem Net will be as
specific as possible in providing an account of third parties to
which it has disclosed personal information about an individual. When
it is not possible to provide a list of the organizations to which it
has actually disclosed information about an individual, Al Ghanem Net
will provide a list of organizations to which it may have disclosed
information about the individual.
9.4 In certain instances, Al
Ghanem Net will not be able to provide the individual access to his
or her personal information. For example, Al Ghanem Net where the
information contains references to other individuals; where the
information cannot be disclosed for legal, security or commercial
proprietary reasons; where the information is subject to
solicitor-client or litigation privilege; or where the information
can best be available from another source. In each case, Al Ghanem
Net will provide reasons for denying any access to personal
information.
9.6 When an individual
successfully demonstrates the inaccuracy or incompleteness of
personal information, Al Ghanem Net will amend the information as
required. Depending upon the nature of the information challenged,
amendment involves the correction, deletion or addition of
information. Where appropriate, the amended information will be
transmitted to third parties having access to the information in
question.
9.7 When a challenge is not
resolved to the satisfaction of the individual, Al Ghanem Net will
record the substance of the unresolved challenge. When appropriate,
the existence of the unresolved challenge will be transmitted to
third parties having access to the information in question.
10. CHALLENGING
COMPLIANCE
An individual will be able to
address a challenge concerning compliance with the above principles
to Al Ghanem Net Privacy Officer.
10.1 Al Ghanem Net will maintain
procedures to receive and respond to complaints or inquiries about
its policies and practices relating to the handling of personal
information. Al Ghanem Net will make every effort to ensure that its
procedures are easily accessible and simple to use.
10.2 Al Ghanem Net will inform
individuals who make inquiries or lodge complaints of the existence
of relevant complaint procedures.
10.3 The person or persons
accountable for compliance with this Privacy Policy may seek external
advice where appropriate before providing a final response to
individual complaints.
10.4 Al Ghanem Net will
investigate all complaints. If a complaint is found to be justified,
Al Ghanem Net will take appropriate measures, including, if
necessary, amending its policies and practices.
|
