Scope and Application of this Privacy Policy
(Last Updated on Sept 23, 2009) This Privacy Policy and the nine accompanying principles are observed by Misha Essentials when collecting and disclosing the personal information of its clientele. The information, including these nine principles, contained in this Privacy Policy must be read and understood as a whole. This Privacy Policy has been customized to personal information issues specifically related to Misha Essentials. The general scope and application of the Privacy Policy for Misha Essentials is as follows:
Definitions
Misha Essentials – includes Misha Essentials Inc.
Client – a client is any individual, in their capacity as an individual either personally or through a business carried on as a sole proprietorship or partnership, who uses or applies to use the products and services of Misha Essentials. The term ‘client’ includes a prospective client who has provided Misha Essentials with personal information.
Collection – the act of gathering, acquiring, recording and/or obtaining personal information.
Consent – the voluntary agreement with respect to the collection, use and disclosure of personal information for defined purposes. Consent can either be expressed, implied or deemed and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Misha Essentials. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. ‘Deemed consent’ is consent that is deemed to be given pursuant to applicable legislation or other regulations.
Personal Information – information about an identifiable individual, but does not include aggregated information that cannot be associated with a specific individual. ‘Personal information’ also excludes certain information that is excluded pursuant to applicable legislation or regulations, such as publicly available information or business contact information, as and when applicable. Misha Essentials’ Nine Privacy Principles
1. Accountability Misha Essentials’ management team is ultimately responsible for ensuring compliance with this Privacy Policy and related privacy legislation in Canada. Misha Essentials is responsible for the personal information under its control and shall designate up to two persons to act as privacy officers accountable for Misha Essentials’ compliance with the following principles:
1.1 Upon request, Misha Essentials will make known the title of the person(s) designated to oversee this Privacy Policy and Misha Essentials’ compliance with said policy.
1.2 Misha Essentials is responsible for the personal information in its possession or under its control and shall use appropriate means to protect this personal information while being processed by a third party.
1.3 The internal policies and procedures needed to give effect to this Privacy Policy will be put in place by Misha Essentials.
2. Identifying Purposes for the Collection of Personal Information
Misha Essentials collects personal information for the following identified purposes:
3. Consent for the Collection, Use or Disclosure of Personal Information
Generally, the knowledge and consent of an individual are required for the collection, use or disclosure of personal information. When obtaining this consent, Misha Essentials will use reasonable efforts to ensure the individual is advised of the purpose for using or disclosing this personal information, and this purpose shall be expressed in a way that is reasonably understood by the individual. Personal information may be collected, used or disclosed without the knowledge or consent of the individual by Misha Essentials under certain circumstances in the case of an emergency where the life, health or security of an individual is threatened. An individual may withdraw their consent at any time, subject to legal or obligations and reasonable notice. Individuals should contact Misha Essentials for more information regarding the implications of withdrawing consent. |
4. Limiting the Use, Disclosure and Retention of Personal Information
Except with the expressed consent of the individual or as required by law, Misha Essentials will not use or disclose personal information for purposes other than those for which this information was collected.
Furthermore, personal information will be kept by Misha Essentials only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the particular circumstance, where personal information has been used to make a decision about a client, Misha Essentials will retain, for a period of time that is reasonably sufficient to allow access by the individual, either the actual information or the rationale for making the decision.
5. Accuracy of Personal Information
Reasonable steps will be taken by Misha Essentials to ensure the personal information of its clients is as accurate, complete and up-to-date as is appropriate and reasonable for its purposes.
5.1 Personal information used by Misha Essentials shall be sufficiently accurate, complete and up-to-date as to minimize the possibility that inappropriate information may be used to make decision about an individual.
5.2 Misha Essentials shall update personal information about individuals as and when reasonably necessary to fulfill the identified purposes or as reasonably requested by the individual.
6. Security Safeguards
Misha Essentials will take reasonable steps through appropriate security measures to protect personal information against risks, such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction.
7. Openness – Policies and Procedures
Misha Essentials shall make information about its policies and practices related to the management of personal information readily available to individuals. This includes providing copies of its Privacy Policy upon request and making said information easy to understand. The title and addresses of the person(s) accountable for Misha Essentials’ compliance with this Privacy Policy and to whom inquiries or complaints can be made shall be readily available.
8. Access to Personal Information
Misha Essentials shall, upon request, allow a reasonable opportunity to its clients to review the personal information collected, at a minimal or no cost to the individual. This individual will then be able to challenge the accuracy and/or completeness of this personal information and have it duly amended as needed. 8.1 An individual requesting access to their personal information may be required to provide sufficient identification to permit Misha Essentials to authorize access to the individual’s files, in order to safeguard this personal information. 8.2 Individuals seeking access to their personal information must do so by written request to the designated Misha Essentials Privacy Officer.
9. Compliance Challenges and Inquiries
Procedures for addressing and responding to all inquiries or complaints from individuals about the handling of their personal information shall be maintained by Misha Essentials. The designated Privacy Officer will be responsible for addressing these inquiries or complaints. This officer may seek external advice, where appropriate, before providing a final response.
Individuals protected by this Privacy Policy may seek advice from the Office of the Privacy Commissioner in British Columbia by calling 1-250-387-5629, or file a written complaint with this office. All individuals are, however, encouraged to follow Misha Essentials’ internal processes and procedures for addressing their concerns. Please contact our Privacy Officer with any questions or concerns you may have about this Privacy Policy or practices.
Email: info@mishaessentials.com |
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