PRIVACY POLICY

BRAMA takes seriously its obligations to protect personal information in its possession. This Privacy Policy outlines how Brama deals with personal information.

Definitions
In this Policy:

” BRAMA” means BRAMA Telecom Inc.

“collection” means the act of gathering, acquiring, or obtaining personal information through BRAMA’s website, by email, in person, by phone, or by mail or through any other source or means, including third parties.

“disclosure” means making personal information available to a third party.

“personal information” means information about an identifiable individual in any form, including, for example: name, age, contact information, previous phone numbers and credit information. Personal information does not include the business contact information of an individual, information about corporate or commercial entities, information exempted under PIPEDA, or information that cannot be associated with a specific individual.

“PIPEDA” means the federal Personal Information Protection and Electronic Documents Act.

“third party” means an individual or organization other than BRAMA and the customer.

“Privacy Officer” means an individual designated by BRAMA who is accountable for BRAMA’s compliance with this Policy.

“use” means the treatment and handling of personal information by and within BRAMA.

BRAMA will adopt policies and procedures to protect personal information, receive and respond to complaints and inquiries by providing information regarding these policies and procedures in an accessible format, and train its staff regarding these policies and procedures.

BRAMA assumes responsibility for personal information in its possession or custody, and this responsibility extends to information that is communicated to a third party for processing purposes. Our clients and partners have obligations to consumers when accessing personal information from us or providing personal information to us. BRAMA enters into arrangements so as to ensure that the requisite level of protection is afforded to personal information being processed by a third party and that third parties comply with applicable laws and obtain any necessary consents.

BRAMA is in the business of providing homes and businesses with local and long distance telephone services, and collects such personal information as is necessary to provide these services.

The following are the particular purposes for which BRAMA collects personal information (“identified purposes”):

-providing its services and products to customers;

-maintaining commercial relations and communicating with customers (e.g. regarding billing, advertising and promotions);

-in connection with a transfer, sale, financing or reorganization of Brama or its assets;

-managing its operations;

-for specific purposes identified at the time of collection;

-identifying customers’ needs and preferences;

-satisfying legal and regulatory requirements.

If BRAMA intends to use personal information that was previously collected for a purpose or purposes other than those set out above, BRAMA will identify and explain the new purpose prior to its use. BRAMA will obtain consent for the use of information for a new purpose prior to its use unless the new purpose is required by law or its use comes under the exceptions noted below.

On occasion, BRAMA will communicate special bonuses and/or new product offers to you that may be of interest. As a BRAMA customer, you are entitled to opt-out of receiving such information from BRAMA; if you would prefer not to receive direct marketing materials of this nature, please inform us in writing at the following address:

Privacy Officer
BRAMA Telecom Inc.
15 Wertheim Court, Suite 404
Richmond Hill, ON
L4B 3H7, Canada
Phone: (416) 548-4888

BRAMA 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 which is required in order for BRAMA to meet its stated purposes. 

BRAMA’s website may contain links to other sites that are not governed by this Privacy Policy. BRAMA provides these links to customers only as a convenience; their presence does not signify or imply any endorsement or verification of these sites or the products and/or services advertised by those sites. BRAMA assumes no responsibility for the collection, use and/or disclosure of personal information obtained on such other sites, and expressly disclaims any and all liability related to the collection, use or disclosure of such information.

An individual’s consent can be express or implied, or it may be given through an authorized representative (such as a legal guardian) or agent. Consent may be provided orally, in writing, or electronically. The form of consent sought by BRAMA may vary, depending upon the circumstances, the type and sensitivity of information disclosed, and the reasonable expectations of the person about whom it collects personal information. BRAMA 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 products or services by a customer will be considered implied consent to the collection, use and disclosure of personal information for the particular purposes identified above. In some cases, consumers will not provide consent directly to BRAMA, but to one of our agents. We work with our agents to make them aware of the importance of obtaining consumer consent prior to providing BRAMA with personal consumer information.

An individual may withdraw consent at any time by providing BRAMA with notice in writing, subject to any applicable legal or contractual restrictions. BRAMA will inform the individual of the associated implications, including the fact that if consent is withdrawn, BRAMA may be unable to process requests for certain products and services.

BRAMA may also seek out personal information from third parties, including credit bureaus, existing or former employers, personal references, and other third parties who represent that they may disclose personal information about our customers.

Customers may visit BRAMA’s website anonymously without revealing any personal information. When a customer visits the site, his or her IP address is collected by BRAMA, so that the website can determine where to send the information that is being requested; this IP address does not identify a customer personally. Personal information is obtained through BRAMA’s website only by the knowing and consenting supply of that information by a customer.

BRAMA’s website uses cookies, which are files sent to your web browser from BRAMA’s website and stored on your computer’s hard drive. These cookies are small text files which contain a unique identification number associated with your computer, to allow BRAMA to collect aggregated, anonymous information on the use of its website (for example, which pages were visited, what content was downloaded, and the type of web browser employed). Cookies allow BRAMA to track visitors to its site and compile related statistics and, in turn, enable BRAMA to improve customers’ online experience and to monitor the site’s operation. BRAMA does not collect personal information through the use of cookies on its website. The use of cookies is an industry standard and, in fact, is common across many industries. Customers may choose to configure their web browsers so as to reject all cookies or to notify the customer when a cookie is sent. Although customers need not accept cookies to visit BRAMA’s website, the site’s functionality may be compromised. If cookies are not accepted, some features may not work properly.

Personal information will only be used or disclosed for the identified purposes and as authorized by PIPEDA and other applicable laws, except with an individual’s consent or as required or permitted by law, or in the circumstances described above. 

There are some situations in which BRAMA may disclose personal information about a particular customer to third parties. For example, BRAMA may disclose information to the following parties:

- another telecommunications company, regarding the provision of services to a customer;
- companies providing communications directory services;
- persons involved in marketing or developing BRAMA’s services;
- credit collections agencies;
- emergency services;
- people who are an agent of the customer, as reasonably determined by BRAMA;
- third party affiliates of BRAMA that fulfil certain administrative purposes on BRAMA’s behalf, such as billing; and
- any other third party, with the customer’s consent or as required by law.

Note that some of these parties to whom information may be disclosed may be located outside of Canada. If BRAMA believes that a third party is using personal information in a manner that does not comply with applicable laws, industry codes or contracts, BRAMA will pursue corrective action, up to and including termination of the relationship.

BRAMA will retain personal information only for as long as is necessary for the fulfilment of the identified purposes or as otherwise permitted or required pursuant to applicable legislation. BRAMA will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. BRAMA will take due care when destroying personal information so as to prevent unauthorized access to the information. In any event, BRAMA will retain personal information used to make any decisions about an individual for the requisite period of time in order to allow that individual access to the information after a decision has been reached; information will be retained long enough, should an access request or a challenge to that decision be brought, so that any recourse available at law may be fully exhausted.

BRAMA will make reasonable efforts to ensure that the personal information it is using or disclosing is accurate and complete. BRAMA undertakes to ensure that information will be sufficiently accurate and current so as to minimize the likelihood of outdated information being used in connection with any decision to be made about a particular individual. BRAMA will not update personal information on a routine basis, unless doing so is required in order to fulfil the purposes for which that information was obtained. The extent to and speed at which personal information will be updated depends on the nature and use of that information.

In some cases, BRAMA relies on third parties who in turn rely on you to ensure that certain personal information is current, complete and accurate. Where an individual demonstrates satisfactorily to BRAMA that his or her personal information is inaccurate or incomplete, BRAMA will amend the information, as required. If BRAMA considers it appropriate, it will transmit the revised information to third parties who may access that information. 

We take the protection of personal information seriously. BRAMA protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. The safeguards employed are chosen to reflect the relative sensitivity of the information in question, the distribution and format of the information, and the method and location of storage of the information. These safeguards include: 

• physical measures, such as locked filing cabinets;

• organizational measures, such as restricting employee access to files and databases as appropriate;

• electronic measures, such as passwords and firewalls;

• regular reviews of processes in place to safeguard personal information; and

• investigative measures, where BRAMA has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

BRAMA is committed to refining its technological security features and introducing new features as they become available and reliable. However, the state of current technology is such that BRAMA cannot ensure that its system is entirely sufficient or impermeable, and as such makes no warranties or representations to that effect. BRAMA will not assume liability for any damages or liabilities (actual or consequential) that may result from security breaches or technical difficulties that in turn lead to a breach of this Privacy Policy, including those arising as a result of BRAMA’s negligence.

BRAMA communicates to its employees the critical importance of ensuring the confidentiality of all personal information in its control or possession, and its employees are governed by non-disclosure obligations that prohibit disclosure of any personal information for purposes other than the stated purposes. BRAMA will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to you.

BRAMA is open about the policies and procedures it uses to protect your personal information. This Privacy Policy can also be accessed online on BRAMA’s website (www.bramatelecom.com).

To ensure the integrity of our security procedures and business methods, BRAMA will not disclose sensitive information about its policies and procedures, nor will it disclose commercial information which it considers to be confidential.

Upon written request and authentication of identity, BRAMA will confirm whether it possess information about an individual and will provide information regarding the collection, use and disclosure of that individual’s personal information and grant the individual access to that information, providing a reasonable opportunity to review his or her file. The accuracy of such information may be challenged and/or updated by that individual, and it will be amended as appropriate. The written request or application must contain sufficient information to enable BRAMA to provide an account of the existence, use and disclosure of this information to third parties.

Typically, BRAMA will provide the pertinent personal information at no cost, depending on the nature and extent of the request. However, BRAMA reserves the right to impose a cost in appropriate circumstances; should a cost be imposed, BRAMA will communicate the approximate cost to the individual and will await payment before proceeding. BRAMA is committed to providing any requested information in a format that is accessible and easily understandable.

In response to any requests seeking further details regarding disclosure of personal information to third parties, BRAMA will provide as much detail and information as is reasonably possible. Where BRAMA cannot provide a fulsome list of the third parties to whom it has disclosed the relevant personal information, it will provide a list of the third parties to whom it may have disclosed such information.

In some situations, BRAMA may not be able to provide access to certain personal information. This may be the case where, for example: disclosure would reveal personal information about another individual or sensitive commercial information and that information cannot be severed; the personal information is protected by solicitor-client or litigation privilege or would be prohibitively costly; the information was collected for the purposes of an investigation relating to investigation of a breach of an agreement or contravention of a law; or the information was generated in the course of a formal dispute resolution process. BRAMA may also be prevented by law from providing access to certain personal information. Where possible, BRAMA will disclose the reasons for denying access to an individual upon written request.

Where an individual is unsatisfied with BRAMA’s response to a challenge or a request for information, BRAMA will record details of that challenge in the individual’s file.

BRAMA has in place certain procedures in order to receive and respond to inquiries and complaints regarding its Privacy Policy and compliance therewith. BRAMA will, on request, provide customers with information regarding its complaint procedures. Any inquiries, complaints or questions regarding this Policy, or compliance with the principles outlined herein, should be directed in writing to the BRAMA Privacy Officer. Alternatively, you may also seek advice from the Office of the Privacy Commissioner of Canada, who may be contacted at 1-800-282-1376 or info@privcom.gc.ca and, if necessary, file a written complaint with that office.

BRAMA may amend this Policy from time to time. It is your responsibility to review this Policy to check for updates.

BRAMA has designated a Privacy Officer who is accountable for BRAMA’s compliance with this Policy. The Privacy Officer may be reached at:

Privacy Officer
BRAMA Telecom Inc.
15 Wertheim Court, Suite 404
Richmond Hill, ON
L4B 3H7, Canada
Phone: (416) 548-4888