Our Commitment to Your Privacy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our website.

The Information We Collect

This notice applies exclusively to personal information collected or submitted through use of our website.

We use the term “personal information” as it is defined in the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (“PIPEDA”). As such, for the purposes of this policy, personal information means information about an identifiable individual, but does not include the name, title, or telephone number of an employee of an organization.

We may collect non-personally identifiable information by using cookies. Cookies are small data files that are sent to your browser and stored on your computer’s hard-drive when you visit certain websites, thereby “tracking” your use of the websites. All information collected by means of cookies is anonymous, aggregated and only used to better understand how our website is used so that we may make design improvements.

How We Use Your Information

We only use the personal information collected through our website to communicate directly with you. We do not share your personal information with any outside parties.

For users of our website (the “Site”), the Site automatically collects information, such as the Internet domain name (“IP Address”) assigned to your computer or browser software when you are on the Internet, through electronic means. Information about your use of the Site is collected through “cookies” that exist only during your visit to the Site and are deleted once you logoff this Site or close your browser. Session cookies are only used by the Site to recognize your visit as a unique visit and to keep your visit on this Site separate from that of other visitors to this Site. We may use the information we collect electronically to obtain aggregate data for the purposes of: improving our products and services to you; improving the design and content of the Site; and planning and other internal administrative functions.

We also attempt to personalize your experience on the Site by, for example, suggesting products and services that we believe will be of interest to you. Your browser can be set to alert you when you receive a cookie or it can be set to refuse cookies altogether. You should refer to the instructions of your particular browser to learn about these functions. Please note that refusal to accept cookies may limit functionality that the Site can provide to you.

Please refer to the Terms and Conditions of Use posted on the Site for additional information.

We are using remarketing or similar audiences to advertise online using third-party vendors, including Google, to show our ads on sites across the Internet based on past search history. Third-party vendors, including Google, use cookies to serve ads based on past visits to our Site. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings: http://google.com/settings/ads/onweb/optout?hl=en

Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt out age: http://optout.networkadvertising.org/#/

How We Keep Your Information Secure

We are committed to keeping your information secure and maintaining its accuracy. We make all commercially reasonable efforts to ensure that personal information collected from you is protected against loss and unauthorized access. Personal information is collected and stored by us in a secure manner.

Any other companies and individuals who we may employ from time -to-time to perform functions on our behalf are required to protect any personal information accessed in a manner consistent with this policy.

Links to Third Party Sites

Our website may contain links to other third party websites. We are not responsible for the privacy practices or the content of such linked third party websites.

How We Comply With Canada's Anti Spam Law (CASL)

In accordance with Canada’s Anti-Spam legislation we may use your personal information so that we may send you commercial electronic messages (CEMS). Unless such messages are sent subject to exemption we will obtain your prior implied or express consent in accordance with this legislation.

You may withdraw your consent to receive CEMs from us at any time by using the unsubscribe mechanism contained in all of our electronic communications.

We do not install or cause to be installed any computer programs on your computer system that requires your consent under CASL.

How You Can Access, Modify, and/or Remove Your Information

You may e-mail us at reception@azuressm.ca any time to request a copy of the personal information we have in our possession about you and/or to ask us to modify or remove your information from our online database. We will take all reasonable steps to verify your identity before taking any action in respect of such requests.

Please be aware that it may not always be possible to completely modify or remove information in our database.

How You Can Contact Us If You Have Any Questions

If you have questions and/or concerns about this policy, please contact our Privacy Officer: Whitney MacKenzie, management@azuressm.ca.

All Complaints will be investigated within 60 days of receipt and appropriate measures will be taken to resolve them.

How You Will Be Informed of Updates to Our Privacy Policy

We reserve the right to update our privacy policy at any time without notice. All updates to our privacy policy will be made readily available and accessible through our website. The privacy policy posted shall be deemed to be the privacy policy then in effect.

Your use of or access to our website indicates your acknowledgment of this privacy policy and consent to the collection, use, and disclosure of your personal information in accordance with this privacy policy.

Legal Disclosures

We reserve the right to co-operate fully with local, provincial and federal officials in any investigation relating to any personal or any purported unlawful activities.

Surveillance Policy

Purpose

This policy applies to the collection, use, disclosure, and disposal of recorded information collected through video surveillance technology, which is used to enhance the protection and safety of Azure Salon Spa Medispa’s employees, its customers and invitees by reducing, deterring and assisting in the investigation of incidents of criminal activity, and protecting property and assets.

Scope

This policy has been created in accordance with the Guidelines for Overt Use of Video Surveillance in the Private Sector as issued by Ontario’s Information and Privacy Commissioner (March, 2008).

This policy applies to:

• all Azure Salon Spa Medispa employees, agents, independent contractors, customers and invitees; and
• all Azure Salon Spa Medispa owned or leased land and buildings (the “Premises”).

Policy and Procedures

It is the policy of Azure Salon Spa Medispa to ensure:

• Video surveillance of the Premises is conducted in a professional, ethical and legal manner;
• Video surveillance is used for a purpose consistent with this policy and to promote the following goals:
• Public safety
• Combating unauthorized access
• Coordinating operational activities
• Supporting criminal investigations
• Deterring theft and break and enter
• Reinforcing employee safety
• Ensuring adequate staffing for high level of customer service
• Video surveillance is used only to the extent that less intrusive means of achieving a purpose consistent with the policy and the foregoing goals has shown to be ineffective or unworkable;
• If cameras are adjustable by operators, this practice will be restricted, wherever possible, so that operators cannot adjust or manipulate the cameras to view spaces where individuals have a heightened expectation of privacy, (e.g. washrooms).
• Clear understandable notice is provided about the use of video surveillance on the Premises to individuals whose images might be captured, before these individuals enter the Premises. Such notice will be in form of signs that include a contact in case individuals have questions or if they want access to images relating to them.
• Cameras shall normally not be monitored. When cameras are monitored, the recording function shall be turned on only when unlawful activity is suspected or observed.
• Sound is not recorded unless there is a specific need to do so.
• A process is in place to facilitate the making and handling of complaints about the use of video surveillance by Azure Salon Spa Medispa.

MANAGING RECORDINGS

Azure Salon Spa Medispa will retain all video surveillance recordings for a period of 30 days. Records shall only be retained for more than 30 days where the footage is required as part of an investigation or for the purposes of evidence.

While retained by Azure Salon Spa Medispa, video recordings shall be stored in a secure environment and their content shall not be altered.

Recording no longer retained by Azure Salon Spa Medispa shall be securely destroyed.

Disclosure of Recordings

Subject to legislative exemptions, Azure Salon Spa Medispa shall not disclose recordings containing identifying information about an individual without that individual’s consent. Such exemptions include, but are not limited to, disclosure Azure Salon Spa Medispa legal counsel, disclosure to identify an injured, ill or deceased individual, and disclosure to law enforcement where a crime has been committed or to comply with a subpoena, warrant or court order.

Individuals have a right to access recordings they appear in. When disclosing recordings to individuals who appear in them, Azure Salon Spa Medispa shall ensure that identifying information about any other individuals on the recording is not revealed. This may be done through technologies that mask identity.

Responsibilities

Azure Salon Spa Medispa management level employees are collectively responsible for approving and directing compliance with this policy.

The owner and managers are responsible for:

• Resolving any issues or conflicts relating to this policy;
• Implementation, administration, and evaluation of this policy;
• Ensuring that information obtained through video surveillance is used exclusively for lawful purposes; and
• Documenting access to recordings and the retention or disposal of recordings.

Policy Evaluation

The owner and managers will evaluate this policy periodically, at least once every three years, to:

• Accommodate developments in the interpretation of data protection legislation;
• Respond to developments in the technology involved with the recording of images and the use of such technologies; and
• Ensure that the procedures comply with all applicable laws and Azure Salon Spa Medispa
• policies, including laws and policies relating to privacy and access to information.

Effective Date:              November, 2017
Next Evaluation:          November, 2020
Revision History:          Version 1
Related Documents:   Personal Information Protection and Electronic Documents Act and Regulations

Guidelines for Overt Video Surveillance in the Private Sector

• All recordings will be labelled and documented appropriately with the dates and camera source.
• All activities regarding surveillance activities- Only authorized personnel will have access to the surveillance activities
• All recordings will be stored securely in an access-controlled area and server.
• With the exception of requests by law enforcement agencies, individuals must submit a formal request to view recordings that will be subject to approval by the owner and managers.
• In the event that any law enforcement agency requests access to Azure Salon Spa Medispa surveillance recordings, Azure Salon Spa Medispa act in accordance with the law and provide the materials as
• All recordings created by means of security surveillance cameras will be the sole property of Azure Salon Spa Medispa and may not be taken, reproduced or destroyed for any reason without prior written permission. Authorized personnel shall be the only parties eligible to delete recordings in accordance with this policy and following the
• Where recordings are disposed of, they must be deleted or destroyed in such a manner as to ensure that they cannot be viewed or accessed by
• Periodic evaluation of the need for surveillance will be done to ensure it is still meeting the needs of Azure Salon Spa Medispa with respect to the goals.