Trol-Mation Privacy Policy
TROL-MATION PRIVACY POLICY
Effective Date: [Insert Date]
Last Updated: [Insert Date]
Note: Cette politique de confidentialité est également disponible en français. Pour obtenir la version française, veuillez nous contacter.
1. INTRODUCTION
Trol-Mation ("we," "our," or "us") respects your privacy and is committed to protecting your personal information in accordance with Canadian privacy laws. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our services, including our SMS text messaging services.
This policy complies with:
- PIPEDA (Personal Information Protection and Electronic Documents Act)
- Quebec Law 25 concerning the protection of personal information
- CASL (Canadian Anti-Spam Legislation)
2. PRIVACY OFFICER
Quebec Privacy Officer:
[Insert Name]
[Insert Contact Information]
Email: [Insert Privacy Officer Email]
Phone: [Insert Phone]
3. INFORMATION WE COLLECT
3.1 Information You Provide
We collect information you voluntarily provide, including:
- Name and company name
- Email address
- Phone number (including mobile for SMS services)
- Mailing address
- Language preference
- Project specifications and requirements
- Quote request details
- Express consent records for electronic communications
3.2 SMS-Specific Information (CASL Compliant)
When you opt in to our SMS services, we collect:
- Mobile phone number
- Carrier information
- Express consent details (date, time, method, IP address)
- Purpose of consent
- Message interaction history
- Unsubscribe preferences
3.3 Automatically Collected Information
We may collect:
- IP address
- Browser type and version
- Device information
- Website usage data
- Cookies (with consent as required)
4. LEGAL BASIS FOR COLLECTION
We collect personal information only when:
- You provide express consent
- Collection is necessary for contract performance
- We have a legitimate interest that doesn't override your privacy rights
- Required by law
5. HOW WE USE YOUR INFORMATION
5.1 Primary Purposes
We use your information for purposes identified at collection:
- Process quote requests and orders
- Provide customer service
- Send transactional communications
- Fulfill contractual obligations
5.2 Secondary Purposes (Require Separate Consent)
- Marketing communications
- Service improvements
- Analytics and research
5.3 SMS-Specific Uses (CASL Compliant)
For SMS services, we use your information to:
- Send service-related messages (implied consent may apply)
- Send commercial messages (express consent required)
- Manage consent preferences
- Comply with CASL requirements
6. CONSENT
6.1 Express Consent
We obtain express, informed consent that is:
- Voluntary and specific
- Obtained for each purpose
- Documented with date, time, and method
- Withdrawable at any time
6.2 Implied Consent (Limited Circumstances)
May apply only for:
- Existing business relationships as defined by CASL
- Service-related messages
- Responding to inquiries
6.3 Minors
We do not knowingly collect information from individuals under 14 without parental consent.
7. INFORMATION SHARING AND DISCLOSURE
7.1 We DO NOT Sell Your Information
We never sell, rent, or trade your personal information.
7.2 Service Providers
We may share information with providers who:
- Have signed confidentiality agreements
- Use information only for specified purposes
- Meet our security standards
- Include: SMS platforms, hosting services, payment processors
7.3 Cross-Border Data Transfers
- Data may be processed in the United States
- We ensure appropriate safeguards are in place
- You consent to transfer when using our services
7.4 Legal Disclosure
We may disclose information to:
- Comply with Canadian law or legal process
- Protect rights and safety
- Investigate breaches of agreements
- As required by law enforcement with proper authority
8. DATA RETENTION
8.1 Retention Periods
Data Type
Retention Period
Active customer data
Duration of business relationship
Consent records
3 years from collection or 1 year after withdrawal
Commercial message records
3 years (CASL requirement)
Other data
As required by applicable law
8.2 Secure Destruction
Personal information is securely destroyed when no longer needed.
9. YOUR PRIVACY RIGHTS
9.1 Under PIPEDA, you have the right to:
- Access your personal information
- Request corrections
- Withdraw consent (subject to legal/contractual restrictions)
- File a complaint with the Privacy Commissioner
9.2 Under Quebec Law 25, additional rights include:
- Data portability in structured format
- Right to de-indexing
- Right to rectification
- Enhanced consent rights
- Automated decision-making transparency
9.3 How to Exercise Rights
Contact our Privacy Officer at:
Email: [Insert Privacy Officer Email]
Phone: [Insert Phone]
Mail: [Insert Address]
Response time: Within 30 days (extensions may apply)
10. DATA SECURITY
We implement security safeguards appropriate to sensitivity including:
- Encryption of data in transit and at rest
- Access controls and authentication
- Regular security assessments
- Employee privacy training
- Incident response procedures
11. BREACH NOTIFICATION
In case of a privacy breach that creates real risk of significant harm:
- We notify affected individuals as required by law
- We notify the Privacy Commissioner
- We maintain breach records
12. COOKIES AND TRACKING
12.1 Cookie Consent
- We obtain consent before using non-essential cookies
- Essential cookies may be used for site functionality
- You can manage cookie preferences in your browser
12.2 Analytics
We use analytics tools in compliance with privacy laws.
13. DIRECT MARKETING
13.1 CASL Compliance
- Express consent required for commercial electronic messages
- Clear unsubscribe in every message
- Consent records maintained as required
13.2 Unsubscribe Options
- SMS: Text STOP/ARRET
- Email: Unsubscribe link or [Insert Email]
- Phone: 315.437.4100
- Mail: [Insert Address]
14. THIRD-PARTY LINKS
We are not responsible for privacy practices of linked third-party sites.
15. PRIVACY BY DESIGN
We implement privacy considerations in:
- New service development
- System design
- Business practices
- Privacy impact assessments
16. UPDATES TO THIS POLICY
16.1 Notice of Changes
- Material changes: 30 days advance notice
- Notice via website and/or direct communication
- Opportunity to withdraw consent before changes
16.2 Continued Use
Continued use after notice period constitutes acceptance.
17. COMPLAINTS AND CONTACT
17.1 Internal Complaints
Contact our Privacy Officer:
Email: [Insert Privacy Officer Email]
Phone: [Insert Phone]
Mail: [Insert Address]
17.2 Regulatory Complaints
You may file complaints with:
Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: www.priv.gc.ca
Commission d'accès à l'information du Québec
575, rue Saint-Amable
Québec (Québec) G1R 2G4
Toll-free: 1-888-528-7741
Website: www.cai.gouv.qc.ca
18. ACCESSIBILITY
This policy is available in alternative formats upon request for persons with disabilities.
19. LANGUAGE RIGHTS
Quebec residents have the right to:
- Receive this policy in French
- Communicate with us in French
- Exercise all privacy rights in French
20. CONTACT INFORMATION
Trol-Mation (Head Office)
6462 Ridings Rd.
Syracuse, NY 13206
United States
Phone: 315.437.4100
For Canadian Privacy Matters:
Privacy Officer: [Insert Name]
Email: [Insert Canadian Privacy Email]
Phone: [Insert Canadian Phone]
For Quebec Residents:
Responsable de la protection des renseignements personnels
Email: [Insert Quebec Privacy Email]
Phone: [Insert Quebec Phone]
21. COMPLIANCE CERTIFICATIONS
We comply with:
- PIPEDA (Personal Information Protection and Electronic Documents Act)
- Quebec Law 25 (Act respecting the protection of personal information)
- CASL (Canadian Anti-Spam Legislation)
- CPPA (Consumer Privacy Protection Act) when enacted
- Industry codes of conduct
