Privacy Policy
What we collect, why we collect it, and the rights you have over it. Written against Canada's PIPEDA fair information principles.
Status: DRAFT — pending legal review. Effective date: [EFFECTIVE DATE]
Who is responsible for your information
Clink Innovations Inc. (“Clink”) is the organization responsible for the personal information we collect. Our privacy officer is [PRIVACY OFFICER NAME], who can be reached at [PRIVACY OFFICER EMAIL], or by post at Clink Innovations Inc., [REGISTERED ADDRESS], Richmond Hill, Ontario, Canada.
What we collect
We collect only what we need to answer an inquiry, quote, supply and support our products:
- Contact details — name, email address, telephone number where you offer one.
- Site and vehicle details — city or postal code, vehicle make and model, what you want to charge, and photographs you send us of an electrical panel or parking space.
- Inquiry content — the message you write and any correspondence that follows.
- Order and warranty records — purchase date, model, serial number and service history, so we can register a warranty and handle a claim.
- Technical information — if you install a networked charger, energy and session data generated by the equipment. See our Cookie Policy for what the website itself stores.
How we collect it
Directly from you, when you fill in a form, send an email, or speak with us; and automatically from our own equipment if you own one of our networked products. We do not buy personal information from data brokers and we do not sell it.
Why we use it
To answer your inquiry and prepare a quotation; to supply, install and support equipment; to register and administer warranties; to meet legal, tax and product-safety obligations; and, only where you have asked for it, to send you product news. We do not use your information for automated decision-making that has a legal effect on you.
Consent and marketing (CASL)
We send commercial email only with your consent. If you ask to be told about new products, we record that request and the date. Every marketing message identifies us, gives a postal address and a way to contact us, and includes a way to unsubscribe that is available at no cost. We process unsubscribe requests within ten business days, the period set by Canada's anti-spam legislation (CASL). Where we rely on an existing business relationship rather than a direct request, we stop relying on it within the period CASL allows.
How long and where we keep it
We keep inquiry records while the inquiry is live and for a reasonable period afterwards; order and warranty records for the life of the product plus the period tax and product-safety law requires. Our systems are hosted in Canada where practicable. We keep records of any consent and of any unsubscribe request.
How we protect it
Access is limited to people who need it for the purposes above, on password-protected accounts. We use encryption in transit and keep our administrative and technical safeguards under review.
If something goes wrong
If a breach of our safeguards creates a real risk of significant harm to you, we will notify the Office of the Privacy Commissioner of Canada and affected individuals as soon as feasible, as required by PIPEDA, and we will keep a record of the breach for at least 24 months.
The ten fair information principles we work to
Our practices follow the ten principles in Schedule 1 of PIPEDA:
- Accountability — a named privacy officer answers for our handling of information.
- Identifying purposes — we tell you why we collect it before or when we collect it.
- Consent — we ask, and you can withdraw it, subject to legal limits.
- Limiting collection — we collect only what we need.
- Limiting use, disclosure and retention — we use it for those purposes and no other, and we do not keep it longer than necessary.
- Accuracy — we correct it on request.
- Safeguards — appropriate to how sensitive the information is.
- Openness — this policy describes our practices and is available at any time.
- Individual access — you may ask what we hold about you.
- Challenging compliance — you may question us, and we will investigate and answer.
Your rights
You may ask to see the information we hold about you, ask us to correct it, ask us to delete it where we are not required to keep it, and withdraw consent to marketing at any time. Write to [PRIVACY OFFICER EMAIL]. We may need to verify your identity first. We will answer within the period PIPEDA allows.
Cookies
Our website is built as self-contained pages and currently sets no tracking cookies and connects to no analytics or advertising network. Read our Cookie Policy for the detail and for how we will tell you if that changes.
Changes to this policy
If we change this policy we will update the date at the top. Where a change materially affects how we use information already collected, we will tell you directly where we can.
Complaints
Raise it with [PRIVACY OFFICER NAME] first, at [PRIVACY OFFICER EMAIL]. You may also contact the Office of the Privacy Commissioner of Canada, or the information and privacy commissioner of your province if you live outside Ontario.