VOIP Freedom takes seriously its obligations to protect
how VOIP Freedom deals with personal information.
In this Policy:
” VOIP Freedom” means VOIP Freedom LLC.
“collection” means the act of gathering, acquiring,
or obtaining personal information through VOIP Freedom’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 VOIP Freedom and the customer.
“Privacy Officer” means an individual designated by VOIP Freedom who is accountable for VOIP Freedom’s compliance with this Policy.
“use” means the treatment and handling of personal information by and within VOIP Freedom.
VOIP Freedom 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.
VOIP Freedom 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. VOIP Freedom 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.
VOIP Freedom 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
The following are the particular purposes for which VOIP Freedom 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 VOIP Freedom 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 VOIP Freedom intends to use personal information
that was previously collected for a purpose or purposes other than
those set out above, VOIP Freedom will identify and explain the new purpose
prior to its use. VOIP Freedom 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, VOIP Freedom will communicate special
bonuses and/or new product offers to you that may be of interest. As a
VOIP Freedom customer, you are entitled to opt-out of receiving such
information from VOIP Freedom
VOIP Freedom 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 VOIP Freedom to meet its stated purposes.
VOIP Freedom’s website may contain links to other sites
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. VOIP Freedom 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
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 VOIP Freedom 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. VOIP Freedom 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 VOIP Freedom, 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 VOIP Freedom with
personal consumer information.
An individual may withdraw consent at any time
by providing VOIP Freedom with notice in writing, subject to any applicable
legal or contractual restrictions. VOIP Freedom will inform the individual of
the associated implications, including the fact that if consent is
withdrawn, VOIP Freedom may be unable to process requests for certain products
VOIP Freedom 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 VOIP Freedom’s website anonymously
without revealing any personal information. When a customer visits the
site, his or her IP address is collected by VOIP Freedom, 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 VOIP Freedom’s website only by the knowing and consenting supply of that information by a customer.
sent to your web browser from VOIP Freedom’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
VOIP Freedom 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 VOIP Freedom
to track visitors to its site and compile related statistics and, in
turn, enable VOIP Freedom to improve customers’ online experience and to
monitor the site’s operation. VOIP Freedom does not collect personal
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 VOIP Freedom’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 VOIP Freedom may
disclose personal information about a particular customer to third
parties. For example, VOIP Freedom may disclose information to the following
- another telecommunications company, regarding the provision of services to a customer;
- companies providing communications directory services;
- persons involved in marketing or developing VOIP Freedom’s services;
- credit collections agencies;
- emergency services;
- people who are an agent of the customer, as reasonably determined by VOIP Freedom;
- third party affiliates of VOIP Freedom that fulfil certain administrative purposes on VOIP Freedom’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 VOIP Freedom believes that a third party is using personal information in a
manner that does not comply with applicable laws, industry codes or
contracts, VOIP Freedom will pursue corrective action, up to and including
termination of the relationship.
VOIP Freedom 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. VOIP Freedom 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. VOIP Freedom will take due care when
destroying personal information so as to prevent unauthorized access to
the information. In any event, VOIP Freedom 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.
VOIP Freedom will make reasonable efforts to ensure
that the personal information it is using or disclosing is accurate and
complete. VOIP Freedom 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. VOIP Freedom 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, VOIP Freedom 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 VOIP Freedom that his or her personal information is
inaccurate or incomplete, VOIP Freedom will amend the information, as
required. If VOIP Freedom 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. VOIP Freedom 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
• 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 VOIP Freedom has
reasonable grounds to believe that personal information is being
inappropriately collected, used or disclosed.
VOIP Freedom 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
VOIP Freedom cannot ensure that its system is entirely sufficient or
impermeable, and as such makes no warranties or representations to that
effect. VOIP Freedom 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 VOIP Freedom’s negligence.
VOIP Freedom 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. VOIP Freedom 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.
VOIP Freedom is open about the policies and procedures
also be accessed online on VOIP Freedom’s website (www.voipfreedom.net).
To ensure the integrity of our security
procedures and business methods, VOIP Freedom 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, VOIP Freedom 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 VOIP Freedom to provide an account of the
existence, use and disclosure of this information to third parties.
Typically, VOIP Freedom will provide the pertinent
personal information at no cost, depending on the nature and extent of
the request. However, VOIP Freedom reserves the right to impose a cost in
appropriate circumstances; should a cost be imposed, VOIP Freedom will
communicate the approximate cost to the individual and will await
payment before proceeding. VOIP Freedom is committed to providing any
requested information in a format that is accessible and easily
In response to any requests seeking further
details regarding disclosure of personal information to third parties,
VOIP Freedom will provide as much detail and information as is reasonably
possible. Where VOIP Freedom 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
In some situations, VOIP Freedom 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. VOIP Freedom may also be prevented by
law from providing access to certain personal information. Where
possible, VOIP Freedom will disclose the reasons for denying access to an
individual upon written request.
Where an individual is unsatisfied with VOIP Freedom’s
response to a challenge or a request for information, VOIP Freedom will record
details of that challenge in the individual’s file.
VOIP Freedom has in place certain procedures in order
to receive and respond to inquiries and complaints regarding its
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 VOIP Freedom Privacy Officer.
VOIP Freedom may amend this Policy from time to time. It is your responsibility to review this Policy to check for updates.