SPLICE SOFTWARE INCORPORATED - PRIVACY POLICY

Our Commitment

This Privacy Policy is based on the federal Personal Information Protection and Electronic Documents Act ("PIPEDA") and Alberta's Personal Information Protection Act ("PIPA"). It governs the relationship between Splice Software Incorporated ("Splice", "we", "us" etc.) and individuals with whom we interact, such as our customers, potential customers, the clients of our customers and suppliers ("you").

At Splice we are committed to providing excellent service and to ensuring that our relationship with you is conducted with integrity and in a responsible, fair, honest and ethical manner. Consistent with these objectives we maintain high standards of confidentiality with respect to the personal information in our possession.

If you have any questions about this Privacy Policy or wish to access the personal information in our possession about you, please contact our Privacy Officer at the address set out below.

1.0 Collection, Use and Disclosure of Personal Information

1.1 What is personal information?

Personal information is information that may be used to identify a specific individual (not including the business address and business phone number of an individual). Examples of personal information include your name, address, age, social insurance number and other personal identification numbers.

1.2 What personal information does Splice collect and use?

In the course of carrying on our business, it is necessary for Splice to collect and use information about a variety of individuals. The way this information is used is dependent upon the nature and sensitivity of the particular information. Splice limits its collection, use and disclosure of your personal information to the purposes that we have identified to you. For example, Splice may collect personal information such as name, address and contact information in order to provide you with our services or to respond to your questions or concerns.

The only personally identifiable information we collect and store is the information you choose to provide us. In addition, we may occasionally collect information when offering information from our site. At the time that we collect this information we will give you the opportunity to opt out of receiving further offers and information from Splice.

1.3 Purposes: Why do we collect personal information?

Splice collects and uses personal information for the purposes reasonably required to carry on our business, including the following:

To establish and maintain a responsible relationship with you: Splice collects basic information from its customers, potential customers, clients of customers or suppliers and other individuals to confirm their identity and related contact information. This information is used to maintain an effective relationship with you.

To provide our services: Splice collects and uses personal information in order to provide our call-centre service that dispatches voicemail messages to a database of contacts, each of whom have provided their express consent.

To meet legal requirements: Splice collects and uses personal information in order to meet our contractual obligations to you, and our legal obligations to others.

To manage, develop and improve our operations: Splice collects and uses personal information to ensure the efficient operation of our business.

To understand your needs: From time to time, we may ask you to participate in surveys that provide us with important information about the effectiveness of services, or other communications.

We do not sell names, email addresses, mailing addresses, or other information to third parties for any purpose.

If we identify a new purpose for the personal information that we have collected from you, we will obtain your consent before using your personal information for the new purpose.

1.4 What personal information does Splice disclose?

Splice may be required to disclose personal information about individuals in certain situations, including the following:

To an affiliated company or a third party service provider where the third party has agreed to handle the information in accordance with our policies and the applicable legislation.

To a person whom Splice reasonably believes to be acting as the individual's agent.

To a public authority, or its agent, to the extent required to comply with legal or regulatory requirements.

For the purpose of a proposed sale of all of or a part of our business, in which case, Splice will obtain the agreement of third parties to protect the confidentiality of information disclosed.

1.5 Consent

Except in limited circumstances, Splice will only collect, use or disclose your personal information with your consent. In certain cases, Splice will have obtained your express consent to the collection, use or disclosure of your personal information. Alternatively, by your receipt of this Privacy Policy or by using the services provided on the Splice website, Splice will assume, unless we hear from you otherwise, that you consent to the collection, use and disclosure of your personal information by Splice in accordance with this Policy.

You may withdraw or limit your consent to our collection, use or disclosure of your personal information at any time, subject to any legal or contractual restriction and reasonable notice. Please note that the withdrawal of your consent may change the way in which Splice is able to interact with you.

We will not use or disclose your personal information without your consent except in the following circumstances:

When required by law or for law enforcement or investigatory purposes.

For an emergency that threatens life, health or security.

For the purpose of collecting on a debt owed to Splice.

If the information is publicly available and specified in the applicable regulations.

2.0 Protecting Your Personal Information

Keeping your personal information confidential and secure is a priority for us. In order to ensure protection of your personal information, we have developed security procedures to safeguard and protect your personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification, including:

Limiting the collection, use and disclosure of personal information to that reasonably required to carry on our business.

Ensuring that areas and documents are only accessible by authorized personnel on a need-to-know basis.

Protecting the confidential nature of personal information when dealing with other organizations and requiring them to meet the same standard as we do in handling personal information.

3.0 Your Rights

3.1 Accessing your personal information

We will honour any reasonable requests you make to review, update or correct any of your personal information that is held by Splice. We will respond to your request for access within 30 days of the request being made.

You could refuse to allow us to obtain, use or share your personal information or you could also withdraw a previously given consent at any time. However, by doing so, depending on the situation, you may be limiting or even preventing our ability to provide you with the service or product you desire.

3.2 Requesting an update or correction

If you believe that any of your personal information is inaccurate, you may ask us to correct it. We will respond to your request to update or correct your personal information within 30 days of the request being made.

3.3 Registering complaints

In the event of any conflict or other concern regarding access to, or the accuracy or our use of, your personal information, you may register a question or complaint with our Privacy Officer.

4.0 Contact Information and Resources

Our goal is to respect your privacy. We welcome your comments and questions.

If you wish to access your personal information, change your consent to the ways in which we may use your personal information, have a complaint about our Privacy Policy or the manner in which we may have handled your personal information, or if you have any questions about our Privacy Policy, please contact our Privacy Officer as follows:

Chief Privacy Officer
Tara Kelly, President
Tel: (403) 720-8326

To find out more about federal privacy laws, contact the Office of the Privacy Commissioner at 1-800-282-1376 or visit its website at www.privcom.gc.ca.

For more information on privacy laws in Alberta, you may contact the Office of the Information and Privacy Commissioner of Alberta toll free at 1-888-878-4044 or email generalinfo@oipc.ab.ca or visit its website at www.oipc.ab.ca.

5.0 Changes to this Privacy Policy

In order to ensure that our Privacy Policy is kept up to date, we reserve the right to change it from time to time. Notice of changes to the Privacy Policy may be posted on the Splice website. We encourage you to review this Privacy Policy periodically for any changes or updates.

6.0 Visiting the Splice Website

A visitor to the Splice website is not required to reveal any personal information, such as name, address, or telephone number. Nor is such information collected passively by electronic means.

Your personal information is only collected when you voluntarily complete an online application, request form, or survey or when you voluntarily provide the information to one of our customers for the express purpose of being contacted by us. Personal information collected during the online application is only used to respond to your inquires or requests or to provide the services you expressly request and is not used for any other purposes. We will not send you any unsolicited electronic communication.

Our website does not collect visitor information in the form of the visitor's domain or Internet Protocol ("IP") address but does collect information regarding which pages are accessed. This information is used internally, only in aggregate form, to better serve you by helping us manage and improve the content of our website and to diagnose technical problems.

Splice does not store 'cookies' on your computer when you visit our website.

This site contains links to other websites on the Internet that are owned and operated by third parties. Splice is not responsible for the privacy practices or the content of such Web sites. The information practices of those websites are not covered by this Privacy Policy, but by their own terms and policies, which you should read carefully. These other sites may send their own cookies, collect data or solicit personal information.

7.0 Splice's Commitment to the Ten Privacy Principles

Principle #1: Accountability - Splice is responsible for personal information under its control and has designated a Privacy Officer who is accountable for Splice's compliance with the ten privacy principles.

Principle #2: Identifying Purposes - Splice shall identify the purposes for which personal information is collected at or before the time of collection.

Principle #3: Obtaining Consent - The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Principle #4: Limiting Collection - The collection of personal information shall be limited to that which is necessary for the purposes identified by Splice. Personal information shall be collected by fair and lawful means.

Principle #5: Limiting Use, Disclosure and Retention - Splice shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Splice shall retain personal information only for as long as necessary to achieve fulfillment of the identified purposes.

Principle #6: Keeping Personal Information Accurate - Splice shall keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle #7: Safeguarding Personal Information - Splice shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle #8: Openness Concerning our Privacy Practices - Splice shall ensure that specific information about its policies and practices relating to the management of personal information is made readily available to individuals with whom it interacts.

Principle #9: Access to Information - Splice shall, upon request, inform an individual of the existence, use, and disclosure of his or her personal information and shall give such individual access to that information.

Principle #10: Challenging Compliance - An individual shall be able to address a challenge concerning Splice compliance with PIPEDA or PIPA to the Splice Privacy Officer.