Gazelle provides a full range of services to meet the communications needs of consumers including wireless, high-speed internet, local and long distance wireline services.

Gazelle has long been committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various Gazelle policies, agreements and in applicable service rules approved by regulatory agencies over the years. It is also reflected in the high regard and trust with which customers and employees view the management of personal information by Gazelle.

In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the “CSA Code”), was published as a National Standard of Canada. In September 2016, Gazelle established the Gazelle Privacy Policy, to describe in detail how we subscribe to the principles of the CSA Code and the requirements of the Personal Information Protection and Electronic Documents Act, which came into force in 2001.

The Gazelle Privacy Policy is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by Gazelle to our customers and employees. The objective of the Gazelle Privacy Policy is responsible and transparent practices in the management of personal information, in accordance with the National Standard and federal legislation.

Gazelle will continue to review the Gazelle Privacy Policy and privacy-related information made publicly available to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of Gazelle, our customers and employees.

Scope and Application

The 10 principles that form the basis of the Gazelle Privacy Policy are interrelated and Gazelle shall adhere to the 10 principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the CSA Code, the commentary in the Gazelle Privacy Policy has been tailored to reflect personal information issues specific to Gazelle.

The scope and application of the Gazelle Privacy Policy are as follows:

• The Gazelle Privacy Policy applies to Gazelle offering communications services including wireless, high-speed internet, local and long distancewireline services as well as radio. Any time you do business with any of Gazelle, or with anyone acting as an agent on our behalf, you are protected by the rights and safeguards contained in the Gazelle Privacy Policy.
• The Gazelle Privacy Policy applies to personal information about customers and employees of Gazelle that is collected, used or disclosed by these companies.
• The Gazelle Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
• The Gazelle Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Gazelle:
  • a) information that is publicly available, such as a customer’s name, address and telephone number when listed in a directory or made available through directory assistance;
  • b) name, title or business address or telephone number of an employee of an organization; or
  • c) other information about a customer or an employee that is publicly available and is set out in Regulations made pursuant to the Personal Information Protection and Electronic Documents Act.
• The Gazelle Privacy Policy does not apply to customers that are not individuals, such as corporate customers; however, information collected from such customers is protected by other Gazelle policies and practices and by applicable contractual terms.
• The application of the Gazelle Privacy Policy is subject to the requirements or provisions of the Personal Information Protection and Electronic Documents Act, the Regulations made there under, and any other applicable legislation, regulations, tariffs or agreements (such as collective agreements), or the order of any court or other lawful request.

Definitions

Collection – the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means. 
Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Gazelle. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. 
Customer – an individual who o uses, or applies to use, the products or services of Gazelle; o corresponds with Gazelle; or o enters a contest sponsored by Gazelle. 
Disclosure – making personal information available to a third party. 
Employee – an employee or pensioner of Gazelle. 
Personal information – information about an identifiable individual but not aggregated information that cannot be associated with a specific individual.

• For a customer, such information includes a customer’s credit information, billing records, service and equipment records, and any recorded complaints.
• For an employee, such information includes information found in personal employment files, performance appraisals and medical and benefits information.

Third party – an individual other than the customer or his agent, or an organization other than Gazelle or its agents. 
Use – the treatment, handling, and management of personal information by Gazelle and their agents.

Gazelle is responsible for personal information under its control and shall designate one or more persons who are accountable for the company’s compliance with the following principles.

1.1 Responsibility for ensuring compliance with the provisions of the Gazelle Privacy Policy rests with the senior management of Gazelle, which shall designate one or more persons to be accountable for compliance with the Gazelle Privacy Policy. Other individuals within Gazelle may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.

1.2 Gazelle shall make known, upon request, the title of the person or persons designated to oversee the companies’ compliance with the Gazelle Privacy Policy.

Gazelle has designated the Gazelle Privacy Ombudsman to oversee compliance with the Gazelle Privacy Policy. The Gazelle Privacy Ombudsman can be contacted at:

The Office of the Gazelle Privacy Ombudsman
1235 Bay Street, Suite 1003
Toronto, Ontario
M5R 3K4

1.3 Gazelle is responsible for personal information in their possession or control, including information that has been transferred to a third party for processing. Gazelle shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).

1.4 Gazelle has implemented policies and procedures to give effect to the Gazelle Privacy Policy, including:

a) implementing procedures to protect personal information and to oversee the company’s compliance with the Gazelle Privacy Policy; 
b) establishing procedures to receive and respond to inquiries or complaints; 
c) training and communicating to staff about the company’s policies and practices; and 
d) developing public information to explain the company’s policies and practices.

Gazelle shall identify the purposes for which personal information is collected at or before the time the information is collected.

2.1 Gazelle collects personal information only for the following purposes: 
a) to establish and maintain responsible commercial relations with customers and to provide ongoing service; 
b) to understand customer needs and preferences, and determine eligibility for products and services; 
c) to recommend particular products & services to meet customer needs; 
d) to develop, enhance, market or provide products and services; 
e) to manage and develop their business and operations, including personnel and employment matters; and 
f) to meet legal and regulatory requirements. 
Further references to “identified purposes” mean the purposes identified in this Principle 2.

2.2 Gazelle shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Gazelle who shall explain the purposes.

2.3 Unless required by law, Gazelle shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

3.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Gazelle may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.Gazelle may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.Gazelle may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.Gazelle may disclose personal information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.

3.2 In obtaining consent, Gazelle shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.

3.3 Generally, Gazelle shall seek consent to use and disclose personal information at the same time it collects the information. However, Gazelle may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.

3.4 Gazelle will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

3.5 In determining the appropriate form of consent, Gazelle shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.

3.6 In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for Gazelle to collect, use and disclose personal information for all identified purposes.

3.7 A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact Gazelle for more information regarding the implications of withdrawing consent.