Privacy Policy
This Privacy Policy applies to Start.ca and its subsidiary companies, as they may exist from time to time (“Start”, “us”, “we”, or “our”).
At Start, your privacy is important to us.
We respect your privacy and take great care to safeguard personal information. As part of our ongoing commitment to put our customers first, we have instilled a corporate philosophy of protecting privacy across all of our business operations.
We have developed this Privacy Policy to provide you with details about our privacy practices and the general principles that govern our collection, use and disclosure of personal information. This Privacy Policy reflects the requirements of Canada’s applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and our own continuing commitment to customer privacy. In this policy, the terms collection, use, disclosure have the meanings set out in PIPEDA and other applicable privacy legislation.
Why We Collect Personal Information
Start may collect personal information about you for the following purposes:
- To establish and maintain a responsible commercial relationship with you and to provide ongoing service. For example, when you apply for services, we collect information that allows us to confirm your identity and credit history so that we can accurately bill and collect for the products and services that you receive from us. We may collect credit card or bank account information if you prefer the convenience of pre-authorized payment for services.
- To understand your needs and preferences. We maintain a record of the products and services you receive from us, and we may ask for additional information so that we can serve you better. For example, we will ask for your email address, if you wish to pay your bills electronically.
- To develop, enhance, market or provide products and services. For example, we look at how our customers use our products and services, so that we can understand how to improve them. From time to time, we may review and analyze your use of our products and services to help us provide better product recommendations and special offers that we think will interest you. In addition, we may collect information about you from sources who have your consent or are otherwise authorized to disclose it, for the purpose of inferring your preferences for particular products, services, or lifestyle activities and providing recommendations and special offers from Start or marketing partners that we think will interest you.
- To manage and develop our business and operations. For example, we analyze customer usage of our networks and facilities to help us manage them efficiently and plan for future growth. Telephone calls to or from Start customer care, sales or service representatives may be monitored or recorded for quality assurance purposes.
- To meet legal and regulatory requirements. For example, we may collect information in response to a court order, or to satisfy a request by the Canadian Radio-television and Telecommunications Commission, herein referred to as the CRTC, for information about a customer complaint and how it was resolved.
When We Disclose Personal Information
There are a variety of circumstances where we may need to disclose some personal information about our customers. Subject to applicable regulations, we may disclose personal information, on a confidential basis with the information to be used only for the purpose for which it was disclosed, to:
- a person seeking information as an agent of a customer, such as a customer’s legal representative, or as an authorized user under his or her account, if we are satisfied that the person is authorized to receive the information;
- other Start business units to help us serve our customers better and to provide them with services from different parts of our company;
- another telecommunications company for the efficient and cost-effective provision of telecommunications services, such as the information required to facilitate the porting of services between carriers;
- a company involved in supplying a customer with telecommunications or directory related services, for example, Yellow or White Page listings;
- our service providers and partners to help us serve you better, for example, a company or individual hired by Start to perform research or data processing, or to administer Start offers or services. We may share information with our suppliers, agents or other organizations or individuals contracted to Start to perform services or functions on our behalf where they require the information to assist us in serving you. We strive to minimize the amount of personal information that we share with our service providers and partners; we share the information reasonably necessary to achieve the stated purpose, and require that it only be used for that purpose.
- a third party to evaluate a customer’s creditworthiness or to collect an account;
- a credit-reporting agency;
- a public authority or agent of a public authority if, in the reasonable judgment of Start, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information. If a customer dials 911, for example, we will provide the customer’s name, telephone number, address and other location information to the emergency agency;
- third parties in connection with the sale of parts of our business, the sale or securitization of assets, or the merger or amalgamation of part or all of our business with other entities. Since customer and account information will normally be part of such transactions, we may use or disclose such information to other parties included in the transaction, as part of due diligence and/or on completion of the transaction.
- corporate affiliates and parent companies for purposes disclosed under ‘Why We Collect Personal Information’.
- Federal and provincial government institutions, law enforcement agencies or other third parties in response to a court order or if otherwise required or authorized by law.
How We Protect Your Personal Information
We maintain a robust information security governance program to protect your personal information with appropriate security safeguards. Our safeguards include administrative, physical and technical security controls. We protect the privacy of your personal information through contractual and other means when we are working with other organizations.
In order to protect your personal information and your right to privacy, Start will:
- strive to keep your personal information as accurate and up-to-date as is necessary for identification purposes;
- not collect, use or disclose your personal information for any purpose other than those identified in this Privacy Policy, your Customer Service Agreement, or our Service Terms, except with your consent and/or in accordance with applicable regulations.
For greater clarity, unless you provide express consent, Start will not:
- share your personal information with or sell it to third-party marketers not acting on Start’s behalf; or
- use your personal information to enable third-party targeted advertisements, unless your consent has been provided. Moreover, Start does not collect information about the websites you viewed (except visits to our own websites, which we use to optimize our Start web properties), your internet search history or the content of the third party applications you use.
Personal information may be stored or processed outside the jurisdiction where it was collected. In either case, the information is protected with appropriate security safeguards, but may be available to government agencies under applicable law.
What Are Your Choices?
We rely on your consent to continue to collect, use and disclose your personal information for the purposes we have identified to you. Your consent may be express or implied consent (implied consent is consent that can reasonably be inferred from an individual’s action or inaction), whichever is appropriate in the circumstances and permitted by law. We want you to know that you do have choices and can refuse or withdraw your consent as follows:
- You may have your Personal Information removed from our telephone, mail or email marketing lists. We use these lists to inform you of relevant products, services and special offers that may be of benefit to you. Our directory publisher (Yellow Pages Group) makes available lists of published names, addresses and phone numbers to selected organizations for a fee. You may choose to be excluded from these lists (non-published names, addresses and phone numbers are automatically excluded).
- You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, in either case, this may limit our ability to serve you. You can Contact Us for further information. Unless you tell us otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the identified purposes referred to herein.
We strive to keep your personal information as accurate and up-to-date as is reasonably necessary for the identified purposes. We respond in a timely manner to your requests for correction of your personal information.
We respond in a timely manner to your requests for access to your personal information. We keep personal information only as long as reasonably necessary for the purposes for which it was collected, or as required by law.
Start’s Web Site Usage
During a customer’s interaction with one of Start’s websites, Start may use a browser feature called a “cookie” to collect information anonymously and track user patterns on Start websites. A cookie is a small text file containing a unique identification number that identifies a customer’s browser – but not the customer personally – to Start computers each time a customer visits one of the Start’s websites using cookies. Cookies tell Start which pages of its websites are visited and how many people visited each web page. This helps Start to enhance the on-line experience of visitors to the Start websites. Cookies also serve to identify your computer so that your preferences can be saved for future visits, and Start works with third parties that use these cookies to help us with such traffic management, research and analytics.
The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on Start’s websites.
Third Party Cookies and Advertisements: Some of the advertisements you see on the Start websites are delivered by third party advertisers, Internet advertising companies that work on Start’s behalf or ad networks. These third parties may use cookies or other technology to help deliver ads that are tailored to your interests and track their performance. This is commonly known as “behavioral” or “interest-based advertising”. You can opt-out of several third party ad servers’ and networks’ cookies simultaneously using a tool created by the Network Advertising Initiative located at https://www.networkadvertising.org/managing/opt_out.asp . Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
Updating this Privacy Policy
Start will continue to review this Privacy Policy to ensure it is relevant, remains current with changing technologies and laws, and continues to meet your evolving needs. If changes are made to this Privacy Policy, the updated Privacy Policy will be posted on this page. You may determine when this Privacy Policy was last updated by referring to the date below.
Contact us
We want you to be comfortable with how we protect your privacy. If you have questions that are not addressed in this Privacy Policy, you can call us at 1-866-434-5888 or email [email protected].
Definitions
Customer – An individual who uses, or applies to use, Start products or services, where such individual is a residential customer or an individual carrying on business alone as a sole proprietorship or in partnership with other individuals.
Personal information – Information about an identifiable customer but does not include 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, and any recorded complaints. Information about sole proprietors or partners is only considered to be “personal information” for the purposes of the Start Privacy Policy if it is information about the individuals themselves, as distinct from information about their businesses. The latter is protected by other Start policies and practices and through contractual arrangements.
Date of Publication: November 11, 2024
Privacy Policy last revised on: October 4, 2024