Overview and Scope
Telelink Services Incorporated (“TLS”) is committed to safeguarding and handling the personal information that it collects, uses, discloses, and otherwise processes in a responsible and secure manner. TLS is a call center operation that provides in-bound and out-bound calling and related services such as web chat, email and SMS (collectively, the “Services”) for businesses that may include any FirstService owned Brand (“Business Customers”). Through these Services, TLS collects information on behalf of its Business Customers in order to provide its Business Customers with information they need to provide their own services for individual consumers.
This privacy policy outlines how TLS collects, uses, and otherwise processes information about our Business Customers and those entities’ customers through our website located at www.tlscv.com (“Website”) as well as through our on- and offline Services as described above. It also describes how we process the personal information of individuals who may apply for a job with us.
Personal Information
“Personal information” is any information that is related to you, identifies you, or makes you identifiable. Generally speaking, personal information does not include “business contact information” such as the name, job title, business address, or business telephone number of an employee of an organization.
Overview of the Information we Process
In order to provide our Services, we collect and use personal information about the customers and potential customers of our Business Customers p. In general, we collect and use this personal information as directed by our Business Customers and legally speaking, we are a “data processor” and a “service provider” as these terms are used in certain applicable privacy laws. TLS collects and records information from individuals on behalf of its Business Customers in various ways including through telephone conversations (which may be recorded), by written responses in email or paper form, by Web based correspondence, and by indirect means such as call displays within our cloud contact center. The types of personal information we collect will vary depending on the requirements of each Business Customer.
Because our Business Customers decide how the personal information of their customers will be used, it is the responsibility of our Business Customers to ensure that such individuals understand how the Business Customer (and how TLS on behalf of the Business Customer) collect and process their personal information. Our Business Customers should do this by, at a minimum, posting a privacy policy that describes the information they collect, how they use it, and who they share it with. Also, if our Business Customers collect any sensitive personal information, they should obtain the affirmative, express consent from their individual customers to use and process this information.
Generally speaking, TLS does not use the personal information it collects on behalf of its Business Customers for any of its own purposes without the express consent of the individual. TLS relies on the representations of its Business Customers regarding the consent to collect, use, and disclose the personal information of individual consumers. TLS is not responsible for the privacy policies or practices of its Business Customers. TLS may use personal information for internal quality control and training purposes, and it may also use aggregate or anonymized information which will not be linked to identified individuals for various other uses for itself and third parties such as customer analytics.
What Information we Collect and How we Use it
In order to perform our contract with our Business Customers, or in order to maintain our business relationships, prevent risk and fraud, provide our Services, improve our Services, and to be responsive to our Business Customers or other individuals we interact with, we must process your personal information. In some cases, we only process your personal information with your consent.
What we Collect
- Information about you that you provide us about yourself, like your name, address, email address and phone number
- Information about how you access and use our Website or Services (or that of our Business Customers), including information about the device and browser you use, your network connection, your IP address, and details about how you browse our Business Customers’ websites and platforms. We collect some of this information by using cookies or other similar technologies directly from your device. For more information about how we use these technologies, please refer to our Cookies section below.
- If you are a Business Customer, we collect your contact information, such as your mailing address
How we use it
- To provide you use of, and to improve our Services you are trying to use (e.g., to confirm your identity, contact you about issues you may be experiencing with one of our Business Customers, etc.)
- To verify that we are speaking with you
- To comply with legal requirements
- To provide you use of, and to improve our Website and Services (e.g., identifying ways to make our platform easier to use or navigate)
- To personalize your experience using our Websites (e.g., by changing the layout of our webpages)
- To provide our Business Customers with aggregated analytics relating to their services
- To provide you with the Services
- For billing purpose
Who we Share your Information with
TLS does not share personal information with any third parties except the Business Customer on whose behalf TLS collected such information and TLS’ consultants and professional advisers for the uses described above. The following is a summary of the categories of personal information we may collect about you and with whom we may have disclosed that information, depending on how you use TLS’ Services:
Categories of Personal Information Collected
- Identifiers, including name, email address, mailing address, phone number
- Commercial information, including products you purchase, place in your shopping cart, favourite or review (if you are an individual consumer of one of our Business Customers) and information about you and your business (if you are a Business Customer)
- Internet or other electronic network activity information, including information regarding the device and browser you use, network connection, IP address, and how you browse through our Website or that of our Business Customers
- Geolocation data, including your mailing and billing address
- Inferences, or information derived from other personal information about you, which could include your preferences, interests, and other information used to personalize your experience
- Other information you provide to us or our Business Customers
Recipients of Personal Information
- Companies who help us provide you with our services, including cloud storage providers, payment processors, fulfillment partners, security vendors, email providers, marketplaces and data analytics vendors;
- Business Customers whose websites you visit or whose services you obtain in order to help them improve their services and conduct analytics and marketing;
- Law enforcement or other third parties in connection with legal requests, to comply with applicable law, or to prevent harm
- In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or reorganization, we will share your personal information with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets.
Retention
Because we need your personal information to provide our Services, we generally keep your personal information while you use our Services or those of our Business Customers.
If you are a Business Customer of ours and you close your business, you stop paying your contractual fees, or we terminate our contract with you, we retain store information for two years before we begin the process of deleting or anonymizing personal information. We don’t do this immediately in case you renew your contract with us, or if there is a legal complaint or audit relating to your business. If you contact us to request deletion of your business’ information, we will begin the process of deleting or anonymizing personal information after 90 days, except if we are legally required to retain specific information. If you have questions about this process, please contact us. Please keep in mind that after we anonymize your personal information, we may continue to use non-identifiable information to improve our Services.
Security
TLS stores any personal information it collected through a combination of paper and electronic files. We have implemented reasonable physical, organizational and technological measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. These measures include:
- Our local office is secured with controlled access to floors and offices and server room monitored by security cameras. Additionally stationary devices left in office overnight are locked to workstations.
- Administrative protocols such as robust internal password policies and restricted access by our personnel to files that contain personal information on a need-to-know basis; and
- Technological safeguards such as the use of security software and firewalls.
You should be aware, however, that no system or method of transmitting or storing information is completely secure. While TLS takes appropriate measures commensurate to the volume and sensitivity of personal information we collect to protect such information, there is always a risk that it may be lost, intercepted or misused.
TLS also cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be secure.
Links to Third Party Websites and Social Media Platforms
The Website may present links to other websites. We provide links to third party websites as a convenience to users and these links are not intended as an endorsement of, or referral to such linked websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. TLS is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies and Terms of Use before providing them with your personal information.
Our Website may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Website.
Cookies & Tracking Information
The Websites and our third-party service providers may use “cookies”, a technology that installs information on a Website user’s computer to permit the Website to recognize future visits using that computer and to track information about your use of our Website. Cookies are small text files that enhance the convenience and use of the Website. We use them to determine Website traffic, information about your devices and internet connection, including your IP address, operation system and browser type, convey useful information about your interests, and to personalize any future visits you make to our Website. We may maintain or associate this information with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically.
If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser’s cookie options, please refer to the instruction documentation of your particular browser or seek online assistance.
Like many other websites, the Website may make use of “per session” and “persistent” cookie technology. Per session cookies track information during an open session and are stored only temporarily in your computer’s memory. Persistent cookies are deposited on a visitor’s computer until they expire or until the visitor deletes the cookies. Information from these cookies help TLS analyze traffic patterns to the Websites, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that the Website’s visitors use. TLS uses this information to facilitate and enhance your online visits.
Accessing your Information
Under Canadian privacy law, you have the right to request access to any personal information TLS has in its custody or control, and to request updating and/or correction to same.
Subject to certain exceptions and restrictions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include, but are not limited to: information that is prohibitively costly to provide, information that contains the personal information of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
https://preferences.tlscv.com/privacy
If TLS has forwarded information to one of its Business Customers, it will advise of the contact information of that Business Customer so the individual can access such information in accordance with the Business Customer’s privacy policies.
Changes to this Policy
Privacy laws are rapidly evolving and, as a result, TLS reserves the right to change this Privacy Policy at any time. The most current version of this Privacy Policy is posted on the Website. Regardless of any changes TLS makes to this Privacy Policy, TLS will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, or as otherwise required or permitted by law, unless you have given your express consent for TLS to do otherwise.
Contact us
If you have any questions or comments about this Policy or the manner in which we treat your personal information, you may contact our Privacy Officer Stephanie Thomson at privacy@tlscv.com TLS Privacy Officer.