At Cityfone, we are committed to protecting the privacy of our customers’ personal information. We take all reasonable steps to ensure that this information is safe and secure, including putting in place rigorous policies and procedures to fully comply with all Canadian privacy laws and regulations.
All customers of Cityfone, operated by Rogers Communications Canada Inc. which is referred to here as Cityfone.
What is personal information?
Personal information is information collected by Cityfone about an identifiable individual, but does not include aggregated information that cannot be associated with a specific individual.
Principle 1 – Accountability
How can I get more information about how Cityfone handles my personal information?
Cityfone’s privacy practices comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and where applicable with the privacy rules established by the Canadian Radio-television and Telecommunications Commission (CRTC). Our corporate and online Privacy Policies are available at http://www.cityfone.net/terms/privacy-policy. We also review our privacy policies and practices on a regular basis to ensure they remain current and meet our customers’ expectations. Additionally, Cityfone’s employees receive privacy training and must comply with Cityfone’s privacy practices as a condition of employment.
Rogers has appointed a Chief Privacy Officer (CPO) who oversees privacy compliance for the Rogers Group of Companies including Cityfone. The CPO has a team that takes responsibility for the day-to-day compliance with PIPEDA, including the collection, use, and disclosure of personal information.
Principle 2 – Identifying Purposes
What type of personal information about me does Cityfone collect?
Personal and account information for our customers may include, but is not limited to name, e-mail address, mailing address, phone number, payment information, date of birth, telephone numbers you placed calls to or received calls from, location information, and any recorded complaints.
Cityfone may also collect network data about you, your devices, and your use of those devices on our network.
Why does Cityfone collect my personal information?
Your relationship with Cityfone means that we collect and use account and personal information about you. This information helps Cityfone manage our business operations for the following reasons:
- To deliver you the products and services you have purchased from us, and to bill you and collect payment for those products and services.
- To understand your needs and make customized information available regarding other products and services offered by Cityfone and our agents, dealers and related companies, or trusted third parties that may be of interest to you.
- To provide tailored service to you. For example, we may use account information about you to improve your interactions with us or provide a positive and personalized customer experience.
- To perform analytics, administer surveys, or request feedback to improve and manage our relationship with you.
- To ensure the Cityfone network is functioning and protect the integrity of our network.
- To comply with legal obligations and regulatory requirements.
We will also collect information from third party credit agencies or other Rogers’ companies (of which Cityfone is part of) and affiliates, such as Rogers Bank, to fulfill any special offers; manage credit or other business risks; collect outstanding debt; or detect, prevent, manage, suppress, or investigate financial abuse, fraud or other unauthorized or illegal activity.
We may also collect personal and account information about you to evaluate your eligibility for other products and services offered by Cityfone and the Rogers Group of Companies, and to assist other Rogers companies or affiliates such as Rogers Bank, to assess your eligibility for their products or services.
We may also collect personal information about you for other purposes from time-to-time, or as permitted or required by law. We will always identify any additional purpose prior to or at the time of collection.
Principle 3 – Consent
How does Cityfone collect information about me, or obtain my consent to use or disclose that information?
Cityfone collects information about you primarily from you, but from time to time we may also collect information about you from third parties. For example, we may collect information about you from credit reporting agencies, those who you have authorized to disclosure your information to us, government agencies, or publicly available information or other public sources.
We may also collect information from other Rogers’ companies, such as Rogers Bank.
Your consent to the collection, use, or disclosure of your personal information may be implied or express. We may obtain your express consent to the collection, use, and disclose your information in one of the following ways:
- in writing; or
- by electronic confirmation via the internet; or
- verbally, where an audio recording of the consent is retained by us; or
- through other methods, as long as a record of your consent is created by you, by us, or by a third party acting on Cityfone’s behalf.
The choice to provide Cityfone with your consent to the collection, use, and disclosure of your personal and account information is always yours, however, your decision to withhold such consent may limit our ability to provide you with certain products, services, or offers.
Principle 4 – Limiting Collection
What types of personal information does Cityfone not collect?
We do not collect and retain the following types of information:
- content of telephone conversations across our networks (other than recordings of calls made to our customer care centre, which are recorded for quality and training purposes);
- the content of your text, picture and video messages;
- content of the applications you use;
- websites visited or IP addresses; and
- internet search history.
Yes, but we limit the types of technologies and the information such technologies will collect about you.
Principle 5 – Limiting Use, Disclosure, and Retention
What can Cityfone do with my account and personal information?
Cityfone uses your personal and account information to fulfill the purpose for which it was collected.
We will disclose information about your credit behaviour to credit reporting agencies or other parties collecting outstanding debt.
Your personal and account information may also be shared with other Rogers’ companies or affiliates, such as Rogers Bank, in order for them to assess your eligibility for their products or services; to directly provide you offers about their products or services; to confirm or authenticate your identity and ensure they have your correct and up-to-date information; to manage credit risk or other business risk; to better understand your needs and to serve you better; to process any offers or loyalty credits; or to detect, prevent, manage, and investigate fraud or other unauthorized or illegal activity.
We do not sell customer information to third parties, and will only disclose your personal information to organizations outside of Cityfone and the Rogers Group of Companies without your consent in the following limited circumstances:
- To a person who, in our reasonable judgement, is seeking the information as your agent;
- To another telephone company, when the information is required for the provision of home phone service and disclosure is made confidentially and only for that purpose.
- To a company involved in supplying phone or phone directory related services.
- To a service provider or other agent retained by us, such as a credit reporting agency, for account management, the collection of past due bills on your account, or to evaluate your credit history.
- To a service provider or third party that is performing administrative functions for us to manage or customer accounts or employee benefits and/or programs provided the information is used only for that purpose.
- To another organization for fraud prevention, detection, and investigation if seeking consent from you would compromise the investigation.
- To a law enforcement agency whenever we have reasonable grounds to believe that you have knowingly supplied us with false or misleading information or are otherwise involved in unlawful activities.
- To a public authority or agent of a public authority if, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.
- To a public authority or agent of a public authority, for emergency public alerting purposes, if a public authority has determined that there is an imminent or unfolding danger that threatens the life, health or security of an individual and that the danger could be avoided or minimized by disclosure of the information.
- To assess a third party who may be interested in buying Cityfone’s assets, and personal customer and/or employee information must be shared in order to assess the business transaction.
We will disclose information about your credit behaviour to credit reporting agencies or parties collecting outstanding debt.
Your personal and account information may also be shared with other Rogers’ companies or affiliates, such as Rogers Bank.
We will not make any other disclosure of your personal information unless we have your consent or we are required to do so by law.
We may also de-identify or anonymize information about our customers to identify trends, manage our business, develop statistical information, understand how we are performing, or develop relevant products services or offers. Use of de-identified information may also be shared with third parties for other analytical purposes. De-identified or anonymized information will not personally identify any individual and therefore is not subject to this policy.
Will Cityfone use my information for direct mailings or other communications?
Cityfone may send you information about other products or services that we, or our affiliates or partners, offer that may be of interest to you. If you do not want to receive such communications, all you have to do is tell us, either online or through a customer service representative. If you have given permission and change your mind, you can ask to be removed from future promotional communication from us.
How long will Cityfone retain my personal information?
Cityfone will only retain your account or personal information for as long as necessary to fulfill the purpose we collected the information, or for sufficient time to allow you access to the information if it was used to make a decision about you or your account. Once we no longer require your account or personal information it will be destroyed or de-identified.
Principle 6 – Accuracy
What if I disagree with the accuracy of my personal information Cityfone has about me?
Cityfone ensures that customer information is accurate, complete and up-to-date. Customers can ask to review that information and have the opportunity to challenge its accuracy and completeness and request amendments, as appropriate, by contacting our Chief Privacy Officer.
Principle 7 – Safeguards
Where will my personal information be stored?
Account and personal information about our customers may be stored or processed in or outside Canada. The information will be protected with appropriate safeguards, but may be subject to the laws of the jurisdiction where it is held.
How will Cityfone ensure my personal information is kept safe?
Cityfone has rigorous security and safeguard processes and procedures in place, to ensure that any account or personal information of our customers remains safe from theft, loss, or unauthorized access.
For example, we use ID validation process as part of our ongoing corporate efforts to protect your personal information associated with your Cityfone account(s). By requesting information from you upfront (e.g. name, phone number and date of birth or other identification), Cityfone can confirm that we are in fact communicating with you or an authorized person to act on your behalf.
Our processes assist in the prevention of any unauthorized access to your account information that may arise from attempts to commit fraud or identity theft. Cityfone may change this ID validation process from time to time as industry best practices evolve.
The Chief Privacy Officer and delegates ensure that Cityfone is responsible for the personal information of our customers that is in our possession and control. We will ensure that there is a comparable level of protection for information that is processed for us by third parties.
Principle 8 – Openness
How can I get more information about how Cityfone handles my personal information?
Principle 9 – Individual Access
How can I access my personal information that is retained by Cityfone?
You can access your personal information retained by us by contacting our CPO by email at firstname.lastname@example.org or in writing at Chief Privacy Officer, Rogers Group of Companies, 333 Bloor St. E., Toronto, ON, M4W 1G9.
Principle 10 – Challenging Compliance
What are my options if I want more information about privacy?
The Office of the Privacy Commissioner of Canada oversees Cityfone’s personal information handling practices. If your privacy concerns are not addressed to your satisfaction by Cityfone you may contact the Office of the Privacy Commissioner of Canada for further guidance:
- Website: www.priv.gc.ca
- By Phone: 1 800 282 1376 or 819 994 5444
- By Fax: 819 994 5424
- By TTY: 819 994 6591