Half Blind Productions

Personal Information Protection Policy

This Personal Information Protection Policy for Private Sector Privacy Legislation comes from file:BC's Personal Information Protection Act
Privacy Officer – means the individual designated responsibility for ensuring that Half Blind Productions complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customer information that is necessary to fulfill the following purposes:

• To verify identity (we may collect email address);
• To process payments (Google, Play Store, or Steam purchases);
• To send marketing emails about our products;
• To gather analytics to improve our products;
• To ensure a high standard of service to our customers;
• To meet regulatory requirements;

Policy 2 – Consent

2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided [include the methods that apply to your organization: e.g., orally, in writing, electronically, through an authorized representative] or it can be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising, analytics and the customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers can withhold or withdraw their consent for Half Blind Productions to use their personal information in certain ways. A customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s, member’s knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;
• When the personal information is required to make a purchase;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law;

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection:
To conduct customer surveys in order to enhance the provision of our products/services;
To contact our customers directly about products and services that may be of interest;
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or personal information to other parties without consent.

Policy 4 – Retaining Personal Information

4.1 If we use customer personal information to make a decision that directly affects the customer, we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the customers' correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
The use of user IDs, passwords, firewalls, and industry standard encryption for storage
Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access)
Contractually requiring any service providers to provide comparable security measures
6.3 We will use appropriate security measures when destroying customer’s personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Customers Access to Personal Information

7.1 Customers have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer of the cost and request further direction from the customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the customer in writing, providing the reasons for refusal and the recourse available to the customer.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer is responsible for ensuring Half Blind Productions' compliance with this policy and the Personal Information Protection Act.
8.2 Customers should direct any complaints, concerns or questions regarding Half Blind Productions' compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Half Blind Productions' Privacy Officer: