PUFFINSTYLE (“www.puffinstyle.com”) is strongly committed to respecting and
protecting your privacy.
personal information PUFFINSTYLE collects from its customers, as well as visitors to its
website located at www.PUFFINSTYLE.today (“Site”), is used only in the manner and
information about an identifiable individual, presented in any form, such as: age, name,
ID number(s), income, ethnic origin, opinions, evaluations, social status, but does not
include the name, title, business address and telephone number of an employee of an
Information Protection and Electronic Documents Act (Canada), and applies to the
collection of personal information from Canadian customers by PUFFINSTYLE.
Identifying Purposes, Consent, Limiting Collection, Limiting Use, Disclosure and
Retention, Accuracy Safeguards, Openness, Individual Access, Challenging
PRINCIPLE #1 – ACCOUNTABILITY
PUFFINSTYLE is responsible for personal information under its control and will
designate an individual or individuals who are accountable for the organization’s
compliance with the following principles.
1.1 Accountability for PUFFINSTYLE ‘s compliance with the principles rests with the
senior management of PUFFINSTYLE and the person or persons designated by senior
management as Privacy Officer, even though other individuals within the organization
may be responsible for the day-to-day collection and processing of personal
information. In addition, other individuals within the organization may be delegated to
act on behalf of senior management or the Privacy Officer.
1.2 PUFFINSTYLE Privacy Officer may be contacted at: Attention: PUFFINSTYLE c/o
Privacy Officer, firstname.lastname@example.org.
1.3. PUFFINSTYLE is responsible for personal information in its possession or custody,
including information that has been transferred to a third party for processing.
PUFFINSTYLE will use contractual or other means to provide a comparable level of
protection while the information is being processed by a third party.
1.4 PUFFINSTYLE will implement policies and practices to give effect to these
principles, including: implementing procedures to protect personal information;
establishing procedures to receive and respond to complaints and inquiries; training
staff and communicating to staff information about PUFFINSTYLE ’s policies and
practices; and developing information to explain PUFFINSTYLE ’s policies and
PRINCIPLE #2 – IDENTIFYING PURPOSES
PUFFINSTYLE will identify the purposes for which personal information is collected at
or before the time the information is collected.
2.1 PUFFINSTYLE collects personal information only for the following purposes
(“identified purposes”): to provide service(s) and/or products to its customers; to
maintain commercial relations and to communicate with its customers (which will
include, but not be limited to: billing, collection, advertising, promotion, account
verification); to evaluate customers’ financial status and eligibility for credit; to identify
customer needs and/or preferences; to meet legal and regulatory requirements; to
administer and manage its business operations; and as otherwise required or permitted
2.2 PUFFINSTYLE will provide notice of the identified purposes either orally,
electronically or in writing prior to or at the time of collection of the personal information.
2.3 If individual persons collect personal information, they will be able to specify the
purposes for which the information is being collected, or will refer the individual whose
information is being collected to a designated person at PUFFINSTYLE who will specify
2.4 When personal information that previously has been collected is to be used for a
purpose not previously identified, the new purpose will be identified prior to use. Unless
the new purpose is required by law, and subject to the exceptions referred to in
Principle #3, PUFFINSTYLE will obtain the consent of the individual before information
is used for that new purpose.
2.5 Occasionally, PUFFINSTYLE will communicate to you special bonus and new
product offers that we think may be of value to you. PUFFINSTYLE may retain third
parties to assist it in marketing such new or additional PUFFINSTYLE products and
services to our customers (and for such purpose may share personal information with
such third parties) but will not otherwise disclose or make available any personal
information to any third parties seeking to market their products to PUFFINSTYLE ‘s
customers. All PUFFINSTYLE customers have the right to choose not to participate in
direct marketing of new products and services from PUFFINSTYLE . If you wish to opt-
out of receiving targeted communications from PUFFINSTYLE in electronic, printed or
verbal format simply inform us in writing at: Attention: PUFFINSTYLE c/o Privacy
Officer, Email: email@example.com
2.6 The Site may provide hyperlinks, which are highlighted words or pictures within a
hypertext document that may, when clicked, take you to another place within the
document, to another document altogether, or to a third party website not controlled by
PUFFINSTYLE . Such hyperlinked third party websites may collect and disclose
information different than this Site. PUFFINSTYLE is not responsible for the collection,
use, or disclosure of information collected through these third-party websites, and
PUFFINSTYLE expressly disclaims any and all liability related to such collection, use, or
PRINCIPLE #3 – CONSENT
The knowledge and consent of the individual 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, where collection or
use is clearly in the interests of the individual and consent cannot be obtained in a
timely way; where used or disclosed in the case of an emergency that threatens the life,
health or security of an individual; where personal information is publicly available as
defined by regulation; where collection with knowledge or consent might compromise
the availability or accuracy of the information and the collection relates to investigation
of a breach of agreement or contravention of law; and where disclosed for debt
collection purposes or to comply with a subpoena, warrant or court order.
3.2 Where required, PUFFINSTYLE will generally seek consent for the use or
disclosure of the information at the time of collection. In certain circumstances, consent
with respect to use or disclosure may be sought after the information has been collected
but before use (for example, when PUFFINSTYLE wants to use information for a
purpose not previously identified).
3.3 PUFFINSTYLE will make a reasonable effort to ensure that the individual is advised
of the purposes for which the information will be used. To make the consent meaningful,
the purposes will be stated in such a manner that the individual can reasonably
understand how the information will be used or disclosed.3.4 PUFFINSTYLE will not, as a condition of the supply of a product or service, require
an individual to consent to the collection, use, or disclosure of information beyond that
required to fulfill the explicitly specified and legitimate purposes.
3.5 The form of consent sought by PUFFINSTYLE may vary, depending upon the
circumstances and the type of information disclosed. PUFFINSTYLE will seek express
consent when the information is likely to be considered sensitive. Implied consent will
generally be appropriate when the information is less sensitive.
3.6 An individual may withdraw consent at any time, subject to legal or contractual
restrictions and reasonable notice. PUFFINSTYLE will inform the individual of the
implications of such withdrawal. In order to withdraw consent, an individual must provide
notice to PUFFINSTYLE in writing.
3.7 With respect to personal information already collected by PUFFINSTYLE prior to the
PUFFINSTYLE ‘s current customers of the purposes and uses for which such personal
information has been collected. Should an individual object to these ongoing uses or
disclosures, consent may be withdrawn upon providing notice to PUFFINSTYLE in
PRINCIPLE #4 – LIMITING COLLECTION
The collection of personal information will be limited to that which is necessary for the
purposes identified by PUFFINSTYLE . Information will be collected by fair and lawful
4.1 PUFFINSTYLE collects personal information from its customers for the purposes
described under Principle #2.
4.2 PUFFINSTYLE may also collect personal information from such third parties as
credit bureaus, employers or personal references or other third parties that represent
that they have the right to disclose the information.
4.3 The Site uses a feature of Internet web browsers called a cookie, which is a file that
is sent to your browser from the Site’s computers and stored on your computer’s hard
drive. A cookie assigns a unique identification code to your computer in order to collect
anonymous information. On this Site, cookies are used to help us track visitors, conduct
research and improve our content and services.
PUFFINSTYLE ‘s cookies do not collect personal information. PUFFINSTYLE only
collects personal information if you knowingly and willingly provide such information.
You may set your Internet web browser to notify you when you receive a cookie or to
prevent cookies from being sent. If you prevent a cookie from being sent, you may limit
the functionality of the Site.
PRINCIPLE #5 – LIMITING USE, DISCLOSURE, AND RETENTION
Personal information will not be used or disclosed for purposes other than those for
which it was collected, except with the consent of the individual or as otherwise required
or permitted by law. Personal information will be retained only as long as necessary for
the fulfillment of those purposes or as otherwise required or permitted by law.
5.1 PUFFINSTYLE may collect, use or disclose personal information without the
individual’s knowledge or consent in certain circumstances as described in Principle
5.2 PUFFINSTYLE may disclose a customer’s personal information to: Our contracted
agency or company or personnel involved in the development, promotion, marketing or
enhancement of PUFFINSTYLE products and services;
5.3 Personal information may also be disclosed in connection with a sale, transfer or
reorganization of one or more of PUFFINSTYLE ‘s businesses, in which case
PUFFINSTYLE will require that any personal information will continue to be treated in
5.4 PUFFINSTYLE will retain personal information that has been used to make a
decision about an individual long enough to allow the individual access to the
information after the decision has been made, and, in the event of an access request or
a challenge, long enough to exhaust any recourse an individual may have under the
PRINCIPLE #6 – ACCURACY
Personal information will be updated as necessary for the purposes for which it is to be
collected and used.
6.1 The extent to which personal information will be updated will depend upon the use
of the information, taking into account the interests of the individual. Information will be
sufficiently accurate, complete, and up-to-date to minimize the possibility that
inappropriate information may be used to make a decision about the individual.
6.2 PUFFINSTYLE will not routinely update personal information unless such a process
is necessary to fulfill the purposes for which the information was collected.
6.3 Personal information that is used on an ongoing basis, including information that is
disclosed to third parties, will generally be accurate and up-to-date to the best of
PUFFINSTYLE ’s knowledge unless limits to the requirement for accuracy are clearly
PRINCIPLE #7 – SAFEGUARDS
PUFFINSTYLE will use reasonable efforts to protect personal information by security
safeguards appropriate to the sensitivity of the information.
7.1 PUFFINSTYLE has invested and deployed a wide variety of technology and security
features to ensure the privacy of personal and anonymous information on its network. In
addition, PUFFINSTYLE has implemented strict operations guidelines to safeguard
customer privacy at every level of its organization. PUFFINSTYLE will continue to revise
policies and implement additional security features as new technologies become
available. Unfortunately, no system is perfect; therefore, PUFFINSTYLE makes no
representations or warranties with regard to the sufficiency of these security measures.
PUFFINSTYLE shall not be responsible for any actual or consequential damages (or
any other damages or liability of any kind whatsoever, whether as a result of negligence
or otherwise) that result from a lapse in compliance with this Policy because of a
security breach or technical malfunction.
7.2 PUFFINSTYLE protects all personal information regardless of the format in which it
is held. The methods of protection include: physical measures, such as locked filing
cabinets and restricted access to offices; organizational measures, such as security
clearances and limiting access on a “need to know” basis; technological measures,
such as the use of passwords and encryption.
7.3 PUFFINSTYLE makes their employees aware of the importance of maintaining the
confidentiality of personal information. PUFFINSTYLE employees are governed by non-
disclosure obligations. These obligations prohibit disclosure or use of any confidential or
PRINCIPLE #8 – OPENNESS
PUFFINSTYLE will, upon written request, make readily available to individuals specific
information about its policies and practices relating to the management of personal
information, other than confidential commercial information.
8.1 PUFFINSTYLE will make its policies and practices with respect to the management
of personal information comprehensible and accessible, by providing upon request: the
name, title, and address of the Privacy Officer accountable for PUFFINSTYLE‘s policies
and practices and to whom complaints or inquiries can be forwarded; the means by
which an individual can gain access to his or her personal information held by
PUFFINSTYLE ; and a description of the type of information held by PUFFINSTYLE
and/or its subsidiaries, including a general account of its use.
PRINCIPLE #9 – INDIVIDUAL ACCESS
Upon written request, an individual will be informed of the existence, use, and
disclosure of his or her personal information and will be given access to that
information. An individual will be able to challenge the accuracy and completeness of
the information and have it amended as appropriate.
9.1 Upon written request, PUFFINSTYLE will inform an individual whether or not the
organization holds personal information about that individual, and will provide that
individual with a reasonable opportunity to review the personal information in his or her
9.2 PUFFINSTYLE will allow the individual access to his or her personal information
once the individual has provided PUFFINSTYLE with a written request application. The
application will include sufficient information to permit PUFFINSTYLE to provide an
account of the existence, use, and disclosure to any third parties of this personal
information. PUFFINSTYLE will use the application only for this purpose.
9.3 PUFFINSTYLE will respond to an individual’s written request within 30 days unless
this period is extended in accordance with applicable legislation, in which case notice
will be sent to the individual within 30 days regarding the extension, the reasons for it
and the individual’s rights in connection with it. PUFFINSTYLE will assist any individual
who informs it that they need assistance in preparing a request. While the response will
typically be provided at no cost to the individual, depending on the nature of the request
and the amount of information involved, PUFFINSTYLE reserves the right to impose a
cost. In these circumstances, PUFFINSTYLE will inform the individual of the
approximate cost to provide the response and proceed upon payment. The requested
information will be provided or made available in a form that is generally
9.4 PUFFINSTYLE will be as specific as possible in providing an account of third parties
to which it has disclosed personal information about an individual. When it is not
possible to provide a list of the organizations to which it has actually disclosed
information about an individual, PUFFINSTYLE will provide a list of organizations to
which it may have disclosed information about the individual.
9.5 In certain instances, PUFFINSTYLE will not be able to provide the individual access
to his or her personal information. Where permitted, the reasons for denying access will
be provided to the individual. This will be done upon the individual’s request unless
PUFFINSTYLE is required by law to provide such written reasons. Exceptions to the
grant of an access request may include: information that contains references to other
individuals or contains confidential commercial information, where such information
cannot be severed from the record; information protected by solicitor-client privilege;
information properly collected without the knowledge or consent of the individual for
purposes related to investigating a breach of an agreement or a contravention of law;
information generated in the course of a formal dispute resolution process; and as
required or permitted by law.
9.6 When an individual successfully demonstrates the inaccuracy or incompleteness of
personal information, PUFFINSTYLE will amend the information as required. Depending
upon the nature of the information challenged, an amendment may involve the
correction, deletion or addition of information. Where appropriate, the amended
information will be transmitted to third parties having access to the information in
9.7 When a challenge is not resolved to the satisfaction of the individual,
PUFFINSTYLE will record the substance of the unresolved challenge. When
appropriate in PUFFINSTYLE ’s judgment, the unresolved challenge will be transmitted
to third parties having access to the information in question.
PRINCIPLE #10 – CHALLENGING COMPLIANCE
An individual will be able to address a challenge concerning compliance with the above
principles to PUFFINSTYLE’s Privacy Officer.
10.1 PUFFINSTYLE will maintain procedures to receive and respond to complaints or
inquiries about its policies and practices relating to the handling of personal information.
10.2 PUFFINSTYLE will inform individuals who make inquiries or lodge complaints of
the existence of relevant complaint procedures.
seek external advice where appropriate before providing a final response to individual
10.4 PUFFINSTYLE will investigate all complaints. If a complaint is found to be justified,
PUFFINSTYLE will take appropriate measures, including, if necessary, amending its
policies and practices. We will take all necessary steps to protect the information you
share with us, including using appropriate security technology for credit card data used
in electronic commerce transactions.