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Privacy Policy

TOUCH Communications Inc. is committed to protecting your privacy and the confidentiality of your Personal Information.

Personal Information is information about an identifiable individual.

Privacy Legislation

Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information, incorporated by reference into PIPEDA. These obligations extend to TOUCH Communications and are integrated into the Privacy Policy herein.

What is Personal Information?

Personal Information is defined in PIPEDA as information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, it does not include the information that one expects to find on a business card or information that is available in public records.

Personal Information includes, but is not limited to, a Client’s name, mailing address, telephone number, e-mail address, facsimile number, age, gender, marital status, health status, financial status, credit card information, credit history, and information about your organization, your customers, product and service subscriptions and usage. (the “Personal Information”).

In the delivery of the Services, hereunder it is acknowledged that the TOUCH Communications’ Personnel are acting as agents of St. Joseph’s Health Care (“SJHC”) for the purposes of the Personal Health Information Protection Act, 2004, and shall comply with this legislation.

TOUCH Communication shall ensure its Personnel;

  • (a) strictly comply with all applicable privacy and confidentiality legislation and with applicable SJHC policies;
  • (b) at all times safeguard the confidentiality of Personal Information, Client Records or Client information in their possession in accordance with applicable law;
  • (c) collect, use or disclose Personal Information only as authorized by SJHC;
  • (d) do not reproduce, copy destroy, dispose of or duplicate any Personal Health Information, Client Records or Client Information except as required or permitted by law.

Identified Purposes

TOUCH Communications collects Personal Information for the following purposes:

  • (a) To establish and maintain commercial relations with you and to provide you with on-going service;
  • (b) To analyze your needs and to recommend particular products and services to meet those needs;
  • (c) To manage and develop TOUCH Communications’ business and operations, including personnel and employment matters; and
  • (d) To meet legal and regulatory requirements.

Your Personal Information will not be used for any other purposes without your consent. If TOUCH Communications requires Personal Information for any other purpose, you will be notified of that new purpose, and subject to your consent, that new purpose will become an Identified Purpose.

TOUCH Communications will retain Personal Information only as long as is necessary for the fulfillment of the Identified Purposes. CONSENT

Your knowledge and consent of TOUCH Communications’ collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:

  • (a) Your voluntary provision of Personal Information directly to a service representative (including information previously provided to TOUCH Communications Inc.);
  • (b) Your express consent or acknowledgement contained within a written, verbal or electronic application process; and
  • (c) Your receipt of this Privacy Policy, until you notify TOUCH Communications of a withdrawal of this consent.

Other Parties with whom TOUCH Communications may share Personal Information

Unless otherwise advised, TOUCH Communication will not sell or share Personal Information. However, TOUCH Communication reserves the right to disclose Personal Information, including e-mail addresses, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by law. Except as provided in the Electronic Privacy Policy, Personal Information will not otherwise be shared without a User’s permission.

TOUCH Communications Inc. takes all of the necessary precautions to ensure the safeguarding of your information, whether it is stored electronically or in paper format. In all cases, information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required. Our employees sign an agreement that states that they will keep our customers information confidential.

Accuracy of and access to your Personal Information

Communications Inc. is committed to the accuracy of your Personal Information for as long as it is being used for the Identified Purposes. We encourage you to notify us of inaccuracies or corrections to your information.


TOUCH Communication employs physical, administrative, and technological security safeguards appropriate to the sensitivity of the information. TOUCH Communication will take all reasonable steps to protect Personal Information as it is transmitted from a Client. TOUCH Communication will also protect Personal Information from unauthorized access, disclosure, alteration or destruction. TOUCH Communication ensures that all affiliates and other third parties that are retained to perform services on TOUCH Communication’s behalf and are provided with Personal Information are contractually required to observe the Electronic Privacy Policy. It is a Client’s personal responsibility to secure a Client’s own copies of any logins, passwords and related access codes used on or for the Web Site.


If you have questions or concerns about your privacy, you can contact:

TOUCH Communications Inc.
183 James Street South
Hamilton, Ontario
L8P 3A8