Privacy Policy

Starpy Communications respects the privacy of our valued clients and we are committed to keeping your personal information accurate, confidential, secure and private. We have adopted the following privacy policy to ensure that Starpy continues to meet its commitment to privacy.

In the course of providing these services, Starpy may consensually collect certain personal information about our clients.

"Personal Information" means information about an identifiable individual client. This may include without limitation, the individual's name, address, age, gender, personal preferences, billing information and other information about his or her interests in the type of services we provide.

The Starpy Privacy Policy is based on, and complies with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), which includes the Ten Privacy Principles outlined in the Canadian Standards Association Model Code for the Protection of Personal Privacy. For more information about this legislation, please visit the official web site of the Privacy Commission of Canada at http://www.privcom.gc.ca/.

This privacy policy describes the ten principles that Starpy follows to ensure that we protect our clients' personal information when we collect, use or disclose it in the course of carrying on commercial activities. All of our employees who have access to personal information must adhere to the Starpy Privacy Policy and related procedures.

This introduction and the following sections, read as a whole, comprise the Starpy Privacy Policy:

* The Ten Principles of Privacy
* Application of the Ten Privacy Principles
* The Kind Of Information We Collect
* How We Use Your Information
* When We May Disclose Your Personal Information
* Who We May Share Your Information With
* How We Safeguard Your Information
* Web Site Security
* Accessing and Amending Your Personal Information
* Opting Out
* Questions, Concerns and Complaints

1. The Ten Principles of Privacy
The following ten principles govern our actions as they relate to the use of our clients' personal information:

Principle 1 - Accountability
Principle 2 - Identifying Purposes
Principle 3 - Consent
Principle 4 - Limiting Collection
Principle 5 - Limiting Use, Disclosure and Retention
Principle 6 - Accuracy
Principle 7 - Safeguarding Personal Information
Principle 8 - Openness
Principle 9 - Client Access
Principle 10 - Addressing Client Complaints

Starpy is accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees.

Principle 2 - Identifying Purposes
Starpy will inform you of the purposes for which it is collecting any personal information, unless otherwise apparent, before or at the time the information is collected.

Principle 3 - Consent
Starpy will obtain consent from our clients before or when we collect, use or disclose their personal information.

A client's consent can be express, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. Starpy, however, may collect, use or disclose personal information without the client's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.

Principle 4 - Limiting Collection
The information collected from the client will be limited to those details necessary for the purposes identified to the client. Information will be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the amount of time needed to fulfill the purpose for which it was collected. In certain exceptional circumstances, Starpy may have a legal duty or right to disclose personal information without our clients' knowledge or consent with respect to matters that concern the company's or the public's interest.

We have a zero tolerance spamming policy. Services may be terminated for violators

Principle 6 - Accuracy

Starpy will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Clients may have this information amended where it is found to be inaccurate or incomplete.

Principle 7 - Safeguarding Personal Information
Personal information is safeguarded using measures appropriate to the sensitivity of the information. We have a zero tolerance spamming policy. Services may be terminated for any violations.

Principle 8 - Openness
Starpy will make information available to our clients about the policies and procedures Starpy uses to manage personal information. Clients have access to this information through our web site, or through alternate means if requested.

Principle 9 - Client Access
Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. Starpy will respond to such requests as efficiently as possible. If Starpy is prohibited from providing such access we will explain the reasons for the lack of access, except where prohibited by law.

Principle 10 - Addressing Client Complaints and Suggestions
Starpy has policies and procedures to receive, investigate and respond to clients' complaints and questions. Clients may contact Starpy to express any concerns or to request access to their personal information. The contact information for this individual is provided below.

2. Application of the Ten Privacy Principles

2.1 The Kind Of Information We Collect
Starpy gathers and uses personal information in order to provide you with the services you have requested or to offer additional services in which you may be interested. Providing us with your personal information is your choice, however, we may not be able to provide you with certain services if you do not provide us with certain information.

The nature of your request will determine the kind of personal information we might ask for.

Information that is typically required to provide you with our services includes:
Name
Address, email address
Phone number(s)
Relevant financial information.
If you are applying for credit you will be asked for specific financial information. Starpy may keep a file with your contact history to be used for inquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you.

If you visit Starpy web sites, we do not collect personally identifiable information about you unless you provide it. All information that you do provide us with is securely maintained and kept strictly confidential.

2.2 How We Use Your Information
At Starpy we use personal information for three general purposes:

  1. To communicate with you in order to provide you with our services or information.
  2. To better understand how we can serve our entire population.
  3. To make a credit assessment if you are applying for credit.

We will only use personal information for the purpose that we have disclosed to you. If we want to use your information for a different purpose, we will notify you and ask for your consent first.

2.3 When We May Disclose Your Personal Information
Starpy is obliged to keep your personal information confidential except under the following circumstances:

* When Authorized by You
* When Required by Law
* When Permitted by Law

(i)When Authorized by You
Many of the services offered by Starpy require us to obtain personal information about you in order to perform the services we have been engaged to provide. We will use this information to tailor products to meet your needs and objectives. We will always obtain consent from you first, and we will never use the information for purposes other than those we have told you about.

(ii) When Required by Law
The type of information we are legally required to disclose usually relates to government reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain purposes other than those we have told you about.

(ii) When Required by Law
The type of information we are legally required to disclose usually relates to government reporting requirements. However, in some cases, such as under a court order, we may be required to disclose certain information to persons specified in the court order. We will only provide the specific information requested and only upon being satisfied that the authorities have legitimate grounds to request the information.

(iii) When Permitted by Law
The legislation has provided certain situations where Starpy is legally permitted to disclose personal information without your consent. Examples include situations involving the collection of debt in arrears, or suspicion of illegal activities.

2.4 Who We May Share Your Information With
(i) Starpy Employees
In the course of daily operations, access to sensitive personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Starpy employees are required to follow all applicable laws and regulations, including this privacy policy.

Unauthorized use or disclosure of confidential client information by a Starpy employee is prohibited and may result in disciplinary measures.

(ii) Starpy affiliates and partners
In order to better meet your needs, we may share some of your personal information with our affiliates and partners. We will only do this with your express consent and you may withdraw this consent at any time. The procedure for withdrawing consent is outlined below under the section "2.8 Opting Out". Starpy Affiliates and partners are companies that are authorized and contracted parties involved in the provisioning of our services and who will accept our commitments under this privacy policy.

2.5 How We Safeguard Your Information
Starpy has appropriate controls in place to maintain the security of our information and information systems. Client files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees only.

If you telephone a Starpy employee to speak about your file, you may be asked for some personally identifying information. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

2.6 Web Site Security
Our main contact and business is conducted through our web site. This critical capability of the company has the most advanced levels of security and access controls available, both electronically and physically. Our procedures and techniques are reviewed and updated regularly under the responsibility of the Chief Technology Officer.

Starpy does not provide services to underage children. We will not knowingly collect personally identifiable information from children under the age of 18 years nor do we knowingly link to web sites that do.

2.7 Accessing and Amending Your Personal Information
As a client, you have the right to access the personal information we keep in your file and you have the right to verify or amend the information if it is shown to be inaccurate. If you would like to view the personal information held in your file, please make a written request through the contact procedure on our web site. We will respond to your request as efficiently as possible.

To make a change, please make a similar request.

2.8 Opting Out
In order to provide you with our services, Starpy will, with your consent, share your mandatory personal information with other Affiliates and partners. You are not obliged to provide any or all optional information which is clearly indicated where and when we collect such information.

3. Questions, Concerns and Complaints
If you have any questions, concerns or complaints about your personal information, or about the Starpy Privacy Policy, please contact us through our contact procedure on our web site.