This policy is applicable to TNEXT Communication Inc. This document was last updated on November 12, 2021. We value the security and integrity of our customers and we take all required measures to protect the privacy of our customers whilst providing a high level of service to our customers.

TNEXT Communication Inc. practices the privacy policy in accordance with all Federal and Provincial laws and regulations. We comply with Personal Information Protection and Electronic Documents Act and where applicable with the privacy rules established by the Canadian Radio-Television and Telecommunication Commission.

This is the document of Privacy Policy of TNEXT Communication Inc. Please refer to our Privacy FAQ for more information.

TNEXT Communication Inc. provides a broad range of telecommunication services to customers, including Internet, local and long distance calling and e-fax services in Canada. TNEXT Communication Inc. (as defined under section “Definitions” below) is committed to maintain the privacy, confidentiality, security and accuracy of customers’ personal information.
TNEXT Communication Inc. Privacy Policy ("Privacy Policy") is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided to TNEXT Communication Inc. by it’s customers. The objective of the Privacy Policy is to be responsible and transparent of best practices and the management of personal information in accordance with the Canadian Standards Association (CSA) Model Code and Federal Privacy Legislation depicted in the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5, as amended (PIPEDA).

SCOPE & APPLICATION

There are ten principles that forms the basis of the Privacy Policy. Each principle must be read in conjunction with the accompanying commentary which has been tailored in accordance with PIPEDA to reflect privacy issues specific to the TNEXT Communication Inc. The Privacy Policy applies to the management of personal information in any form (oral, electronic or written). The Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by TNEXT Communication Inc.:

1. Information that is publicly available; OR

2. Name, title, address or telephone number of a customer

The ten principles that form the basis of the Privacy Policy are interrelated and TNEXT Communication Inc. shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by PIPEDA, the commentary in the Privacy Policy has been tailored to reflect personal information issues specific to TNEXT Communication Inc. The application of the Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements, or the order or determination of any court or other lawful authority, including any applicable regulations, orders or determinations of the Canadian Radio Television and Telecommunications Commission.

DEFINITIONS

Collection: The act of gathering, acquiring, recording or otherwise obtaining any personal information from any source, including third party, by any means.
Consent: Voluntarily agreeing to the collection, use and disclosure of personal information for a defined purpose. Consent can be either express or implied and can be provided directly by the individual or by an authorized Representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of TNEXT Communication Inc. Implied consent is a consent that can reasonably be inferred from an individual's action or inaction.
Customer: An individual who uses, or applies to use, TNEXT Communication Inc.’s products or services or otherwise provides personal information to TNEXT Communication Inc. in the course of TNEXT Communication Inc.’s commercial activities.
Disclosure: The act of making personal information available to a third party.
Personal information: Any information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual. For a customer, such information includes, but is not limited to, a customer's credit information, billing records, service and equipment information, and any recorded complaints.
Third party: An individual other than the customer, their Agent or an Organization other than the TNEXT Communication Inc.
Use: The treatment, handling, and management of personal information by the TNEXT Communication Inc.

PRIVACY PRINCIPLES

Accountability: TNEXT Communication is responsible for all personal information under their control and shall designate one or more persons who are accountable for compliance with the following principles.
1. Responsibility of ensuring compliance with the provisions of the Privacy Policy rests with the Senior Management of TNEXT Communication Inc., which shall designate one or more persons to be accountable for compliance with the Privacy Policy. Other individuals within TNEXT Communication Inc. may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.
2. TNEXT Communication Inc. shall make known, upon request, the title of the person(s) designated to oversee TNEXT Communication Inc.’s compliance in accordance with the Privacy Policy. TNEXT Communication Inc. has designated Data Protection Team to oversee compliance with the Privacy Policy. The Data Protection Team could be contacted at:

Data Protection Team
TNEXT Communication Inc.
4 Finley Road,
Brampton
ON, L6T 1A9

Tel: 416 477 8181
Fax: 416 477 8194
Email: info@tnext.ca

3. TNEXT Communication Inc. is responsible for all personal information in their possession or control, including information that has been transferred to a third party for processing. TNEXT Communication Inc. shall use appropriate means to provide a comparable level of protection while information is being processed by a third party.
4. TNEXT Communication Inc. has implemented policies and procedures to comply with Privacy Policy, including:

(a) Implementing procedures to protect personal information and oversee compliance accordance with the Privacy Policy;

(b) Establishing procedures to receive and respond to inquiries or complaints;

(c) Training and communicating to staff about the TNEXT Communication Inc.’s policies and practices;

(d) Developing public information to explain TNEXT Communication Inc.’s policies and practices.

Identifying Purposes for Collection of Personal Information
TNEXT Communication Inc. shall identify the purposes for which personal information is collected at the time of collection of information or prior.
1. TNEXT Communication collects personal information for one or more of the following purposes:

(a) To establish and maintain responsible commercial relationship with customers and to provide ongoing service(s);

(b) To provide a positive customer experience and deliver bill for, and collect payment for products and services;

(c) To understand customer requirements;

(d) To manage business operations, develop, enhance, market or provide product(s) and service(s);

(e) To meet legal and regulatory requirements;

2. TNEXT Communication Inc. shall specify orally, electronically or in writing the identified purposes to the customer at or before the time personal information is collected. Upon request, person(s) collecting personal information shall explain these identified purposes or refer the individual to a designated person within the TNEXT Communication Inc. who shall explain the purpose(s).
3. Unless required by law, TNEXT Communication Inc. shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent from customer.
4. As members of the public browse the website www.tnext.ca or other websites, advertising cookies will be placed on the users’ computers so that TNEXT Communication can understand consumer interests. “Cookies” are small information packets that a website creates which are stored on the hard drive of a user’s computer by the user’s browser software. TNEXT Communication Inc. use cookies to track and collect information relating to use of the site by public.
Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer is required for the collection, use or disclosure of personal information, except where inappropriate.
1. In certain circumstances personal information can be collected, used or disclosed without the knowledge or consent of the individual. For example, TNEXT Communication Inc. may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.
TNEXT Communication Inc. may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a Federal or Provincial law. The TNEXT Communication Inc. may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
TNEXT Communication Inc. may disclose personal information without knowledge or consent to a Lawyer representing TNEXT Communication Inc., to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
2. In obtaining consent, TNEXT Communication Inc. shall use reasonable efforts to ensure that a customer is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer.
3. Generally, TNEXT Communication Inc. shall seek consent to use and disclose personal information at the same time they collect the information. However, TNEXT Communication Inc. may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.
4. TNEXT Communication Inc. will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes. For example, TNEXT Communication Inc. may collect customers’ IP address, MAC address, and router settings from routers connected to TNEXT Communication Inc.’s network for the purpose of providing ongoing service(s). TNEXT Communication Inc. uses this data to routinely monitor and manage end-users’ connectivity and performance on TNEXT Communication Inc.’s network.
5. In determining the appropriate form of consent, the TNEXT Communication Inc. shall take into account the sensitivity of the personal information and the reasonable expectations of customers.
6. In general, the use of products and services by a customer constitutes implied consent for TNEXT Communication Inc. to collect, use and disclose personal information for all identified purposes.
7. A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers may contact TNEXT Communication Inc. for more information regarding the implications of withdrawing consent.
Limiting Collection of Personal Information
TNEXT Communication Inc. shall limit the collection of personal information to that which is necessary for the purposes identified and collect personal information by fair and lawful means.

1. TNEXT Communication Inc. collect personal information primarily from customers.

2. TNEXT Communication Inc. may also collect personal information from other sources including credit bureaus or other third parties that represent that they have the right to disclose the information.

Limitations on Use, Disclosure and Retention of Personal Information
TNEXT Communication Inc. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. TNEXT Communication Inc. shall retain personal information only as long as necessary for the fulfillment of those purposes.
1. Personal information is not shared with anyone outside TNEXT Communication Inc. whereas could be avoided, however in circumstances when we have to do so.

(a) Limitation on information disclosure to third parties: With respect to third party requests for information, where we are required to disclose personal information we limit it to the information required in the circumstances, provide it only for the purpose stipulated, and make it subject to strict terms of confidentiality. When a court orders us to provide personal information, we tell you about it unless we have been ordered by law not to, and we follow up regularly to question whether non-disclosure orders ought to remain in force.

(b) We work to keep as much traffic within Canada as we can: With respect to Internet traffic, we place an emphasis on preferring in-country interconnection for domestic traffic. We peer openly with peers in Canada whose Autonomous Systems are mostly located within Canada and who provide geographically diverse peering within Canada. We peer conditionally with other peers. We maintain publicly-available information on our traffic routing at PeeringDB (AS5645).

2. In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual.
3. In addition, TNEXT Communication Inc. may disclose a customer's personal information to:

(a) Another Telecommunications Services Provider for the efficient and effective provision of Telecommunications Services;

(b) An entity involved in supplying the customer with communications or communications directory related services;

(c) Another entity for the development, enhancement, marketing or provision of any of the products or services of TNEXT Communication Inc.;

(d) An agent retained by TNEXT Communication Inc. related with the collection of the customer's account;

(e) Credit grantors and reporting agencies;

(f) A person who, in the reasonable judgment of TNEXT Communication Inc. is seeking the information as an agent of the customer; and

(g) A third party or parties, where the customer consents to such disclosure or disclosure is required by law.

4. TNEXT Communication Inc. shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer, TNEXT Communication Inc. shall retain, for a period of time that is reasonably sufficient to allow for access by the customer, either the actual information or the rationale for making the decision.
5. TNEXT Communication Inc. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
1. Personal information used by TNEXT Communication Inc. shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer.
2. TNEXT Communication Inc. shall update personal information about customers as and when necessary to fulfill the identified purposes or upon notification by the individual.
Security Safeguards
TNEXT Communication Inc. shall protect personal information by security safeguards appropriate to the sensitivity of the information.
1. TNEXT Communication Inc. shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. TNEXT Communication Inc. shall protect the information regardless of the format in which it is held.
2. TNEXT Communication Inc. shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
Transparency Concerning Policies and Practices
TNEXT Communication Inc. shall make readily available to on specific information about their policies and practices relating to the management of personal information.
1. TNEXT Communication Inc. shall make information about their policies and practices easy to understand, including:

(a) The title and address of the person(s) accountable for TNEXT Communication Inc.’s compliance with the Privacy Policy and to whom inquiries or complaints can be forwarded;

(b) The means of gaining access to personal information held by TNEXT Communication Inc.; and

(c) A description of the type of personal information held by TNEXT Communication Inc., including a general account of its use.

2. TNEXT Communication Inc. shall make available information to help customers about the use of their personal information and the privacy-enhancing services available from TNEXT Communication Inc.
Customer Access to Personal Information
TNEXT Communication Inc. shall inform a customer of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.
1. Upon request, the TNEXT Communication Inc. shall afford to a customer a reasonable opportunity to review the personal information in the individual's file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.
2. In certain situations, TNEXT Communication Inc. may not be able to provide access to all of the personal information that they hold about a customer. For example, TNEXT Communication Inc. may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, TNEXT Communication Inc. may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by Solicitor-Client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, TNEXT Communication Inc. shall provide the reasons for denying access upon request.
3. Upon request, TNEXT Communication Inc. shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, TNEXT Communication Inc. shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
4. In order to safeguard personal information, a customer may be required to provide sufficient identification information to permit TNEXT Communication Inc. to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose.
5. TNEXT Communication Inc. shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, TNEXT Communication Inc. shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
6. A customer can obtain information or seek access to his or her individual file by contacting a designated Representative on 416 477 8181 or by sending an email the request to info@tnext.ca.
Challenging Compliance
A customer shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for compliance of TNEXT Communication Inc.’s Privacy Policy.
1. TNEXT Communication Inc. shall maintain procedures for addressing and responding to all inquiries or complaints from their customers about handling of personal information.
2. TNEXT Communication Inc. shall inform their customers about the existence of these procedures as well as the availability of complaint procedures.
3. The person(s) accountable for compliance with the Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.
4. TNEXT Communication Inc. shall investigate all complaints concerning compliance with the Privacy Policy. If a complaint is found to be justified, TNEXT Communication Inc. shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer shall be informed of the outcome of the investigation regarding his or her complaint. For inquiries, complaints or more information please contact:

Data Protection Team
TNEXT Communication Inc.,
4 Finley Road, Brampton
ON, L6T 1A9
Fax: 4164778194
Email: info@tnext.ca

TNEXT Communication Inc. will continue to review the Privacy Policy on a regular basis and at least every five years to ensure it is relevant and current.
ADDITIONAL INFORMATION
Personal Information Protection and Electronic Document Act: http://www.priv.gc.ca Commissioner for Complaints for Telecommunications Services (CCTS): www.ccts-cprst.ca
Toll-free at 1-888-221-1687.