Website Privacy Policy

The Personal Information Protection and Electronic Documents Act (PIPEDA) establishes rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right to privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. 2328525 Ontario Limited o/a Icon1 Communications (the “Company“) is committed to protecting and respecting the personal information of its customers, employees, business partners, and all other entities it interacts with in accordance with PIPEDA. This policy will provide guidelines to ensure that the Company remains compliant with PIPEDA requirements.

In this Privacy Policy, the terms “we”, “our” and “us” mean the Company.

Effective Date and Scope

This Privacy Policy is effective as of 2018

This Privacy Policy governs our practices with respect to personal information we collect through the following website:


By submitting personal information to the Company and its agents, you agree that the Company may collect, use and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting our Privacy Officer. If you refuse or withdraw your consent, the Company may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide the Company or our service providers with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.  The Company may also collect, use and disclose personal information in accordance with applicable law.

What Personal Information Does the Company Collect?

PIPEDA defines “personal information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this Privacy Policy, personal information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally speaking, personal information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or e-mail address.

Why Does the Company Collect Your Personal Information?

Amongst other reasons, the Company collects, uses and discloses your personal information for the following purposes:

  • to register for services;
  • to perform services;
  • to develop, enhance, market, or otherwise provide the Company’s products and services;
  • to develop and manage the Company’s business and operations;
  • to detect and protect the Company and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with the Company’s policies and contractual obligations;
  • as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
  • for any other purpose to which you consent.

The Company will not collect information indiscriminately and will limit collection of information to that which is reasonable and necessary for the above purposes. We will also collect information as is otherwise authorized by law.

We retain your information for as long as necessary to fulfill the purposes for which we collected the information or as required by law. We maintain a records retention and destruction program to destroy information when it is no longer needed or required.

Online Communications

In order to provide our website visitors with a service or information, visitors may voluntarily submit personal information to the Company for purposes such as asking a question, obtaining information, reviewing or downloading a publication or service. If you are known to the Company as a registered user of an online service, the Company may combine and store personal information about your use of our website and the online information you have provided with certain other online and offline information the Company may have collected.

To Whom does the Company Disclose Your Personal Information?

From time to time, the Company may disclose your personal information to:

  • service providers, including an organization or individual working with the Company to perform functions on its behalf, such as marketing, data processing, document management and office services;
  • an organization or individual retained by the Company to collect debts;
  • a person who, in the reasonable judgment of the Company, is providing or seeking the information as your agent;
  • the Company’s insurers and to regulatory agencies, as required;
  • a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements; or
  • any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

Where Does the Company Store Your Personal Information?

Your personal information is stored in secured locations and on servers controlled by the Company, located either at its offices or at the offices of its service providers.

To help protect the confidentiality of your personal information, the Company employs administrative and technological safeguards appropriate to the sensitivity of your personal information. Where personal information is sent to a third party for processing, the Company requires, through its contracts with the third party, that all personal information is kept secure. The Company operates secure data networks protected by industry standard firewall and password protection systems.

How May You Obtain Access to Your Personal Information?

Upon your written request, subject to certain exceptions, the Company will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. Access requests should be sent to our Privacy Officer, using the contact information below. To the extent available by law, the Company may assert privilege in connection with personal information that the Company has collected, used or disclosed.  In such event, and to the extent permitted by law, the Company will not disclose such personal information, give you access to such information or inform you of the existence, use or disclosure of such personal information, except in accordance with the terms of the applicable law.

How do we use Cookies?

We use “cookies” on this site.

A cookie is a small text file sent from a web server and placed on your computer’s hard drive. A cookie is generally used to enhance your browsing experience. You can choose to set your browser to detect and reject cookies, to accept cookies from all sites, or to prompt you whenever a site wants to send you a cookie. Check your browser’s “Help” files to learn how to do this. If you choose to refuse cookies, you may not be able to access some of the interactive features on our website.

Cookies used by the Company do not give us access to anything on your hard drive and cannot do anything to your computer. The Company uses two types of cookies: session cookies (temporary) or persistent cookies (longer–term continuing use).

Session cookies may be used to support on-line feedback/discussion, forms and registration and ‘e-commerce/shopping cart’ transactions. They are used only during your online session and expire when you close your browser. Without session cookies, moving around the website could be much slower.

Persistent cookies are different from session cookies because they are stored on your computer’s hard drive for some length of time. They are usually used if you want us to remember information about your web preferences and passwords for automatic log-in purposes.


The Company will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete. In some cases, we rely on you to ensure that certain information, such as your address or telephone number, is current, complete and accurate.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

What is Aggregate Information

“Aggregate information” is standard web server/visitor traffic information, commonly referred to as ‘aggregate information’, regarding overall website traffic patterns. Web servers normally collect this type of basic information as part of their web log processes. This aggregate information does not identify you and thus does not constitute personal information.

In addition to information provided by our visitors we use the normal Internet tracking tools associated with standard Internet protocols and web–based systems. This system information is typically stored in log files and the information is used for aggregate reporting. Aggregate reporting includes total number of visitors, most visited sections, peak traffic times, etc. Log files are simply transaction records web servers maintain. Those logs are used for recording information, such as:

  • service provider IP addresses;
  • browser versions;
  • referring websites;
  • search terms used;
  • average number of pages requested;
  • average duration of visit;
  • total visitor traffic.

We use aggregate information gathered from your visit to better design our website. This information supplies us with a broad picture of how people use our website in order to help the management of our systems and to better serve our audience.

Law Enforcement Requests

We will disclose personal information without your knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of your personal information.

Storage Outside of Canada

Your personal information may be used or stored by us or our service providers outside of Canada. We require that our service providers safeguard your personal information. However, if your personal information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.

Links to Third-Party Websites and Social Network Plug-Ins

You may be able to access third-party websites through links available on our websites. You may also connect to social networks such as Facebook and Twitter. These links are provided for your convenience. We do not have any control over those third-party websites and we do not provide any guarantee that the privacy practices of the hosts of those websites meet our standards. Your use of such third-party websites is at your own risk and will be governed by the privacy policies of those websites and not by this Privacy Policy. Do not transmit personal information using those websites without reading the privacy policies governing those websites.

You may create links between our website and social networking sites. If you do so, we may be able to publish updates about our products and services to your social network account through the links that you establish. You may terminate those links at any time by modifying your social network account.

You may change the way social networking sites and our sites interact by modifying your privacy settings in your social networking account. You can also log-out of your social networking account before visiting our website. For more information, please refer to your social networking site’s privacy policy, which governs your use of these social plug-in features.

Changes to the Privacy Policy

The Company reserves the right to modify or supplement this Privacy Policy at any time. If the Company makes a change to this Privacy Policy, the Company will post such changes on its website and make such revised policy and changes available to you upon your request to the Company’s Privacy Officer. However, the Company will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

Further Information, Disclosure Requests, and Changes

The Company has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For information on the Company’s privacy practices, please contact the Company’s Privacy Officer at: