Privacy Policy

Introduction

1085459 Ontario Ltd. operating as Kingston Online Services ("KOS," "we," "us," or "our") is committed to protecting the privacy and confidentiality of the personal information of our customers, employees, and other stakeholders. This Privacy Policy describes how we collect, use, disclose, and safeguard personal information in the course of providing our services.

This policy is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Canadian Radio-television and Telecommunications Commission (CRTC) regulations, and all other applicable privacy legislation. KOS adheres to the ten privacy principles established by the Canadian Standards Association (CSA) Model Privacy Code, which form the basis of PIPEDA.

By using KOS services, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with our practices, please contact our Privacy Officer to discuss your concerns before using our services.

Principle 1: Accountability

KOS is responsible for the personal information under its control. We have designated a Privacy Officer who is accountable for our compliance with this Privacy Policy and applicable legislation.

Our Privacy Officer oversees all aspects of our privacy practices, including:

• Implementing policies and procedures to protect personal information
• Ensuring staff are trained on privacy obligations and best practices
• Responding to inquiries and complaints about our privacy practices
• Ensuring compliance with PIPEDA and CRTC privacy requirements

When KOS shares personal information with third-party service providers (for example, billing processors or network infrastructure partners), we require those parties to provide a comparable level of protection through contractual agreements. KOS remains responsible for information that has been transferred to a third party for processing.

Principle 2: Identifying Purposes

KOS identifies the purposes for which personal information is collected at or before the time of collection. We collect personal information for the following primary purposes:

• Service delivery: To establish, maintain, and provide internet, email, VoIP, hosting, and related services
• Billing and account management: To process payments, manage accounts, and collect outstanding debts
• Customer support: To respond to inquiries, troubleshoot service issues, and provide technical assistance
• Network management: To monitor and manage our network for security, performance, and capacity planning
• Legal and regulatory compliance: To comply with lawful orders, regulatory requirements, and legal obligations
• Emergency services: To provide accurate address information for E911 services
• Service improvement: To analyze usage patterns and improve our services and customer experience
• Communications: To send service notifications, billing statements, and important updates about your account

If KOS identifies a new purpose for collecting personal information, we will obtain your consent before using existing information for the new purpose, unless the new use is required or permitted by law.

Principle 3: Consent

KOS obtains meaningful consent for the collection, use, and disclosure of personal information, except where permitted or required by law to act without consent. The form of consent (express or implied) may vary depending on the sensitivity of the information and the reasonable expectations of the customer.

By subscribing to KOS services, you consent to our collection and use of your personal information as described in this policy. You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer. Please note that withdrawing consent may affect our ability to provide certain services.

In certain circumstances, KOS may collect, use, or disclose personal information without consent, as permitted by PIPEDA, including:

• When required by a court order, subpoena, or warrant
• When necessary to investigate a breach of an agreement or a contravention of Canadian law
• When the information is publicly available as defined by regulation
• When disclosure is made to a lawyer representing KOS
• For the purpose of collecting a debt owed by the individual

Principle 4: Limiting Collection

KOS limits the collection of personal information to that which is necessary for the identified purposes. We collect information by fair and lawful means. The types of personal information we typically collect include:

• Name, mailing address, and service address
• Telephone number(s) and email address
• Payment information (credit card number, banking information for pre-authorized debit)
• Service usage data (bandwidth consumption, connection logs)
• Technical information (IP addresses, equipment identifiers)
• E911 registered address for VoIP customers
• Communications with our support team

We do not collect personal information indiscriminately and do not monitor the content of your communications unless required by law or to maintain network security as described in our Acceptable Use Policy.

Principle 5: Limiting Use, Disclosure & Retention

KOS does not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law. We do not sell customer personal information to third parties.

KOS may disclose your personal information to:

• Third-party service providers who assist in delivering our services (subject to contractual privacy protections)
• Law enforcement agencies in response to a valid warrant, court order, or other lawful demand
• Emergency services when necessary for public safety or in life-threatening situations
• Regulatory bodies such as the CRTC or the Office of the Privacy Commissioner of Canada
• Collection agencies for the purpose of recovering outstanding debts

Personal information is retained only as long as necessary to fulfill the purposes for which it was collected, to comply with legal retention requirements, or to resolve disputes. When personal information is no longer needed, it is securely destroyed or anonymized.

Principle 6: Accuracy

KOS takes reasonable steps to ensure that personal information is accurate, complete, and up to date for the purposes for which it is used. We rely on you to provide accurate information and to notify us of any changes.

It is particularly important that your service address for E911 purposes is accurate at all times. Inaccurate address information could result in emergency responders being dispatched to the wrong location.

You may update your personal information by contacting our office by phone, email, or by submitting a support ticket. KOS will make corrections promptly upon receiving a verified request.

Principle 7: Security Safeguards

KOS protects personal information with security safeguards appropriate to the sensitivity of the information. Our safeguards include:

• Physical measures: Restricted access to our offices and data facilities, locked storage for physical records
• Technical measures: Firewalls, encryption, intrusion detection systems, access controls, and secure network architecture
• Organizational measures: Employee privacy training, access limited to authorized personnel on a need-to-know basis, confidentiality agreements

While KOS implements industry-standard security measures, no method of transmission over the internet or method of electronic storage is completely secure. KOS cannot guarantee absolute security of your information but is committed to using commercially reasonable efforts to protect it.

Principle 8: Openness

KOS is open about its policies and practices regarding the management of personal information. This Privacy Policy is available on our website and may be obtained in print by contacting our office.

If you have questions about our privacy practices or wish to obtain more information, please contact our Privacy Officer using the contact information provided at the end of this policy.

Principle 9: Customer Access

Upon written request, KOS will inform you of the existence, use, and disclosure of your personal information and provide you with access to that information. You have the right to:

• Request a summary of the personal information we hold about you
• Challenge the accuracy and completeness of your information and have it amended where appropriate
• Know how your information has been used or disclosed

Access requests must be submitted in writing to our Privacy Officer. KOS will respond to access requests within thirty (30) days. In some cases, KOS may need to extend this period, in which case you will be notified of the extension and the reason for it.

KOS may refuse access to personal information in certain limited circumstances permitted by PIPEDA, such as when the information contains references to other individuals, when disclosure could reveal confidential commercial information, or when the information was generated in the course of a formal dispute resolution process.

Principle 10: Breach Notification

In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm to individuals, KOS will:

• Report the breach to the Office of the Privacy Commissioner of Canada as soon as feasible
• Notify affected individuals as soon as feasible, informing them of the breach, the information involved, the steps KOS has taken to reduce the risk of harm, and actions the individual can take to protect themselves
• Notify any other organization or government institution that may be able to reduce the risk of harm
• Maintain records of all breaches of security safeguards for a minimum of twenty-four (24) months

KOS assesses the risk of harm from a breach by considering the sensitivity of the information involved, the probability that the information has been or will be misused, and any other relevant factors.

Challenging Compliance

You have the right to challenge KOS's compliance with this Privacy Policy by contacting our Privacy Officer. All complaints will be investigated promptly and thoroughly.

If our Privacy Officer is unable to resolve your concern to your satisfaction, you may file a complaint with the Office of the Privacy Commissioner of Canada:

• Website: www.priv.gc.ca
• Toll-free: 1-800-282-1376

You may also contact the Canadian Radio-television and Telecommunications Commission (CRTC) for complaints related to telecommunications privacy matters.

Website Privacy Policy

This section describes how KOS handles information collected through our website at kos.net and related web properties.

Security of Data Transmission

KOS takes reasonable precautions to ensure that the data on our website is secure. However, due to the inherent nature of the internet, we cannot guarantee that communications between you and our servers will be completely free from unauthorized access by third parties. KOS shall not be liable for any loss or damage arising from any such unauthorized access.

Encryption

Pages on our website that collect or display sensitive information use HTTPS encryption (TLS/SSL) to protect data in transit. We recommend that you always verify the presence of HTTPS in your browser address bar when submitting personal information.

Technical Logging

Like most web servers, the KOS web server automatically logs certain technical information for each visit, including your IP address, the pages visited, the referring URL, browser type, and the date and time of access. This information is used for system administration, troubleshooting, and aggregate statistical analysis. It is not used to track individual visitors or to identify individuals.

Cookies

The KOS website may use cookies — small text files stored on your device — to improve your browsing experience, remember preferences, and gather aggregate usage data. Cookies used by KOS do not contain personal information and are not used to track you across other websites.

You can configure your browser to refuse cookies or to alert you when cookies are being sent. Please note that some features of our website may not function properly if cookies are disabled.

No Tracking to Individuals

KOS does not use website analytics or logging data to identify, track, or profile individual visitors. Aggregate data may be used to understand general usage patterns and improve our website. We do not sell, rent, or share website visitor data with third parties for marketing purposes.

Right to Examine Materials

You have the right to request access to any personal information that KOS has collected about you through our website. To make such a request, please contact our Privacy Officer using the contact information below.

Contact the Privacy Officer

If you have questions, concerns, or complaints about this Privacy Policy, our privacy practices, or if you wish to submit an access request, please contact our Privacy Officer:

This Privacy Policy was last updated on January 1, 2025.