Introduction

Inherent throughout, The Data Group of Companies “ corporate culture is our commitment to managing enforcing and practicing our privacy policy. We respect the privacy of individuals, clients, suppliers, customers and business partners who might collect, use or disclose personal information. Our Privacy Policy provides you with all of the safeguards set forth in (PIPEDA) the Canadian federal Personal Information Protection and Electronic Documents Act, on how “Data” manages your personal information with great care as reflected throughout our Privacy Policy. It also applies to the management of personal information in any form whether oral, electronic or written. The Data Group of Companies is not engaged in either buying or selling of personal information for use in marketing or solicitation. The Privacy Policy does not apply to information that is protected by The Data Group of Companies other policies and practices or through contractual arrangements, unless specifically provided in such contractual arrangements.

CONSENT

By submitting personal information to The Data Group of Companies or its service providers and agents, you agree that “Data” and its service providers and agents may collect, use and disclose such personal information in accordance with this privacy policy and as permitted or required by privacy laws. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting the Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information, which may be of value to you. Each third party partner agrees to meet our standards of privacy, confidentiality and security. If you provide “Data” or its service providers and agents 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. All employees and third party staff who in any way handle or manage Personal Information have acknowledged and agreed to adhere to our Privacy Code and the procedures that support that code.

The Privacy Principals The Data Group of Companies

Our Privacy Management Plan includes guidelines on the collection, storage and retention of personal Information as follows:

1. Accountability: “Data” is responsible for personal information under its control and as a result has designated an individual, Genevieve Goldie Pagnotta as Chief Privacy Officer, the person who is accountable for The Data Group of Companies compliance with the ten principles

3. Identifying Purposes: In general, “Data” collects, uses and discloses personal information about you in order to provide our customers, with document management forms, development and processing services. More specifically, “Data” collects, uses and discloses your personal information for the following purposes:

• To establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual and legal obligations;
• To develop and manage our business and operations. This may include the sharing of personal information by and between “Data” personnel and affiliated companies, and with third party service providers and agents, for such purposes;
• To detect and protect “Data” and other third parties to audit compliance with “Data” policies and contractual and legal obligations;
• To distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers;
• Provide products and services of third parties with whom DBF has a commercial relationship; as permitted by, and to comply with, any legal or regulatory requirements or provisions; and for any purpose to which you consent. “Data” will collect, use and disclose only that personal information necessary for the valid business purposes that have been identified.

3. Consent: The knowledge and consent of the individual is required for the collection, use, or disclosure of personal information, except as permitted by Privacy Laws. Pursuant to this Privacy Policy, you acknowledge your consent to “Data” for collection, use and disclosure of your personal information, or the personal information of another individual, which you provided to “Data”, as stated above.

4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by “Data”. Information shall be collected by fair and lawful means and may be collected from other sources including but not limited to credit bureaus or other third parties who represent that they have the right to disclose the information. In most cases, collection shall be pursuant to appropriate contractual arrangements.

5. Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which is was collected, except with the consent of the individual or as required or permitted by Privacy Laws. Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.

6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is possible. “Data” will update personal information as and when necessary to fulfill the identified purposes or upon notification from you. DBF will not routinely update personal information, unless such process is necessary to fulfill the identified purposes. If ever your contact and/or other personal information changes, please feel free to contact us so that we can update our records.

7. Safeguards: Security safeguards, appropriate to the sensitivity of the information, shall protect personal information. The security safeguards are designed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Technological measures include use of passwords, firewalls and encryption.

8. Openness: “Data” shall make readily available to you information about its Privacy Policy and practices relating to the management of personal information, which is accessible on our web-site www.datagroup.ca

9. Individual Access: Upon request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

NOTE: In certain situations, under Privacy Laws, “Data” may not be able to provide access to all of your personal information it holds. The reasons for denying access will be provided to you upon request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

10. Challenging Compliance: You may wish to address a concern in writing, regarding “Data’s” compliance with the above principles to “Data’s” Privacy Officer. “Data” shall investigate all complaints and respond within (30) thirty days. If a complaint is found to be justified, “Data” shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and practices. Individuals can obtain more information as well as a copy of the federal legislation through the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.

Privacy and our Website Cookies – When you access the The Data Group of Companies’ website, we do not use a browser feature called a “cookie” to collect information.

Changes to the Privacy Policy

“Data” reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our websites. We will provide to you such revised Privacy Policy upon request to the Privacy Officer. However, “Data” will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s personal information for purposes other than those to which your consent has previously been obtained unless otherwise required or permitted by Privacy Laws.

Further Information

The Data Group of Companies has appointed a Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws. For information on The Data Group of Companies privacy practices, please contact our Chief Privacy Officer at:

Genevieve Goldie Pagnotta
9195 Torbram Road
Brampton Ontario L6S 6H2
Email: gpagnotta@datagroup.ca
Phone: 905-494-4064
Fax: 905-791-9089

Definition of DATA means The DATA Group of Companies and its affiliates.