This policy explains the types of customer personal information we collect, how it is used, and the steps we take to ensure your personal information is handled appropriately.

Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding provincial privacy acts.

What is personal information?
Personal information is information that refers to an individual specifically and is recorded in any form. Personal information includes such things as age, income, date of birth, ethnic origin, medical records and credit records. Information about individuals contained in the following documents is not considered personal information:

• public telephone directories, where the subscriber can refuse to be listed,

• professional and business directories available to the public,

• certain public registries and court records,

• certain other publicly available printed and electronic publications.

Our commitment to your privacy is governed by the following privacy principles:

1. We are accountable to you
Vanstone is responsible for all personal information under its control, including any personal information that is transferred to third parties for processing, storage or other purposes. We have employees in each of our business units who are accountable for compliance with these privacy and security principles.

2. We let you know why we collect your personal information
Vanstone identifies the purpose for which your personal information is collected. We do this before or at the time the information is actually being collected.

3. We obtain your consent to collect, use or disclose your personal information.

Vanstone obtains your consent to collect, use or disclose personal information. The method of obtaining consent is appropriate to the type of personal information being collected, used or disclosed:

Vanstone will obtain your express consent (verbal, written or electronic agreement) to collect, use or disclose sensitive personal information such as medical data or personal financial information.

Vanstone will use implied consent to collect, use or disclose your personal information where one or more of the following apply:

• a customer relationship already exists,

• express consent has previously been given,

• where the purpose of using the personal information is reasonably apparent to you.

4. We limit collection of your personal information

Vanstone collects only the information required to provide products and services and marketing endeavors to you. If the personal information we require is collected for a reason other than to provide products and services or marketing endeavors, your consent will be obtained before or at the time the information is collected. Vanstone will collect personal information only by clear, fair and lawful means.

Examples of why we collect personal information include:

• Communicating with you generally

• Processing your applications

• Processing and keeping track of transactions and reporting back to you

• Protecting against fraud or error

• Providing product and services requested by you

• Recommending products and services that Vanstone believes will be of interest and provide value to you

• To comply with legal and governmental requirements

5. We limit use, disclosure and retention of your personal information
Vanstone uses and discloses your personal information only for the purposes it was collected. Vanstone does not sell or rent personal information to any organization or person for any reason.
We do not share your personal information with third party organizations except to offer you a product or service. If your personal information is shared with third parties, these third parties are bound by appropriate agreements with Vanstone to secure and protect the confidentiality of your personal information.

6. The security of your personal information is a priority for Vanstone.
We take steps to safeguard your personal information, regardless of the format in which it is held, including:
• physical security measures such as restricted access facilities and locked filing cabinets,
• electronic security measures for computerized personal information such as password protection, database
• encryption and personal identification numbers,
• organizational processes such as limiting access to your personal information to a selected group of individuals,
• contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.

7. We are open about our privacy and security policy
We are committed to providing you with understandable and easily available information about our policy and practices related to management of your personal information.

8. We respond to your questions, concerns and complaints about privacy
Vanstone responds in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policies and procedures.