CUSTOMER PRIVACY POLICY

1. Commitment to Privacy
a) Information technology has brought many ways to do business. It allows businesses and customers to interact through electronic means that enables companies to conduct their business efficiently and provide the highest standard of customer service. At the same time, this has brought legitimate concerns about security and privacy of personal information passed from the customer to the business.
b) We at Bruce Street Technologies Limited (“BST Ltd.”) are committed to protecting the privacy of our customers. Your personal information is fundamental in the way we conduct our business. BST Ltd.’s Customer Privacy Policy provides the principles in which BST Ltd. will adhere to protect your personal information. BST Ltd.’s Customer Privacy Policy complies with the provision set out by the Canadian Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 (PIPEDA).

2. Privacy Protection in Canada
a) The Personal Information Protection and Electronic Documents Act (PIPEDA), of the federal government, significantly impacts the way private businesses, corporations, federal agencies, not-for-profit organizations and associations handle the personal information they have collected in the course of their business. At the same time, it will clearly establish a code of privacy practices that will provide Canadians from coast to coast with a mechanism to ensure their personal information is handled respectfully.
b) PIPEDA acknowledges the need to protect an individual’s right to privacy and also addresses the necessity of collecting private information for businesses in the conduct of their business affair. The act provides guidelines and principles for businesses for the accountability, purpose, obtaining of consent, disclosure, accuracy, safeguarding, openness of policy and access to personal information that was entrusted to its care.
c) The PIPEDA principles:
(i) accountability;
(ii) identifying the purposes for personal information collection;
(iii) obtaining consent;
(iv) limiting the collection of personal information;
(v) limiting use, disclosure, and retention of personal information;
(vi) accuracy of personal information;
(vii) safeguarding personal information;
(vii) openness about policies and procedures;
(ix) providing access to personal information; and
(x) challenging compliance.

3. Our Customer Privacy Policy at BST Ltd.
Under the Act, we at BST Ltd. are obliged to demonstrate to our customers and to any individual our commitment in protecting one’s personal and private information. We have developed our policy to meet the compliance of CSA Model for the Protection of Personal Privacy and PIPEDA.

4. The Personal Information We Collect
a) In dealing with BST Ltd. for Services, our Customer Representative will collect the following information: Name Contact information, i.e., phone number and/or e-mail address, How did you hear about BST Ltd.?
b) To process your request, our Customer Representative will collect the following personal information: Name Contact number E-mail address, if any Home address Contact information of person signing for the Services Password for setting up account Payment information (Personal cheque, Cash, draft, fund transfer, traveler’s cheque and certified cheque, credit card)

5. Why We Collect Your Personal Information?
a) BST Ltd. collects personal information only for the following purposes:
(i) to establish and maintain responsible commercial relations with you and provide you with ongoing service;
(ii) to obtain information for billing and collection;
(iii) to manage your access to services provided by BST Ltd.;
(iv) to manage and develop BST Ltd.’s business and operations to provide its customer the highest level of satisfaction; and
(v) to meet legal and regulatory requirements.

b) Customer Representatives collecting personal information can be asked to explain the purposes for which the information is being collected. The purposes shall be stated in such a manner that the customer shall understand.

6. We Need Your Consent
Consent is required for the collection of personal information and the subsequent use or disclosure of this information.

7. We Will Not Use Your Personal Information Without Your Consent
a) In general, the use of our products and services by a customer constitutes implied consent for us to collect, use and disclose personal information for all identified purposes. But, in most cases, our Customer Representatives will seek consent for the use or disclosure of your personal information at the time of collection.
b) Customers may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers can contact Customer Service at [email protected] to express their intention to withdraw their consent. Customers may also contact [email protected] for more information regarding the implications of withdrawing consent.

8. We Will Only Use Your Personal Information for the Purpose We Mentioned
a) We can only use your personal information for the purpose we have stated and within the limits of the PIPEDA.
b) In the event that we want to use your personal information for a purpose not previously identified, consent with respect to use or disclosure may be sought after the information has been collected, but before it is used.
c) Is Your Information Accurate? We do our best to keep your personal information as accurate as possible during the collection process. We may from time to time, update your personal information within the limits of the purpose we have mentioned.
d) If the purpose of the collection of personal information has been fulfilled, we can no longer gather updates of your personal information.

9. How Long Do We Keep Your Personal Information?
a) We maintain your personal information until the purpose we have mentioned has been fulfilled. We also take into consideration the amount of time required by law to maintain such records.
b) After such time, your personal information will be properly disposed according to our guideline in the destruction of personal information.

10. Our Commitment to Data Security
a) We are committed to protect your personal information with security safeguards appropriately in place.
b) The methods of protection include:
(i) physical measures, for example, locked filing cabinets and restricted access to offices;
(ii) organizational measures, for example, security clearances and limiting access on a “need to know” basis;
(iii) technological measures, for example, the use of passwords and encryption; and
(iv) investigative measures where required to safeguard the interests of BST Ltd. or its customers.
c)   We make the effort to train our employees and make them aware of the  importance of maintaining    the confidentiality of personal information. Only BST Ltd.’s employees with a business need to know, or whose duties reasonably so require, are granted access to your personal information.
d)   We store personal information data only to the extent of its purpose and to meet the period as required by law. After this period, your personal information will be properly disposed according to our guidelines in the destruction of personal information.

11. How Do We Dispose of Your Private Information?
We shall destroy, erase, or make anonymous personal information that is no longer required to fulfill the identified purposes and meeting the required period by law.

12. We Will Adhere to the Following Guidelines In Disposing Your Personal Information
a) We will shred paper documents containing personal information and dispose of them so that the personal information cannot be retrieved.
b) We will delete personal information from our files.
c) In the event that the personal information cannot be deleted, we would then make the information anonymous to make sure that the identity of the person having that personal information is not compromised.

13. Your Right to Your Personal Information We Collect
a) We recognize your right to your personal information we have collected. Our Customer Representatives will make the effort to inform you of what information we have on you. You in return have the right to ask for such information.
b) If you find that your personal information is inaccurate, or have a question on our Customer Privacy Policy, you can contact our Customer Service at (519) 599-3689 and ask for the Privacy Officer or e-mail at [email protected].

14. Contacting Us
a) Should you have any questions or concerns about our Customer Privacy Policy, please feel free to contact us at [email protected] or call (519) 599-3689, and ask for the Privacy Officer.
b) We will make the effort to respond to all inquiries within the required period provided by the PIPEDA. We have put in place a Privacy Officer to look after the implementation and compliance of the Act.