THE NEWINTELLIGENCE PRIVACY AND DATA PROTECTION POLICY

In accordance with Canadian law, Bill C-6, approved on April 13, 2008, NEWINTELLIGENCE applies the 10 principles set out in the ‘Personal Information Protection and Electronic Documents Act’ (PIPEDA). For more information on your rights and responsibilities as concerns this law, please consult the following Internet site: http://www.ic.gc.ca. Please read the full version of the NEWINTELLIGENCE privacy and data protection policy.

ACCOUNTABILITY

NEWINTELLIGENCE Inc. (hereinafter NEWINTELLIGENCE, and composed of the company itself and all other brands marketed by it) applies the 10 principles set out in the ‘Personal Information Protection and Electronic Documents Act,’ which include the following responsibilities maintained by the privacy officer.

The privacy officer ensures that all responsibilities are understood and assumed by the entire organization and answers all questions about the privacy and data protection policy from clients/prospects/consumers/employees/others.

NEWINTELLIGENCE protects all personal information that the organization has in its possession through its internal support systems and firewalls. Our clients’ personal information is never transferred to a third party without their express consent.

NEWINTELLIGENCE is responsible for all provisions included in its privacy and data protection policy.

NEWINTELLIGENCE collects personal information from its clients for marketing purposes:
The Marketing Department regularly sends information in the form of blog posts/press releases by e-mail/advertisement/fax/mail/etc. to prospects/clients to keep them informed of events/promotional offers/product updates or industry information that may be useful for them.

NEWINTELLIGENCE always offers prospects/clients the option of no longer receiving our communications, if that is their wish.

Prospects/clients can register in the NEWINTELLIGENCE data base through any one of several on-line resources, such as one of the NEWINTELLIGENCE Internet sites. Prospects/clients acknowledge that by registering, they agree to allow their information to be added to the NEWINTELLIGENCE data base. However, each time the prospects/clients are contacted, they have the option of no longer receiving our communications if that is their wish.

All marketing promotional offers sent by Internet/e-mail from NEWINTELLIGENCE will contain:

• The NEWINTELLIGENCE privacy and data protection policy with information about how to contact the company with questions.
• The procedure to follow if the addressee no longer wishes to receive promotional offers and other marketing initiatives.
• The procedure to follow if personal information must be corrected.
• The procedure to follow if the addressee wants to send us comments.

CONSENT

Consent to receive marketing materials is obtained either online (for Internet mailings) or by telephone / in-person interactions.

Should prospects/clients choose to be removed from the NEWINTELLIGENCE marketing data base (the consent is withdrawn), they assume responsibility for not being informed of new promotional offers, service offers, events, etc. that NEWINTELLIGENCE may offer at any time.

Prospects/clients who are removed from the marketing data base acknowledge that they will not receive materials sent by the Marketing Department unless it is otherwise notified.

LIMITING USE, DISCLOSURE AND RETENTION

Personal information about prospects/clients will be used only in the following circumstances:

• To ensure effective communication about events, promotional offers, promotional materials, catalogues, press releases, advertisements and other forms of marketing.
• To facilitate all communications-related requests made by prospects/clients to NEWINTELLIGENCE.

No information about clients will be disclosed for other reasons than those stated above.

ACCURACY OF INFORMATION

Information about prospects/clients can be changed/updated at any time. Prospects/clients may ask for their information to be changed/updated if they wish. NEWINTELLIGENCE makes all changes within 48 hours of a change request. If prospects/clients wish to receive the list of information kept by NEWINTELLIGENCE, they must contact NEWINTELLIGENCE by e-mail or telephone. NEWINTELLIGENCE will be sure to send the requested information to them. Clients must contact the privacy officer for all personal information stated above.

PROTECTING INFORMATION

At NEWINTELLIGENCE, client information is protected as follows:

• a) Access to information is limited to those who deal directly with the accounts.
• b) NEWINTELLIGENCE computer system, firewall, etc.

These two precautions ensure that the information is adequately used and distributed throughout the organization (NEWINTELLIGENCE), which makes it possible to efficiently transfer information to better serve the client.

POLICY ACCESS

Clients may at any time request a copy of the NEWINTELLIGENCE privacy and data protection policy. It is available on the NEWINTELLIGENCE website (www.newintelligence.ca) and can also be sent by all NEWINTELLIGENCE employees. All prospects/clients are informed of the NEWINTELLIGENCE privacy and data protection policy, which is accessible on its website and through a link in all e-mail messages sent by it.

INDIVIDUAL ACCESS TO PERSONAL INFORMATION

Prospects/clients/users may request their personal information at any time. These individuals may only request the personal information specifically kept by NEWINTELLIGENCE. Individuals other than those who have consented to be entered into the NEWINTELLIGENCE data base will not have access to the information of the other members registered in the data base.

CHALLENGING COMPLIANCE

If at any time, an individual believes that NEWINTELLIGENCE has not fulfilled its responsibilities in protecting personal information, a formal complaint can be filed if required.

If you have questions or comments about the privacy and data protection policy, feel free to contact our privacy officer.

Jennifer Vezina

jvezina@newintelligence.ca
514 315-2555