Scope of the Exclusive Privacy Policy

The Exclusive Services (“Exclusive”) Privacy Policy (the “Policy”) applies to personal information about both Exclusive employees and other persons who interact with Exclusive that is collected, used or disclosed by Exclusive.

Definitions

“Employees” include both past and present employees of Exclusive “Other Persons” includes individuals and corporations who are customers, suppliers, job applicants, and Internet users who access the Exclusive website “Personal Information” includes information about Employees or Other Persons in any form, whether it is oral, written or electronic.

Exclusions

The Privacy Policy does not restrict the collection, use or disclosure of the following information:

Information that is publicly available, such as a person’s name, address, telephone number or e-mail address Business contact information such as name, title, business address or telephone number of an employee of an organization

Amendment

Exclusive reserves the right to amend this Policy from time to time.

Privacy Officer

Exclusive’s designated Privacy Officer is Brad Hoad. The Privacy Officer can be contacted at Exclusive Services, 208 Hillyard Street, Unit #20, Hamilton, Ontario L8L 6B6.

Purposes for Collection of Personal Information

Exclusive collects Personal Information for the following purposes:

  • For Other Persons: verifying creditworthiness, completing sales transactions, responding to requests for products and information, and better understanding your needs.
  • For Employees: processing payroll, administering employee benefits, confirming employment and verifying income for third parties such as banks. Information will not be given to outside agencies such as banks without an Employee’s express consent.
  • To manage and develop Exclusive’s business and operations, including personnel and employment issues.

Obtaining Consent for Collection, Use or Disclosure of Personal Information

Exclusive will make every effort possible to ensure employees and Other persons understand how their Personal Information will be used by Exclusive. Exclusive will obtain consent, whether implied as discussed below, or express, before or when it collects or uses Personal Information. Exclusive may collect, use or disclose Personal Information without employees and Others consent if required by law to do so.

In general, the use of products and services by Other Persons, or the acceptance of employment or benefits by an Employee, constitutes implied consent for Exclusive to collect, use, or disclose Personal Information.

An Employee or Other Person may withdraw consent at any time, subject to legal restrictions and reasonable notice. Exclusive may be contacted for more information regarding the implications of withdrawing consent.

Exclusive may use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.

Exclusive may also collect Personal Information from other sources, including credit bureaus, employers or personal references, or third parties that represent that they have the right to disclose the information.

Limiting Collection, Use, Disclosure and Retention of Personal Information

Exclusive shall limit the collection of Personal Information to that which is necessary for the purposes mentioned above. Exclusive shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the person or as required by law. Exclusive shall retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected, or as long as required by law. Exclusive may disclose Personal Information about Employees in the following instances:

  • for personnel and benefits administration
  • providing references for former Employees
  • where disclosure is required by law

Exclusive shall restrict access to all Personal Information to only those Employees whose duties require access for business reasons.

Exclusive shall maintain reasonable systems and procedures for Personal Information records, retention, and subsequent destruction when no longer needed.

Exclusive shall update Personal Information as and when necessary to fulfill the identified purposes.

Security Safeguards

Exclusive shall protect Personal Information against such risks as loss or theft, unauthorized access, copying, modification or destruction, through appropriate security measures, regardless of the format it is held.

All Employees with access to Personal Information shall be required as a condition of employment to maintain strict confidentiality.

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