J.C. Williams Group - Global Retail Consultants

J.C. WILLIAMS GROUP LIMITED
WEBSITE PRIVACY POLICY

1. Introduction
This privacy policy explains the privacy practices of J.C. Williams Group Limited (referred to as “J.C. Williams Group,” “us,” “we,” or “our”). This privacy policy applies to the collection, use, and disclosure of Personal Information in connection with our Website and in connection with the provision of our services and products. Our privacy policy may be amended from time to time, so we encourage you to periodically check our Website at http://www.jcwg.com for the current version. Printed copies of our current privacy policy are also available by contacting our Chief Privacy Officer.

2. Our Commitment to Your Privacy
J.C. Williams Group strives to take all appropriate measures to safeguard your Personal Information. We have established this privacy policy to ensure that your Personal Information is protected and that all our practices and procedures comply with relevant Personal Information protection and privacy legislation. Accordingly, we adhere to the privacy principles set out below, which are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada). As used in our privacy policy, the term “Personal Information” means information about an identifiable individual, but does not include the name, title or business address, or telephone number of an employee of an organization.

3. Accountability
J.C. Williams Group Limited is responsible for all Personal Information under its control.

Accountability for our compliance with this privacy policy rests with our Chief Privacy Officer. However, other individuals within J.C. Williams Group may have responsibility for the day-to-day collection and processing of Personal Information.

Contact information for our Chief Privacy Officer is set out below:
John Williams
J.C. Williams Group Limited
17 Dundonald Street, 3rd Floor
Toronto, ON M4Y 1K3
Canada
E-mail: jwilliams@jcwg.com

N.B., CPO is to be confirmed

J.C. Williams Group is responsible for Personal Information under its control including information that needs to be disclosed to third parties in the course of its business. We use contractual and other means to ensure that third parties, to whom we disclose Personal Information for processing, provide a comparable level of protection with respect to Personal Information in their possession or control.

4. Identifying Purposes
We will clearly identify and document the purposes for which we may collect, use, or disclose Personal Information at or before the time of collection. As part of our business operations, we may collect and use certain Personal Information strictly for the following purposes:

-	To obtain registration data so that you may use certain areas of the Website, register for events and conferences, and participate in “join our mailing list” initiatives.
-	To allow us to respond to inquiries for further information.
-	To distribute requested reference materials.
-	To provide information regarding services and products that may be of interest to you. (If you wish to stop receiving such information, simply visit the J.C. Williams Group Website at www.jcwg.com and follow the instructions to unsubscribe, or provide written instructions to our Chief Privacy Officer.)

From time to time, J.C. Williams Group may use the Website as a recruiting tool; therefore, your Personal Information may be collected when submitting a resume or work history information.

In addition, in the unlikely event that J.C. Williams Group sells all or substantially all of its asse ts, subscriber information, including your collected Personal Information, will be one of the transferred assets.

The specific uses of Personal Information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances.

J.C. Williams Group obtains a Customer’s consent before using Personal Information for a purpose that has not been specified, unless the new purpose is required by law.

5. Obtaining Consent and Opting Out/Withdrawing Consent
By using the services of J.C. Williams Group, you consent to the collection, use, and disclosure of specific Personal Information by us as detailed in this privacy policy.

We will use reasonable efforts to seek your express consent for the collection, use, or disclosure of your Personal Information at the time of collection. In some circumstances, such as where we want to use Personal Information for a purpose that was not previously identified, we may have to seek your consent after your Personal Information has been collected but before our use for that purpose.

We will not, as a condition of providing membership service to you, require you to consent to the collection, use, or disclosure of Personal Information beyond that which is absolutely necessary.

You always have the choice of whether or not you wish to supply J.C. Williams Group with Personal Information. If you wish to “opt-out” of receiving certain informational and promotional materials from us, simply visit www.jcwg.com and follow the instructions to unsubscribe, or provide written instructions to our Chief Privacy Officer at the address set out above. Similarly, if you wish to withdraw your consent with respect to a particular use or disclosure of your Personal Information, you may do so at any time by sending written instructions to our Chief Privacy Officer at the address set out above.

In certain limited circumstances, as permitted or required by law, we may collect, use, or disclose Personal Information without the knowledge or consent of the individual. Although the following list is not exhaustive, these circumstances include: (i) Personal Information, which is publicly available as defined by regulation; (ii) situations where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) investigation of a breach of an agreement or a contravention of a law; (iv) action in respect to an emergency that threatens the life, health, or security of an individual; (v) debt collection; or, (vi) compliance with a subpoena, warrant, or court order.

6. Limiting Collection
We will limit the amount and type of Personal Information collected to that which is necessary for our identified purposes, and we will only collect Personal Information by fair and lawful means.

We may collect the following types of Personal Information from individuals visiting our Website or purchasing our membership products and services:

-	Name
-	Credit card number (if purchasing a service or product)
-	Residential address (if purchasing a service or product for personal use)
-	Residential telephone number (if purchasing a service or product)
-	E-mail address.

Through the use of cookies (described in the glossary below) our Website automatically records some general information about your visit, for Website traffic analysis, such as your IP address and type of browser. This information is used to improve your visit to our Website. If you are concerned about the use of cookies, most browsers now recognize when a cookie is offered and permits users to opt-out of receiving it. If you are not sure whether your browser has this capability, you should check with the software developer or your Internet service provider. It is our policy to use cookies to make the use of our Website easier for visitors and to facilitate efficient registration procedures. In most cases, a visitor can refuse a cookie and still fully navigate our Website.

In order to efficiently manage our Website and provide an effective information resource, we may log information on our operational systems on an anonymous basis and identify categories of visitors by fields such as domains and browser types. These statistics are reported in the aggregate to our Webmasters.

Our Website contains links to other sites. Once you leave our Website, you are subject to the privacy policies of the other sites you visit.

7. Limiting Use, Disclosure, and Retention
Your Personal Information collected by J.C. Williams Group will be used to deliver services, products, or programs you have requested or enrolled in.

J.C. Williams Group does not give, rent, or sell Customers lists to any organization or individual other than its affiliated companies or suppliers contracted to process and manage Customers’ transactions (where applicable) and communications.

Visitors are not required to register and provide Personal Information to gain access to most areas of the Website; however, we may require visitors to register and provide required Personal Information in order to obtain a user log-in identification and password to secure access to transactions or certain confidential or proprietary information services provided as a premium content service on our Website.

We will retain your Personal Information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements. J.C. Williams Group has guidelines and implements procedures to govern the destruction of Personal Information that is no longer required to fulfill the identified purposes.

8. Accuracy
We will use our best efforts to ensure that Personal Information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this privacy policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. J.C. Williams Group updates Personal Information as it is made available by Customers. Customers are responsible for informing J.C. Williams Group about changes to Personal Information, as appropriate.

9. Safeguards
We are committed to protecting the security of your Personal Information and we will protect your Personal Information with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which the information is held.

We use security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. [For example, we store Personal Information provided by you on computer systems with limited access in controlled facilities. When confidential information (such as credit card numbers) is transmitted over the Internet, it is protected through the use of SSL Encryption.]

We make our employees and business partners aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise appropriate care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.

Our methods of protection include physical measures (for example, restricted access to offices), organizational measures (for example, limiting access to a need-to-know basis), and technological measures (for example, the use of passwords and encryption).

10. Openness
We will make specific information about our policies and practices readily available except to the extent that it is confidential commercial information.

Upon written request, the information we will make available will include: (i) how to gain access to your Personal Information; (ii) the type of Personal Information held by us including a general account of its use; (iii) general information concerning our privacy policy; (iv) what Personal Information is made available to third parties; and, (v) how to contact our Chief Privacy Officer.

11. Access
Upon written request addressed to our Chief Privacy Officer, we will inform an individual of the existence, use, and disclosure of his or her Personal Information and we will give the individual access to that Personal Information. An individual can challenge the accuracy and completeness of his or her Personal Information under our control and have it amended as appropriate.

We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We will require an individual to provide sufficient information (including passwords) to permit us to provide an account of the existence, use, and disclosure of Personal Information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the said cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.

If you feel that your Personal Information we hold is inaccurate or incomplete, you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the Personal Information. Any such request must be in writing.

In providing an account of third parties to which we may have disclosed Personal Information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed Personal Information, we will provide a list of organizations to which we may have disclosed the Personal Information.

If an individual successfully demonstrates an inaccuracy or incompleteness of his or her Personal Information under our control, we will amend the Personal Information as appropriate. If the amendment is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the Personal Information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon written request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and, (iii) information that is subject to solicitor-client privilege.

12. Challenging Compliance
If you are not completely satisfied with our privacy policy and wish to submit comments or concerns regarding our privacy practices, we invite you to contact our Chief Privacy Officer. We will thoroughly investigate all written complaints addressed to our Chief Privacy Officer. If we find a written complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.

If for any reason you are not satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3, Telephone: 1-800-282-1376.

Glossary

Cookies: Cookies are small text files that a Website may place in your computer to help your browser remember specific information. For example, a cookie may be used to customize services for the interests of the user by tracking the user’s navigation. Cookies can also be used to store registration information in an area of a Website so that a user does not have to re-enter it on subsequent visits to that area.

IP: An abbreviation for Internet Protocol, the basic network transmission protocol of the Internet.

SSL Encryption SSL, or Security Socket Layer: Encrypts your Customers' credit card numbers, as well as other confidential information. This allows for secure online business. When your Web page has SSL, your page will show a small gold lock or key in the lower right hand side of your browser.

Revised: August 25, 2005.

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