Performance Challenges Corporation ("PCC") is fully committed to the protection of the information entrusted to it by its clients. Although we do not generally receive or collect any personal information as part of our services for clients, if personal information is provided to us by our clients, we adhere to the following policy for protecting such personal information, whether it is received through the web, electronic fax, or email. Regardless of how that information arrives, once it is within our control, access is rigorously protected by employing both technological and physical safeguards. COMPLIANCE We comply with the Canadian federal law for the protection of personal information, the Personal Information Protection and Electronic Documents Act ("PIPEDA"). In December 2001, the European Commission formally recognized PIPEDA as providing a level of protection that satisfies the requirements of EU law governing the trans-border transmission and protection of personal information. DATA SECURITY Whether it is personal or not, all information received electronically is secured within our network through firewall, anti-virus, anti-spyware and intrusion detection software that safeguard data from viruses and hacker attacks. When clients enter data through our web-based systems, access is controlled through a combination of User ID and Password unique to each user. When logging in, the user will see a lock symbol on the lower right of the browser’s screen. This symbol indicates that the user has entered our secure server environment and that any information sent to Performance Challenges is going to no one else. We also monitor the number of attempts to login and lock a user’s account if the user is unsuccessful after five attempts. Internally, data access privileges are based on a need-to-know basis and strictly enforced. COOKIES Cookies are small pieces of data that some web sites store on a PC’s hard drive through a user’s browser. Cookies may be employed to gather personal information about users and therefore violate the Consent Principle in Schedule 1 of PIPEDA. Performance Challenges does not store cookies on the PC of either a client or anyone accessing our web site. PRIVACY PCC acts strictly on behalf of its clients when dealing with personal information supplied to PCC. As a service provider to its clients, PCC will use and disclose any personal information provided by a client only as directed in writing by that client, or as may be required by law. For the protection of the data subjects, PCC will require reasonable assurances from the client appropriate to the sensitivity of the information that the client has obtained the necessary consents from the data subjects that their personal information may be used and, if necessary, disclosed by PCC as required by the nature of the assignment from the client. Occasionally individual data subjects will require access to their personal information. PCC will refer all such requests to the client from whom PCC received the information, and will provide access to the individual as and when directed by the client in writing. PCC will also forward to the client any requests by the individual to correct his/her personal information held by PCC, and will promptly correct such information upon receipt of written authorization from the client to do so. PCC retains personal information only for so long as is necessary to complete its mandate from its client, and thereafter any personal information used in the mandate is either returned to the client or destroyed. Our privacy policies and procedures, including those dealing with data security and access privileges, are frequently reviewed to ensure that they meet both national and international legal requirements and specifically the principles embodied in Schedule 1 of PIPEDA. This privacy policy statement will always reflect any changes made as a result of our continuing review process. If you have any questions concerning our privacy policy, please contact our Privacy Officer at the following address. All enquiries must be sent in writing, either by standard mail or email, to the Privacy Officer. Please note that all requests for access, requests to correct information, and complaints should be directed to the applicable PCC client to whom the individual has provided the information. PCC will forward any such enquiries or correspondence to the applicable PCC client for response. Privacy Officer 562 Parliament Street Suite 100 Toronto, ON M4X 1P8 Telephone: (416) 964-5666 Email: privacy@performancechallenges.com More about privacy: EU, Canada, US...