Privacy Globalfaces Direct Inc. Privacy Policy Globalfaces’ Commitment Globalfaces Direct Inc. (“Globalfaces”) is committed to maintaining the privacy of your personal information. Our commitment to you has been developed in accordance with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and ensures that your personal information will only be collected, used, and disclosed in compliance with the law. Scope of Policy Globalfaces’ Online Privacy Policy applies all to personal information about individuals collected through Globalfaces’ website. It does not apply to information relating to corporate or commercial entities or to information collected by means other than this website. Where a Globalfaces customer collects personal information through solutions provided by Globalfaces, Globalfaces will work with the customer to ensure those solutions reasonably assist the customer in complying with its privacy obligations. From time to time changes to this policy may be made and these changes will be incorporated into a revised statement which will be posted here in order to ensure that you will always have the most current information with respect to Globalfaces’ privacy practices. What is Personal Information? “Personal Information” is information about an identifiable individual but does not include the name, title, business address or telephone number of an employee of an organization. It also does not include information that is available in the public domain. Collection and Disclosure of Information Non-identifying Information Globalfaces collects the following information that does not identify you: Personal Information Except as set out above, Globalfaces does not collect personal information about guests to its website, other than personal information which is voluntarily provided. In certain situations, you may be requested to provide personal information for specific purposes. For example: We value your privacy and will keep your personal information secure. To this end, we provide a secure online environment using encryption during transmission. Globalfaces also protects your personal information from unauthorised access by locating all databases which retain this information on access-controlled systems behind secure firewalls. Globalfaces does not sell or trade your personal information with other companies. Subject to the following exceptions, we will not disclose your personal information to third parties without your consent. Globalfaces may disclose your information in accordance with PIPEDA, including but not limited to situations where such disclosure is required by law, to comply with valid legal processes such as a subpoena or court order, to collect a debt owed by you to Globalfaces, or where failure to disclose your personal information may put the safety of another individual at risk. If you have provided personal information and wish to have it removed from our system at a any time, please contact our Privacy Team at privacy@globalfacesdirect.com The accuracy of the personal information in our possession depends on you. Please contact Globalfaces to inform us of any changes to your information or to confirm the accuracy of the information we retain. Privacy Principles The cornerstone of Globalfaces’ Privacy Policy is that it will only collect personal information from you which is necessary for its legitimate business purposes, that it will only use this information in ways which have been clearly communicated to you (or which should be obvious from the manner in which the information was requested) and that it will safeguard your personal information while it is in Globalfaces’ possession and not retain it for longer than necessary. Globalfaces ascribes to ten privacy principles to ensure that your personal information is protected: 1. Accountability Globalfaces is accountable and responsible for personal information in its possession and under its control. Globalfaces has designated a Privacy Compliance Officer (“PCO”) who is accountable for Globalfaces’ compliance with this Policy. Globalfaces has adopted procedures to protect your personal information, to receive and respond to complaints and inquiries, to train staff regarding policies and procedures and to communicate policies and procedures to its customers. For more information on these policies please contact us at info@globalfacesdirect.com. 2. Identifying Purposes When collecting your personal information, Globalfaces will tell you why it is collecting the information and will provide, on request, contact information for the PCO who can answer further questions about the collection. Generally, Globalfaces collects personal information for the following purposes: to respond to inquiries about services that we are providing; to provide and administer the services that we provide; to authenticate your identity; to collect information to enable us to improve our services; to administer contests or promotional offers; and to protect us, yourself, and others from fraud or error. If your personal information is to be used by Globalfaces for a purpose not previously identified, Globalfaces will contact you prior to using your personal information for this purpose to obtain your consent, unless the use is authorized or required by law. 3. Consent Globalfaces will obtain your consent to collect, use or disclose your personal information except where Globalfaces is authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where: the information is publicly available, as defined by statute or regulation; we need to collect debts owed to us by you; we are obtaining legal advice; we reasonably expect that obtaining consent would compromise an investigation or proceeding; or we are contemplating selling all or part of Globalfaces’ business. Other exceptions may apply. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, by negative option, or otherwise. You may withdraw your consent at any time, subject to legal or contractual restrictions, and provided that reasonable notice is given to Globalfaces. Once notice is given, Globalfaces will inform you of the likely consequences of withdrawing your consent, which may include Globalfaces’ inability to provide the services requested. 4. Limiting Collection Globalfaces will limit its collection of personal information to that which is reasonable and necessary to provide the services requested, or as authorized by law. Globalfaces will collect information only by lawful means. 5. Limiting Use, Disclosure and Retention Your personal information will only be used or disclosed for the purposes consented to by you or as authorized by law. Globalfaces shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, Globalfaces shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision. Globalfaces will destroy, erase or make anonymous documents or other records containing your personal information once it is reasonable to believe that retention is unwarranted for legal or business purposes. Globalfaces will take due care when destroying personal information so as to prevent unauthorized access to the information. In the event that Globalfaces requires the services of a third party in order to deal with your personal information, Globalfaces will ensure that the third party adheres to privacy procedures and will keep your personal information confidential. Globalfaces will not provide more information than is necessary to the third party and will ensure that the information is returned or destroyed once the purpose for which it was given is filled. Globalfaces does not trade or sell personal information. Globalfaces may disclose personal information about its employees in the following circumstances: where the employee consents to the disclosure; for normal human resources and benefits administration; to respond to requests for references from prospective employers of current or former employees; where disclosure is required by law. 6. Accuracy Globalfaces will make reasonable efforts to ensure that your personal information is accurate and complete. In most cases, however, Globalfaces relies on you to ensure that the personal information provided is current, complete and accurate. Globalfaces does seek independent confirmation of credit card information provided, if applicable. If you demonstrate the inaccuracy or incompleteness of your personal information, Globalfaces will amend it as required. If appropriate, we will send the amended information to third parties to whom your personal information had previously been disclosed. When a challenge regarding the accuracy of your personal information is not resolved to your satisfaction, Globalfaces will make note that a request to amend the personal information under its control was made but that the information was not amended. 7. Safeguards Globalfaces has made appropriate security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal of your personal information. Some specific safeguards that have been implemented include: organizational measures such as restricting employee access to files and databases, as appropriate; electronic measures such as passwords and firewalls; and investigative measures where Globalfaces has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed. We will take reasonable steps, through contractual or other reasonable means to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us. Note that confidentiality and security are not assured when information is transmitted by email. Please notify us at info@globalfacesdirect.com if you do not want Globalfaces to communicate with you by email. 8.Openness Globalfaces is open about its privacy policies and procedures relating to the management of personal information. Information about these policies and procedures can be obtained from our office by written request. Globalfaces reserves the right to refuse to disclose sensitive information about its policies and procedures to ensure the integrity of its security procedures and business methods. 9. Individual Access Globalfaces will honour your right to be informed of the existence, use and disclosure of your personal information, and your right to access your personal information. Upon written request, Globalfaces will provide you with your personal information in its possession; a description of how your personal information is being used; and a list of those to whom your information has been disclosed. We will respond to such requests within 30 days or provide written notice where additional time is required to respond. We may charge you a reasonable fee for responding to your request. In some situations, Globalfaces may not be able to provide access to certain personal information. Examples of such situations include situations where disclosure would reveal the personal information of another individual, the personal information is subject to legal privilege, the personal information was collected for the purposes of an investigation, or where disclosure would reveal confidential commercial information that could harm the competitive position of Globalfaces. In some circumstances Globalfaces may be prevented by law from providing access to your personal information. Where Globalfaces refuses your request for access to your personal information, it will do so in writing and will explain the reasons why your request is being denied and will identity further steps that are available to you. 10. Challenging Compliance Globalfaces will, on request, provide information regarding its complaint procedures on request. Any inquiries, complaints or questions regarding this Policy should be directed in writing to us at privacy@globalfacesdirect.com .