Your Leverage Rewards Program

PRIVACY COMMITMENT TO THE PROTECTION OF CUSTOMER INFORMATION

Introduction

Yourleverage.com, as the creator and manager of the Your Leverage Rewards Program, is demonstrating its commitment to protection the privacy of Customers Personal Information by developing and implementing this Privacy Commitment to the Protection of customer Information.

The Your Leverage Rewards Privacy Commitment complies with or exceeds the federal Personal Information Protection and Electronic Documents Act, the Canadian Marketing Associations code of Ethics and Standards of Practice, and applicable provincial privacy laws. It is based on the Canadian Standards Associations Model Code for the Protection of Personal Information.

The Your Leverage Rewards Privacy Commitment applies to the collection, storage, use, disclosure, protection, and accuracy of Personal Information collected and controlled by Your Leverage Rewards. It also applies to all Personal Information held in the databases utilized by Yourleverage.com's business units.

Definitions

Collector - an individual, business or organization who or which has enrolled, or its applying for enrollment, in the Your Leverage Rewards Program, the Your Leverage Rewards For Business Program and/or Your Leverage Rewards INCENTIVES, and for whom an Your Leverage Rewards account number has been established or is being established in the Your Leverage Rewards databases.

Collect - to gather, acquire, or obtain Personal Information from any source, including third parties.

Consent - voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of Yourleverage.com. Implied consent arises where consent may reasonably be inferred from the action or inaction of the Collector, such as the presentation or usage of the Your Leverage Rewards Collector Card or number.

Direct Marketing - direct communications targeted to Collectors, including mail, telemarketing, fax or electronic mail, but not including Collector Account Updates.

Personal Information - information about an identifiable Collector recorded in any form.

Sponsor - an organization, corporation or business that issues Your Leverage Rewards points to build and maintain customer and client loyalty.

Summary / Statements - a regular report to Collectors detailing their account balance and transactions, either by mail or electronic means, and which may include promotional material and Your Leverage Rewards Program updates.

Supplier, Participating Business, Partner Business - a company under contract to provide reward supply services, or data collection, processing and/or management services to Yourleverage.com.

Yourleverage.com - the creator and manager of the Your Leverage Rewards Program and the Your Leverage Rewards For Business Program.

The Principles

Principle 1 - Accountability

Yourleverage.com is responsible for Personal Information under its control, including Personal Information disclosed by Yourleverage.com to a third party for data and list processing.

1.1

The Executive Committee of Yourleverage.com is accountable for Yourleverage.com's compliance with the Your Leverage Rewards Privacy Commitment.

1.2

Your Leverage Rewards Marketing and Communications and Yourleverage.com's Counsel oversee Yourleverage.com's compliance with the Your Leverage Rewards Privacy Commitment.

1.3

Yourleverage.com uses agreements to provide a comparable level of protection for Personal Information while the information is being processed by an authorized third party.

1.4

The management of Yourleverage.com has established procedures to implement the Your Leverage Rewards Privacy Commitment, including

• procedures to protect Personal Information;
• procedures to receive and respond to complaints and inquiries;
• communications and training programs to provide information to Yourleverage.com's staff and contractors about privacy policies and practices; and
• information for Sponsors, Collectors and Yourleverage.com's employees to explain the Your Leverage Rewards Privacy Commitment.

Principle 2 - Identifying Purposes

Yourleverage.com collects Personal Information for three primary purposes: to ensure the proper functioning of the Your Leverage Rewards Program; to meet the direct marketing, product development and research requirements of the Your Leverage Rewards Program and its participating Sponsors; and to improve the promotional offers and services of the Your Leverage Rewards Program and its participating Sponsors.

 

2.1

Yourleverage.com provides Collectors with information that explains:

• the purposes for which Personal Information is being collected; and
• how the Personal Information may be used or disclosed.

2.2

Yourleverage.com collects Personal Information for the following purposes:

• To administer the Your Leverage Rewards Program, the Your Leverage Rewards For Business Program, and Your Leverage Rewards INCENTIVES, including the management of Collector Accounts to accurately record and update reward balances;
• To process Collector redemptions, including the issuance of reward tickets and vouchers;
• To invoice Collector and Sponsor Accounts as appropriate;
• To communicate information and offers to Collectors, Sponsors and Suppliers;
• To understand and analyze Collectors responses, needs and preferences;
• To develop, enhance, market and/or provide products and services to meet those needs; and
• To enable Collectors to participate in promotions and contests.

2.3

Your Leverage Rewards Collectors can opt out of receiving marketing and promotional communications in electronic, printed or verbal format, other than Your Leverage Rewards Collector Account Updates and Statements by emailing to:

. The decision to opt out of additional communications does not affect the Collectors ability to collect or redeem reward points in the Your Leverage Rewards Program.

2.4

Yourleverage.com obtains a Collectors consent before using Personal Information for a purpose that has not been specified, unless the new purpose is required by law.

2.5

Contractors of Yourleverage.com who collect Personal Information on behalf of the Your Leverage Rewards Program are able to provide information which explains the purposes for which it is being collected.

Principle 3 - Consent

Yourleverage.com makes a reasonable effort to ensure that Collectors understand how Personal Information will be used. Yourleverage.com obtains the consent of Collectors as required for the collection, use or disclosure of Personal Information, except where it is inappropriate to do so.

 

3.1

Yourleverage.com provides its Collectors with information about the way in which Personal Information will be used through printed materials, the Your Leverage Rewards Web site and other electronic means, any voice response system, or a contracted customer care centre.

3.2

Yourleverage.com obtains consent for the collection, use or disclosure of Personal Information. Typically, this consent is obtained on paper or electronic enrollment forms, survey forms, and/or during telephone conversations with Collectors.

3.3

Yourleverage.com does not, as a condition of participation in the Your Leverage Rewards Program, require a Collector to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill specified purposes.

3.4

Consent can be either express or implied. Express consent is given either verbally or in writing - e.g., on an Your Leverage Rewards enrollment or survey form. Consent is implied when it can be reasonably understood by the action or inaction of the Collector. For example, if a Collector uses an Your Leverage Rewards Card, Yourleverage.com assumes that the Collector has given consent to the collection of the transaction information required to fulfill specified purposes.

3.5

A Collector can withdraw consent at any time as per Section 2.3. If a Collector withdraws consent, Yourleverage.com makes the Collector aware of the consequences of this action.

Principle 4 - Limiting Collection

The collection of Personal Information is limited to that which is necessary for the purposes identified by Yourleverage.com. Yourleverage.com collects Personal Information by fair and lawful means.

 

4.1

Yourleverage.com does not collect Personal Information indiscriminately. Both the amount and the type of Personal Information collected are limited to that which is necessary to fulfill the purposes identified.

4.2

Yourleverage.com collects Personal Information from the Collector:

• as a result of purchases by the Collector at Sponsor locations;
• through online and electronic activity with Yourleverage.com;
• through telephone, paper and online surveys and contests;
• through enrollment in the Your Leverage Rewards Program; and
• through Collector redemption requests.

Principle 5 - Limiting Use, Disclosure and Retention

Yourleverage.com does not use or disclose Personal Information for purposes other than those for which it is collected, except with the consent of the Collector or as required by law. Yourleverage.com retains Personal Information only as long as necessary for the fulfillment of those purposes.

 

5.1

Yourleverage.com does not give, rent or sell Collector lists from the Your Leverage Rewards Program to any organization or individual other than business units of Yourleverage.com, Sponsors of the Your Leverage Rewards Program, and companies contracted to process and manage Collector transactions, redemption requests and communications.
In addition, a Collectors specific transaction information from one Your Leverage Rewards Sponsor is not disclosed to any other Your Leverage Rewards Sponsor.

5.2

Yourleverage.com may disclose Personal Information to comply with legal and regulatory requirements or to ensure compliance with the terms and conditions, and the administration of the Your Leverage Rewards Program, the Your Leverage Rewards for Business Program and Your Leverage Rewards INCENTIVES.

5.3

Yourleverage.com retains Personal Information in accordance with documented guidelines and procedures established by Yourleverage.com. The Personal Information of Collectors is retained for as long as they are active or potentially active in the Your Leverage Rewards Program.

5.4

Yourleverage.com has guidelines and implements procedures to govern the destruction of Personal Information that is no longer required to fulfill the identified purposes. Collector transaction records and inactive Collector accounts that exceed seven (7) years are deleted from the Your Leverage Rewards databases.

Principle 6 -Accuracy

Yourleverage.com keeps Personal Information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

 

6.1

Yourleverage.com updates Personal Information as it is made available by Collectors and Sponsors.

6.2

Collectors and Sponsors are responsible for informing Yourleverage.com about changes to Personal Information, as appropriate.

6.3

Yourleverage.com does not routinely update Personal Information unless such a process is necessary to fulfill the purposes for which the Personal Information is collected.

Principle 7 - Safeguards

Yourleverage.com protects Personal Information with security safeguards appropriate to the sensitivity of the Personal Information.

 

7.1

Yourleverage.com protects Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information. Yourleverage.com protects Personal Information regardless of the format in which it is held.

7.2

The methods of protection for Personal Information include:

1. physical measures, for example, locked filing cabinets and restricted access to offices;
2. organizational measures, for example, employee confidentiality agreements, security clearances and limiting access on a "need-to-know" basis; and
3. technological measures, for example, the use of passwords and encryption.

7.3

Personal Information is stored in secure and confidential databases at out internet service providers locations.

7.4

When Yourleverage.com uses a third party to process information on its behalf, legal agreements require the third party to protect the privacy and confidentiality of the Personal Information. Further, these agreements ensure that the Personal Information is retained only as long as necessary to complete the assigned task and that the third-party organization only uses it for the specified purposes for which it is given.

7.5

Yourleverage.com has appropriate training programs and provides employees with information about its policies and procedures for protecting Collectors Personal Information and the importance of maintaining the confidentiality of Personal Information.

7.6

Personal Information is disposed of or destroyed with care to prevent unauthorized parties from gaining access to the information.

Principle 8 - Openness

Yourleverage.com makes specific information about its policies and practices relating to the management of Personal Information readily available to Collectors.

 

8.1

Yourleverage.com is open about its policies and practices with respect to the management of Personal Information.

8.2

Yourleverage.com makes information about its privacy policies and practices readily available to individuals and its Collectors through written materials, its Web site and other electronic means, its Interactive Voice Response system, and its Customer Care Centre. In addition, copies of the Your Leverage Rewards Privacy Commitment are available to individuals and Collectors upon request.

Principle 9 - Individual Access

Upon request, Yourleverage.com gives Collectors access to their Personal Information and an account of its use and disclosure.

 

9.1

Collectors can request access to their Personal Information held by the Your Leverage Rewards Program by email to

. Upon request, Yourleverage.com informs the Collector whether or not it holds Personal Information about that Collector, and discloses details of that Collectors Personal Information, including, where available, the source type, its use, and Sponsors and research organizations to which it has been disclosed.

9.2

Yourleverage.com may request sufficient information from the Collector including passwords to verify the identity of the Collector and the existence, use and disclosure of Personal Information held by the Your Leverage Rewards Reward Program. Yourleverage.com will assist any Collector who informs Yourleverage.com that he or she needs assistance in preparing a request for access.

9.3

Yourleverage.com responds to a request for information within thirty (30) business days of receipt of request.

9.4

Responding to a Collector request for information will usually be done at no or minimal cost to the Collector. However, a fee for reasonable costs incurred may be charged in responding to more complex requests, provided the Collector is informed of the fee in advance. The Personal Information requested is provided to the Collector in a form that is generally understandable.

9.5

Yourleverage.com amends the Personal Information contained in the Your Leverage Rewards databases as required when an individual successfully demonstrates the inaccuracy or incompleteness of the Personal Information. An amendment may involve the correction, deletion or addition of information.

9.6

When it is not possible to provide a list of the Sponsors, agents and research organizations to which Yourleverage.com has disclosed Personal Information about a Collector, Yourleverage.com provides a list of the Sponsors, agents and research organizations to which it may have disclosed such Personal Information about the Collector.

9.7

A Collector has the opportunity to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate. When a challenge is not resolved to the satisfaction of the Collector, the Personal Information relating to that Collector shall reflect the unresolved challenge. The existence of the challenge is transmitted to third parties as appropriate.

9.8

If Yourleverage.com is unable to provide access to all the Personal Information it holds about a Collector, the reasons for denying access are provided to the Collector.

Principle 10 - Challenging Compliance

A Collector is able to address a challenge concerning Yourleverage.coms compliance with the above principles with the individual identified in Section 1.2.

 

10.1

Yourleverage.com has procedures in place to receive and respond to inquiries about Yourleverage.coms policies and practices relating to its handling of Personal Information.

10.2

Inquiries about Yourleverage.coms privacy policies can be forwarded to

.

10.3

Yourleverage.com investigates all complaints and responds within ninety (90) business days after receipt of written correspondence. If the complaint is found to be justified, Yourleverage.com takes appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.