LEAD VIRTUAL SOLUTIONS

Personal Information Protection Policy

Lead Virtual Solutions is committed to safeguarding the personal information entrusted to us by our clients. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.

This policy applies to Lead Virtual Solutions and its employees. The policy also applies to any person or corporation providing services on our behalf.

A copy of this policy is provided to any client upon request.

What is personal information?

Personal information means information about an identifiable individual. This includes:

• an individual’s name, home address, home phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc.

What personal information do we collect?

At Lead Virtual Solutions, we collect only the personal information that we need for the purposes of providing services to our clients, including personal information needed to:

• open and manage an account
• deliver requested products and services
• follow up with clients to determine satisfaction with products and services

We normally collect client information directly from our clients. We may collect your information from other persons with your consent or as authorized by law. We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we don’t provide this notification when a client volunteers information for an obvious purpose (for example, to apply to become our client).

Consent

We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in those cases when you volunteer information for an obvious purpose.

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person or by telephone), in writing (by signing a consent form or by checking a box on a form), or electronically by clicking a button on our website.

A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.

We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.

How do we use and disclose personal information?

We use and disclose client personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary.

If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.

How do we safeguard personal information?

We make every reasonable effort to ensure that client information is accurate and complete. We rely on our clients to notify us if there is a change to their personal

information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible.

In some cases we may ask for a written request for correction. We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.

We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

We retain client personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.

We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed.

We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.