Pacific Corporate Trust Company is committed to safeguard the
privacy and security of all personal information entrusted to us. As a part of
this commitment, we have developed a Privacy Policy. Our Privacy Policy is
based on the Canadian Standards Association's Model Code for the Personal
Information Protection and Electronic Documents Act and on the BC Personal
Information Protection Act. The following Ten Principles of Privacy govern how
we handle all personal information in carrying out our business. Personal
Information is any piece of information, either factual or subjective, about an
identifiable individual.
Principle #1: We are Accountable for the Personal
Information in our Possession
Pacific Corporate Trust Company is accountable for all personal
information under its control. This includes any personal information received
directly or indirectly from brokers, shareholders, clients, partners,
employees, and regulatory bodies. We have established policies and procedures
aimed at protecting the privacy of all personal information under our control.
Every Pacific Corporate Trust Company employee is educated about the current
privacy policies and procedures and understands the importance of adhering to
them. All Pacific Corporate Trust employees, officers, directors and
consultants sign a confidentiality agreement annually. Pacific Corporate Trust
ensures that all third party service providers have a commitment to comply with
privacy legislation.
Lisa Scotland, Administrator of Development, has been appointed
as Pacific Corporate Trust Company's Privacy Officer. The Privacy Officer is
responsible for reviewing all personal information handling practices within
our offices and for ensuring that they always conform to this Policy.
Principle #2: We will Identify the Purposes for Collecting
Personal Information
Pacific Corporate Trust Company has identified the purposes for
collecting personal information in order to facilitate explanations to those
whose information is collected. The purpose is most often communicated at the
time the information is collected on paper or online forms. The purpose may be
obvious such as when an individual, a company or their financial institution
provides instructions to transfer shares into their name. It is understood that
the information will be recorded on the issuer's securities register and used
to send corporate mailings, dividends and other entitlements to the new
shareholder.
Principle #3: We will Obtain Consent to Collect, Use and
Disclose Personal Information
Pacific Corporate Trust Company requires and obtains express
consent to collect, use and disclose personal information where it is not
inherently implied in the business transaction. The purpose for collecting the
information will be identified in a clear and understandable manner. Express
consent is obtained in writing, verbally or electronically. Implied consent
occurs when we can reasonably assume that consent is given by an action taken
by or on behalf of an individual. Consent is implied when we receive
instructions directly from an individual, their financial institution or the
issuer to transfer securities into the individual's name. It is also implied
that the organization providing the personal information obtained the
individual's consent.
Upon request, we will provide individuals with the option to
refuse or withdraw consent to the collection, use and disclosure of their
information. The decision to withhold or withdraw consent may result in
limiting the services we are able to perform. Withdrawal of consent must not
prevent us from complying with legal requirements to provide a service or
protect the life, health or security of an individual.
Principle #4: We will Limit Collection of Personal
Information to Meet the Business Purpose
Pacific Corporate Trust Company will limit the collection of
personal information to that which is required to provide our services and
operate our business. If we intend to use your personal information for a
purpose not previously identified to you, we will obtain your consent.
Occasionally, our Website will generate and send users a
"cookie". All cookies generated by our website are exchanged solely with our
server (they are known as "per session cookies"). These cookies are used to
maintain a user's login session and not to collect marketing information or
share with third parties. Most browsers will automatically accept a cookie, but
if the user has set their browser to not accept cookies, there are some areas
of our website that will not be accessible until they have changed this
setting.
Principle #5: We will Limit Use, Disclosure and Retention
of Personal Information
Pacific Corporate Trust Company will use and disclose personal
information only for the purposes consented to. Personal information may be
passed on to third party service providers that have confirmed through a
contractual arrangement that they adhere to the applicable privacy laws.
Security holders' information that is not protected by other confidentiality
arrangements must always be available to the issuer (our clients) in which they
hold securities.
We maintain policies and procedures regarding the retention and
destruction of all records. Our policies provide for the storage of records
which may include personal information in order to meet statutory requirements
and to respond to questions that may arise. Generally records are retained for
the length of the time we are legally required to store such information,
currently six years. Some records may be kept indefinitely if it is in the best
interest of the issuer. All of our records are stored securely and if they are
no longer required, they are destroyed.
Principle # 6: We Strive to Maintain Personal Information
Accuracy
Pacific Corporate Trust Company policies and procedures are
designed to ensure the accuracy of our records and all personal information.
However, we must also rely on those whose information we maintain to provide us
with satisfactory written notice (via fax, mail, email or our website)
regarding changes to their information.
Principle #7: We will Safeguard Personal Information
Pacific Corporate Trust Company uses physical, organizational
and technological methods to safeguard personal information against loss,
inappropriate disclosure and unauthorized access, use or modification.
Access to paper records that contain personal information is
restricted to authorized employees only. This also applies to areas of the
office where personal information may be received, collected and processed. Our
offsite storage facility is required by law to safeguard personal information.
All of our computer systems and databases are secured and
accessible only by authorized employees through confidential passwords.
Confidential information that has been requested or accepted by our website is
encrypted while in transmission and is held on secure servers. Email or other
forms of Internet communications used to convey personal information to us are
not necessarily secure against possible interception. If the information being
communicated is very sensitive, it should not be sent via email.
We review our security policies and procedures periodically to
ensure that our systems will continue to be secure.
Principle #8: We will Ensure Personal Information is
Available
Pacific Corporate Trust Company has prepared this Privacy
Policy to inform you of our commitment to safeguarding the privacy and security
of all personal information entrusted to us. It is available in paper form at
the corporate address and in electronic form on our website" at
www.pctc.com.
Principle #9: We will Give Access to Personal Information
Pacific Corporate Trust Company will provide you with access to
the information that we have recorded about you within 30 days of receiving a
written request and identification that enables us to determine that you are
entitled to the information. We will also confirm how the information is used
and to whom it has been disclosed. This information will be free of charge,
unless significant research is involved, in which case we will advise you of
the cost prior to proceeding.
If there are any errors or inaccuracies with your personal
information, we ask you to contact us as soon as possible. We will make the
necessary corrections immediately upon receipt of a written request and
satisfactory identification.
Where the law prevents us from complying with your request, we
will provide a response that includes the reasons we are unable to provide
access.
Principle #10: We will Handle your Inquiries or Complaints
We encourage you to contact us at any time with questions or
concerns about any aspect of our Privacy Policy and the handling of your
information. We will investigate and respond to all inquiries received. Please
send these to pacific@pctc.com
or submit your inquiry through our website by selecting How Are We Doing? on
the home page or write to us at:
Pacific Corporate Trust Company
510 Burrard Street, 2nd Floor, Vancouver, B.C. V6C 3B9
After you have received our response, if you feel that your
concerns have not been addressed or if you would like to make a formal
complaint, please do so by contacting our Privacy Officer at the above address,
via email to privacyofficer@pctc.com
or via telephone at (604) 661-9400 Ext 7251.
Note that this policy applies to this website alone and does not apply to
any websites from which you may have linked to this website or to which you may
link from this website. Please review the privacy policies on those websites to
determine their information handling practices.
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