Privacy Policy

    Overview

    In the course of conducting our information services and technology business worldwide, Netex Enterprises Inc. collects and processes personally identifiable information of our clients, shareholders, employees, suppliers, business partners, Web site visitors and other persons (Personal Data). Maintaining the integrity and confidentiality of Personal Data and handling it correctly is central to the way we conduct our business activities. This policy describes how we handle Personal Data.

    Personal Data is information that can be used directly or indirectly to identify a living individual. Personal Data may include sensitive categories of information, such as information that reveals racial or ethnic origin, political opinions, religious beliefs, trade union membership, health or sexual orientation (Sensitive Personal Data).

    This policy applies to Netex Enterprises Inc. Corporation and its subsidiaries, and is effective as of June 1, 2004. All employees will be required to abide by this policy.

    This policy is designed to protect Personal Data under applicable law as it is currently exists. However, Netex Enterprises Inc. realizes that this policy cannot address every potential issue and circumstance. Therefore, we acknowledge that this policy is subject in all respects to applicable local legal and regulatory requirements and existing agreements and confirm that we will comply with such requirements and existing agreements.

    Privacy Principles

    We will observe the privacy principles described below of Notice, Choice/Fair Processing, Access, Security/Integrity, Onward Transfer and Enforcement/Compliance in processing Personal Data.

    Notice

    When we collect and process Personal Data about individuals, we will make certain information available to those individuals on a reasonable and timely basis. This information will include what Personal Data is being collected, who is collecting it, how and for what purposes it is being collected, how it is being used and to whom it will be disclosed.

    Choice/Fair Processing

    We will process Personal Data only with consent or when such processing is permitted by applicable law. If we need to process Sensitive Personal Data, we will obtain explicit consent for such processing, unless such processing is permitted by applicable law.

    We will not process Personal Data in a manner incompatible with the purposes for which it was originally collected unless later authorized by the affected individuals or allowed by law; we will take reasonable steps to ensure that such data is accurate, adequate, relevant and not excessive in relation to such purposes; and we will not keep such data longer than is necessary for such purposes.

    We will enable individuals to choose whether their Personal Data can be disclosed to a third party for direct marketing purposes.

    Access

    We will allow individuals reasonable access to their Personal Data to verify, correct or delete their data, where inaccurate. We will also provide a means for individuals to exercise all other legal rights that they may have in relation to their Personal Data.

    Personal Data will be accessible and processed only by (i) Netex Enterprises Inc. employees, suppliers, business partners and others who require access for the performance of their obligations to Netex Enterprises Inc.; (ii) any person granted access by the individual to whom Personal Data pertains; and (iii) those otherwise authorized by law or court order.

    Security/Integrity

    We will take reasonable security procedures through appropriate technical and organizational measures to protect against unauthorized or unlawful access or processing, disclosure, alteration, destruction or accidental loss of Personal Data.

    We will utilize reasonable means to keep Personal Data accurate, complete and current in order to protect the quality and integrity of Personal Data, however, we rely on individuals to provide all relevant information and to advise us of any changes to their Personal Data to ensure that it remains accurate, complete and current.

    Onward Transfer

    When we transfer Personal Data within Netex Enterprises Inc. or to third parties (including our suppliers and business partners), we will observe the privacy principles of Notice and Choice (described above), and we will require all the recipients of such data to provide at least the same level of protection for such data as specified by the standards stated in this policy.

    Enforcement/Compliance

    We will follow internal processes for handling complaints regarding our management of Personal Data.

    We will demonstrate our compliance with this policy by: publishing this policy conspicuously so that it is accessible to all interested persons appointing and maintaining a Privacy Officer with responsibility for developing and implementing a privacy program implementing procedures to execute this policy in the conduct of our business, including training our employees in the use of such procedures and disciplining employees for failure to comply with this policy and its procedures at least annually, reviewing this policy to ensure that it continues to comply with prevailing privacy standards, current applicable law and regulations and existing agreements Netex Enterprises Inc. Web Sites In addition to all other Personal Data handled by Netex Enterprises Inc., this policy applies to Personal Data collected through Netex Enterprises Inc. Web sites. As a convenience to our Web site visitors, we sometimes provide links to other Web sites. These linked sites are not under the control of Netex Enterprises Inc., and as such, we are not responsible for their content.

    Updating the Policy

    Changes in legislation and/or our business activities may require that this policy be updated from time to time.

    Contact Us

    If you have any questions or comments about this policy or our privacy practices, please contact us.

    Phone: 416-225-8324; Fax: 416-225-9161
    Street Address:
    Chief Privacy Officer
    Netex Enterprises Inc.
    47 Steeles Avenue East ,
    Toronto , Ontario M2M 3Y3




    The term "Personal Information" means information about an identifiable individual recorded in any form and includes, but is not limited to, such things as race, ethnic origin, nationality, colour, age, gender, marital status, religion, education, medical information, criminal information, performance reviews, trade union membership, employment and financial history, income, address and telephone number, e-mail address, numerical identifiers such as Social Insurance Number, and views and personal opinions. In the case of a customer, personal information also includes information about a customer’s purchasing history, credit information, billing records, service and any recorded complaints and, in the case of an employee, includes information found in personnel files, employment history, performance reviews and medical and benefits information. Publicly available information, such as a public directory listing of names, addresses, telephone numbers and electronic addresses, however, is not considered personal information.

    In addition to Personal Information, the Company may collect Aggregated Information, which is non-identifying technical information, IP address, operating system and Web browser software, web pages visitors access or and information volunteered by users, such as survey information and/or site registrations. Such Aggregated Information is collected for the Company’s purposes only.

    This Privacy Policy applies to personal information which the Company collects, uses or discloses in respect of any of its customers or employees in the course of its commercial activities. The application of this Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements (such as collective agreements), or the order of any court or other lawful authority. Various legal criteria independent of this Privacy Policy will determine whether federal or provincial privacy legislation applies to the personal information that the Company collects, uses or discloses in respect of its customers or employees. This Privacy Policy does not replace those criteria and nothing in this Privacy Policy should be construed as indicating which privacy legislation, if any, applies to the collection, use and disclosure of personal information.

    The Company's Privacy Policy and Procedures supports the following principles of PIPEDA

    a) Accountability: The Company is accountable for the protection of all Personal Information within the organization's possession or control, including any Personal Information that has been transferred to a third party for processing purposes. The Company may engage employees, contractors or other companies and third parties to perform services for the Company that involve access to Personal Information. The Company shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.

    b) Identifying Purposes: We state the purposes for collecting information before or at the time of collection if one of the purposes for collecting the information is not related to the transaction for which the information is sought and provided.

    At a minimum, the Company collects Personal Information from customers for the following purposes:
    * To identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
    * To deliver products and services;
    * To bill and collect payment;
    * To establish credit worthiness;
    * To sign up for pre-authorized payment;
    * For legal requirements;
    * To provide customers with information about the Company and its agents, partners and business associates and their products and services;
    * To request customer participation in surveys or contest.

    At a minimum, the Company collects Aggregated Information from customers to maintain and change the character and nature of its business to better serve its clients.

    The Company will retain Personal Information only for so long as is necessary to fulfill the Identifying Purposes and to meet its legal and contractual obligations.

    c) Consent: The Company will not use or disclose your Personal Information for purposes other than those for which it was collected except with your consent or as permitted or required by law or regulatory authorities. By using this web site or conducting a transaction through this web site, you are giving your express consent to the collection, retention, use and dissemination of your Personal Information and Aggregated Information by the Company and any of its agents, partners and business associates FOR THE PURPOSES IDENTIFIED HEREIN AND FOR ANY RELATED PURPOSE.

    d) Limiting Collection: The Company limits the collection of information to that which is reasonably required for or related to a specific transaction and to that which is voluntarily provided by customers.

    e) Limited Use, Disclosure and Retention: The Company uses the information that is provided to it only for the purposes for which Consent is provided and the Company retains it only as long as necessary to fulfill those purposes.

    f) Accuracy: The Company’s employees take every step necessary to ensure the accuracy of information that is provided by our participants.

    g) Safeguards: The Company uses the most secure methods of physical, organizational and technological security safeguards in the collection, use, disclosure, and retention of information provided to it. The Company does not sell, trade, or exchange mailing lists with external third party vendors for the purpose of promotion.

    h) Openness: The Company is committed to make readily available to our customers its policies and procedures in respect of the management of personal information.

    i) Individual Access: Upon request, customers may be informed of the existence, use and disclosure of personal information held by the Company and shall be given reasonable access to that information.

    j) Challenging Compliance: Customers may challenge compliance by writing to International Framing Industries Inc., 53 Riderwood Drive, Toronto, Ontario, Canada M2L 2E7.

    k) Opting Out: A customer may opt out of providing consent by writing expressly to International Framing Industries Inc., 53 Riderwood Drive, Toronto, Ontario, Canada M2L 2E7 with express instructions clearly removing their consent. Such opting out may result in the loss of any or all transactions involving the customer;

    l) Protection of Children: Adult or legal guardian approval must be provided in programs where children may participate who are under the age of thirteen.

    The Company will share Personal Information with authorized service providers as necessary in order to complete a transaction that a customer specifically requests. In selecting business partners, The Company considers the quality and accuracy of the data they provide and their customer service quality. Our partner relationships are with reputable third parties that work with The Company to offer our customers and site visitors a variety of products and services. All services throughout The Company that are provided by a third party are described as such. Our business partners may have different privacy policies and practices than The Company, and as such are independent and governed by that organization. We encourage our customers to review our business partners' privacy policies and practices to further understand their procedures for collecting, using, and disclosing customer information.

    The Company may also release Personal Information to third parties to comply with a legal process, enforce or apply the Terms of Service and other agreements or protect the rights, property, or safety of the users, or others related parties as is reasonably required. This may also include disclosing Personal Information to third party companies and organizations for fraud protection and credit risk reduction.

    This web site may contain links to other sites. The Company assumes no responsibility for the information, statements, product/service claims, or privacy practices of other sites. Read the privacy statements of each web site that collects identifiable information.

    The Company reserves the right to change this policy at any time by posting a revised privacy policy.