Personal Information Protection Policy ("Privacy Policy") of: EL APOSTOL (Canada) This Privacy Policy of EL APOSTOL (Canada) is compliant with the Personal Information Protection Act of British Columbia, the Laws of Canada under the Personal Information Protection and Electronic Documents Act and hereby EL APOSTOL (Canada) meets the personal privacy requirements for British Columbia, Canada and international trade as set forth by the European Union (EU) and other international bodies. A copy of this Privacy Policy may be obtained by clicking the "PRINT" buttons at the top and bottom of this page, or, from the Privacy Officer as set out in Section 8 herein. We are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients , protecting their personal information is one of our highest priorities. While we have always respected our clients privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia's Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information. We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances. This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients personal information and allowing our clients to request access to, and correction of, their personal information. Definitions: Personal Information - means information about an identifiable individual. Personal information does not include contact information (described below). Contact information - means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA. Privacy Officer - means the individual designated responsibility for ensuring that EL APOSTOL (Canada) complies with this policy and PIPA. Policy 1 - Collecting Personal Information 1.1 Unless the purposes for collecting personal information are obvious and the clients voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. 1.2 We will only collect clients information that is necessary to fulfill the following purposes: verify identity, creditworthiness, and credit card processing. As well, as in order for EL APOSTOL (Canada) to deliver the requested services and contact our clients for fundraising, and meet regulatory requirements. Policy 2 - Consent 2.1 We will obtain clients consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent). 2.2 Consent can be provided orally, in writing, electronically, through an authorized representative, or it can be implied where the purpose for collecting using or disclosing the p ersonal information would be considered obvious and the clients voluntarily provides personal information for that purpose. 2.3 Consent may also be implied where a clients is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising, and the clients does not opt-out. 2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for EL APOSTOL (Canada) to use their personal information in certain ways. A clients decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the clients in making the decision. 2.5 We may collect, use or disclose personal information without the clients knowledge or consent in the following limited circumstances: When the collection, use or disclosure of personal information is permitted or required by law; In an emergency that threatens an individual's life, health, or personal security; When the personal information is available from a public source (e.g., a telephone directory); When we require legal advice from a lawyer; For the purposes of collecting a debt; When we require legal advice from a lawyer; When we require legal advice from a lawyer; To protect ourselves from fraud; To investigate an anticipated breach of an agreement or a contravention of law. Policy 3 - Using and Disclosing Personal Information 3.1 We will only use or disclose clients personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as: When the collection, use or disclosure of personal information is permitted or required by law; In an emergency that threatens an individual's life, health, or personal security. 3.2 We will not use or disclose clients personal information for any additional purpose unless we obtain consent to do so. 3.3 We will not sell clients lists or personal information to other parties Policy 4 - Retaining Personal Information 4.1 If we use clients personal information to make a decision that directly affects the clients we will retain that personal information for at least one year so that the clients has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain clients personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose. Policy 5 - Ensuring Accuracy of Personal Information 5.1 We will make reasonable efforts to ensure that clients personal information is accurate and complete where it may be used to make a decision about the clients or disclosed to another organization. 5.2 clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer EL APOSTOL 5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients correction request in the file. Policy 6 - Securing Personal Information 6.1 We are committed to ensuring the security of clients personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 6.2 The following security measures will be followed to ensure that clients personal information is appropriately protected: by the use of locked filing cabinets; Physically securing offices where personal information is held; The use of user IDs, passwords, encryption, firewalls; Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); Contractually requiring any service providers to provide comparable security measures; Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access). 6.3 We will use appropriate security measures when destroying clients personal information such as: Shredding documents, deleting electronically stored information. 6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security. Policy 7 - Providing Clients, Customers, Members Access to Personal Information 7.1 clients have a right to access their personal information, subject to limited exceptions. for example solicitor-client privilege, disclosure would reveal personal information about another individual, or health and safety concerns 7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer EL APOSTOL 7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable. 7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. 7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the clients of the cost and request further direction from the clients on whether or not we should proceed with the request. 7.6 If a request is refused in full or in part, we will notify the clients in writing, providing the reasons for refusal and the recourse available to the clients . Policy 8 - Questions and Complaints: The Role of the Privacy Officer 8.1 The Privacy Officer EL APOSTOL is responsible for ensuring EL APOSTOL (Canada) compliance with this policy and the Personal Information Protection Act. 8.2 clients should direct any complaints, concerns or questions regarding EL APOSTOL (Canada) compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the clients may also write to the Information and Privacy Commissioner of British Columbia. Contact information for EL APOSTOL (Canada) Privacy Officer EL APOSTOL: Name: EL APOSTOL Telephone: 604-771-4159 Mail Address 107 - 141 E. 21st Street North Vancouver, BC Canada V7L 3B5 Email Address el@elapostol.com