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Privacy Policy

1.0 PURPOSE

1.1 SPMA INC. recognizes the importance of privacy and the risk of the unauthorized use or disclosure of personal information that comes into the possession or control of SPMA INC. from the use by users of the interactive community hub function of the SPMA INC. website.

1.2 SPMA INC. further recognizes the necessity to design and implement measures for the security of personal information that comes into the possession or control of SPMA INC. from the use by users of the interactive community hub function of the SPMA INC. website.

1.3 The purpose of this Website Privacy Policy is to describe the types of personal information collected from users using the interactive community hub function of the SPMA INC. website, how such information is used and the measures taken by SPMA INC. to ensure its privacy and security.

2.0 DEFINITIONS

2.1 In this Website Privacy Policy, unless otherwise stated, the following terms shall have the meaning prescribed for each:

“Personal Information” means all information about an identifiable individual provided or otherwise collected by the interactive community hub function of the SPMA INC. Website. Personal information includes all information about an identifiable person as defined under the Personal Information Protection and Electronic Documents Act SC 2000, c 5 and includes for purposes of this Website Privacy Policy the person’s home address, email address, telephone number, credit card information and account password.

“Website” means the set of interconnected web pages designed and developed by SPMA INC. which includes an interactive function for the online purchase of products.

3.0 APPLICABILITY

3.1 This Website Privacy Policy applies to SPMA INC. and users accessing the interactive community hub function of the SPMA INC. Website. It describes the technology and procedures of SPMA INC. in offering its products and services to users accessing the interactive function of the Website to ensure the privacy and security of their Personal Information.

4.0 POLICY

4.1 SPMA INC. is committed to ensuring the privacy and security of Personal Information and to meeting its obligations under all applicable Canadian privacy legislation.

4.2 SPMA INC. is committed to collecting, using and disclosing Personal Information provided by users through the interactive community hub function of the SPMA INC. Website only for reasonable and bona fide business-related purposes.

4.3 SPMA INC. is committed to taking all reasonable steps to ensure the continuing privacy and security of all Personal Information provided by users through the interactive community hub function of the SPMA INC. Website.

4.4 SPMA INC. has established the position of Privacy Officer, responsible for the development and implementation of all necessary rules and procedures for the collection, use, disclosure and retention of Personal Information, including Personal Information provided by users through the interactive community hub function of the SPMA INC. Website. The Privacy Officer shall ensure compliance with this Website Privacy Policy and all applicable privacy legislation.

5.0 PRIVACY STANDARDS

5.1 Personal Information of users disclosed through their use of the interactive community hub function of the SPMA INC. Website shall be collected, used and disclosed by SPMA INC. only for reasonable, business-related purposes, and in accordance with the following privacy principles:

5.1.1 Consent.

(a) Express consent is required for the collection, use and disclosure of Personal Information. Customer consent to use Personal Information disclosed through their use of the interactive community hub function of the Website is implied for the purposes of undertaking the purchase of products from SPMA INC. and other reasonably expected business-related purposes.

(b) SPMA INC. may use and disclose Personal Information provided by users through the interactive community hub function of the SPMA INC. website, without consent, for compliance with any applicable law, regulation, or the order of any court or other lawfully constituted authority.

5.1.2 Limiting Collection. The collection of Personal Information from users through the interactive community hub function of the Website will be restricted to that required by the SPMA INC. to undertake the business-related purposes for which it was provided and for SPMA INC. to meet its legal obligations.

5.1.3 Limiting the Use, Disclosure, and Retention of Personal Information. Personal Information collected from users through the interactive community hub function of the Website will be used, disclosed and retained only for undertaking the purchase of products from SPMA INC. and other reasonably expected business-related purposes, or for compliance with any applicable law, regulation, or order of any court or other lawfully constituted authority.

5.1.4 Security of Personal Information. SPMA INC. will take all commercially reasonable steps to protect Personal Information from unauthorized access, use or disclosure. Reasonable steps include physical, electronic and procedural measures appropriate to the level of sensitivity of the Personal Information.

5.1.5 Access to Personal Information.

(a) Users may access their Personal Information provided through the interactive community hub function of the Website to confirm its accuracy or completeness or to update their Personal Information, by contacting the Privacy Officer.

(b) SPMA INC. will correct or update any Personal Information upon request.

(c) SPMA INC. reserves the right to charge a customer requesting access to their Personal Information a reasonable fee for doing so where the costs of providing access are significant.

5.1.6 Response to Inquiries and Complaints. The Privacy Officer will investigate and respond to all customer complaints in regard to the treatment of their Personal Information at the earliest opportunity. If the complaint is found to be justified, the Privacy Officer will so inform the customer and ensure that appropriate corrective measures are taken.

6.0 CONTACT

6.1 Questions concerning this policy should be brought to the attention of the administration.

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