Artez Interactive Privacy Policy

Last updated November 25th, 2009

General Privacy Statement

ARTEZ INTERACTIVE INC. respects your right to privacy and is committed to protect the personal information you provide to us. Your personal information will only be used for the purpose we have identified when obtaining the information. ARTEZ INTERACTIVE uses the information collected through its Internet-based tools to facilitate the processing of donations, to provide tax receipts, and processing online event registrations. ARTEZ INTERACTIVE does not trade or sell your personal information.

I. Introduction

ARTEZ INTERACTIVE is committed to protecting and safeguarding the privacy and security of the personal information provided to us by our clients' donors, volunteers, constituents and others. Our policy complies with the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and the 10 basic principles set out in the Canadian Standards Association Model Code for the Protection of Personal Information. By becoming a member, requesting information, or registering for events on websites we empower, an individual is giving ARTEZ INTERACTIVE permission to contact him or her by way of the information provided. During the course of servicing the needs of registrants, donors, constituents and others we may gather personal information. This policy explains why we may need your personal information, how the confidentiality of this information is protected, and how you can find out what information concerning you is recorded.

II. Personal Information

Personal information is defined as any information that can be used to distinguish, identify or contact a specific individual that pertains to the use of Internet-based tools to facilitate the processing of donations and registrations online and credit card information. Personal information does not include business contact information (with the exception of email addresses which are considered personal information) and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories (i.e. information on a business card). Most of the information ARTEZ INTERACTIVE collects is not personal information. Where an individual uses his or her home contact information as business contact information as well, ARTEZ INTERACTIVE considers that the contact information provided is business contact information and is therefore not subject to protection as personal information.

III. Privacy Practices

ARTEZ INTERACTIVE adheres to the following privacy practices:

• Personal information gathered by ARTEZ INTERACTIVE is held in the strictest confidence and is protected by industry standard best practices.
• ARTEZ INTERACTIVE collects information for expressly identified purposes.
• Safeguards are in place to ensure that the information is disclosed only on a need to know basis and only for the purpose for which it was gathered.
• No more than the minimum required amount of personal information will be collected in the course of providing any service.
• Users have the right to opt out of providing certain information recognizing that in doing so, the purpose may then not be fulfilled or ARTEZ INTERACTIVE may not be able to provide certain services that have Personal Information dependencies.
• ARTEZ INTERACTIVE will advise users accessing our products and services of our Privacy Policy;
o at the time they register, or access a product or service as appropriate
o on the website in the form of an online privacy statement

IV. ARTEZ INTERACTIVE Application Websites
1. Anonymous Non-Personal Information

When our clients' donors, volunteers, and other constituents access the secure section of our website, anonymous, non personal information about their visit is automatically collected. Such information may include the length and date of the visit, how the visitor navigated the Website, what pages the visitor viewed, the type of browser being used by the visitor, the type of operating system used by the visitor and the domain name of the visitor's Internet service provider. This information is used, in aggregate form, to provide statistical measures about usage of our site. This allows us to continually improve the functionality, content and design of websites we empower. This Anonymous Non-Personal Information may be shared with other parties, such as sponsors and partners.

2. Cookie-based Information
When our clients' donors, volunteers, and other constituents access the secure section of our website, a small text file called a "cookie" is sent from our web server to their web browser and is stored on their computer. Cookies allow us to recognize you while you are logged into the ARTEZ INTERACTIVE website and expire when you close your browser window. The ARTEZ INTERACTIVE websites contains links to other websites owned and operated by external parties. ARTEZ INTERACTIVE is not responsible for the content or privacy practices of such sites.

V. Ten Basic Privacy Principles

ARTEZ INTERACTIVE is committed to the following ten basic privacy principles:

1. Accountability
a. ARTEZ INTERACTIVE is responsible for personal information under our control and we have designated a Privacy Officer who is accountable for ARTEZ INTERACTIVE'S compliance with PIPEDA. There are other individuals within ARTEZ INTERACTIVE who are designated with the responsibility for day to day collection and management of personal information.
b. ARTEZ INTERACTIVE has policies and procedures in place to implement and comply with this Privacy Policy, including procedures relating to the collection, handling, storage and destruction of personal information.
c. ARTEZ INTERACTIVE is responsible for personal information transferred by us to third parties, if any, for processing on our behalf. ARTEZ INTERACTIVE uses contractual means to provide an appropriate level of protection for such transferred information. Third parties entering into a business relationship with ARTEZ INTERACTIVE are required to adhere to these privacy principles, this privacy policy, the Act and any other applicable law dealing with the protection of personal information.

2. Identifying Purposes
a. ARTEZ INTERACTIVE identifies the purposes for which personal information is being collected at the time of such collection.
b. Generally, ARTEZ INTERACTIVE collects personal information for the following purposes:
i. When you register online for ARTEZ INTERACTIVE'S clients' events, campaigns, etc.
ii. When you make an online donation.
iii. To facilitate commercial transactions. (ie purchases)
iv. To provide members access to secure area of ARTEZ INTERACTIVE empowered sites.
v. To register members and non-members for ARTEZ INTERACTIVE events.
vi. To communicate and provide information about ARTEZ INTERACTIVE - empowered client events, member benefits, programs, services and other opportunities.
vii. To provide tax receipts.
When a client contracts with ARTEZ INTERACTIVE to develop an online application for its use, the client owns all data that is collected relevant to its events, campaigns and other online initiatives for which ARTEZ INTERACTIVE is facilitating data collection. Often ARTEZ INTERACTIVE clients use this data to communicate directly with you, as a member of its constituent base. The ARTEZ INTERACTIVE data passed on to its clients identifies which of its users have opted in for a permission-based relationship with ARTEZ INTERACTIVE clients. ARTEZ INTERACTIVE may use personal account information and data collected through your registration and / or donation to generate statistics and aggregate reports for internal use
and for sharing with clients and partners. These reports will not contain any information that could identify you personally.

3. Consent
a. ARTEZ INTERACTIVE collects personal information by fair and lawful means and obtains the individual's consent for the collection, use or disclosure of his or her personal information as required by PIPEDA or by other applicable law.
b. The consent may be expressed, implied or given through an authorized representative.
By visiting and using this website, the visitor agrees to the Privacy Policy and the terms of use linked to this Privacy Policy. If you do not agree to the Privacy Policy do not use this Website or provide Personal Information to ARTEZ INTERACTIVE.
c. A user may withdraw consent to use his or her personal information at any time, subject to any legal or contractual restrictions upon giving ARTEZ INTERACTIVE reasonable notice. ARTEZ INTERACTIVE will inform individuals of the implications, if any, of withdrawing consent and how to do so.

4. Limiting Collection
ARTEZ INTERACTIVE limits the collection of personal information to that which is reasonably necessary for the identified purpose(s).

5. Limiting Use, Disclosure and Retention
a. ARTEZ INTERACTIVE does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual, or as permitted or required by law.
b. ARTEZ INTERACTIVE retains personal information only as long as is necessary for the fulfillment of those purposes or as required by law.
c. ARTEZ INTERACTIVE does not disclose credit card account information provided by users except to the appropriate banking institutions and/or clearinghouses in order to obtain debit authorization and payment. The Client may request personal account information. In that event, ARTEZ INTERACTIVE will only transmit or relinquish this data to any organization (including
the Client itself) that is also accredited by the Payment Card Industry at Level 1 certification.
d. ARTEZ INTERACTIVE reserves the right to change this Privacy Policy at any time. We also reserve the right at any time to disclose any information in an individual's registration and / or donation:
i. to satisfy any law, regulation or government request;
ii. if such disclosure is necessary or appropriate to site operation; or
iii. To protect the rights or property of ARTEZ INTERACTIVE and its users,providers, licensors or merchants.

6. Accuracy
ARTEZ INTERACTIVE takes reasonable steps to keep personal information accurate, complete and up to date as is necessary for the identified purpose(s). Individuals are entitled to check on the accuracy of their personal information and submit a correction request, if necessary. ARTEZ INTERACTIVE will rely exclusively on individuals in determining the completeness, accuracy, and timeliness of his or her personal information and will have no further obligation to seek independent verification of any personal information supplied by the individual.

7. Safeguards
a. ARTEZ INTERACTIVE protects personal information from unauthorized access, use and disclosure by establishing and maintaining appropriate security safeguards. All safety and security measures are appropriate to the sensitivity level of the information.
b. ARTEZ INTERACTIVE has implemented safeguards to protect against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction of personal information. All ARTEZ INTERACTIVE staff are made aware of the need to maintain strict confidentiality of all personal information.

8. Openness
a. ARTEZ INTERACTIVE makes information readily available about our policies and practices related to the management of personal information.
b. ARTEZ INTERACTIVE's Privacy Policy is posted on our website and those of users of our product and services about the type of personal information we may collect, what it is used for and to whom the information may be disclosed.

9. Individual Access
a. Upon request ARTEZ INTERACTIVE provides users with access to their personal information. Requests are to be directed to our Privacy Officer:

Artez Interactive
215 Spadina Avenue
Suite 500
Toronto, Ontario, Canada
M5T 2C7

b. Upon request ARTEZ INTERACTIVE will inform users whether their personal information has been disclosed to any authorized third parties.
c. ARTEZ INTERACTIVE will make every effort to respond to requests for access to donor or registrant personal information within 30 days.

10. Challenging Compliance
Any questions, requests or complaints with respect to this Privacy Policy or about our privacy practices may be directed to our Privacy Officer (see 9.a above for contact information).

VI. Changes to Privacy Policy

ARTEZ INTERACTIVE regularly reviews its privacy practices and updates its Privacy Policy as required. We recommend that you check this policy periodically so that you are aware of any
changes.