This version in effect since March 1, 2011

In this Privacy Policy, “Thrive”, “we”, “us” and “our” means the operations of Jackman BrandMarketing Inc.

We recognize the importance of an individual’s right to keep personally identifiable information private. This Privacy Policy (“Policy”) explains how we manage and safeguard personal information in the course of operating our business. We are committed to protecting such privacy through ensuring that all personal information provided to THRIVE is treated with care and, subject to this Policy, is not used or disclosed in ways to which consent has not been given by the disclosing individual. Thrive keeps all company business data secure and does not share any company data with any third party. Thrive does not share any personal information with third parties except as disclosed in this Policy and with the customer’s consent. Client business data is not shared. We are dedicated to adhering to the following principles that relate to the collection, use, retention and disclosure of personal information in Canada. These principles are based on Canada’s Personal Information Protection and Electronic Documents Act, in effect since January 1, 2004.

ACCOUNTABILITY

Thrive is accountable for all personal information in its control. This includes information under the direct control of Thrive, as well as personal information that Thrive may transfer to third party service providers for purposes that facilitate Thrive’s business operations. Thrive will use contractual or other measures to require third parties that process information or provide services on our behalf, such as credit account verification and similar confirmations, to maintain a level of privacy protection comparable to our own practices.
Thrive has a designated Privacy Officer who is ultimately accountable for the handling of all personal information under the control of Thrive and for ensuring that the principles set out in this Policy Statement are being complied with. Any questions with regard to the manner in which Thrive handles or manages personal information should be directed to our Privacy Officer who can be reached as follows:

Privacy Officer
Jackman BrandMarketing
PO Box 8303, Stn A
St. John’s, NL
A1B 3N7
privacyofficer@jackmanbrandmarketing.com

COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

In order for the Thrive application to fulfill its purpose, client business data must be collected and used by the application. This data resides within the application database and is disclosed only to client personnel to whom the client provides the userid and password for the client’s access to the application and to Thrive personnel for the sole purpose of providing support to the client. Business data is not disclosed to any third parties. We collect information from individuals solely for the operation of our software, and only that information which we need to provide our customary high level of service. We may use and disclose the personal information we collect from our customers and other individuals to manage our relationship with such individuals, to administer accounts, to provide business services and carry on our business operations and as may otherwise be required or permitted by law. For example, we may use personal information to provide customers with information about upcoming software advances or marketing opportunities related to our products. We also analyze information about our customers to determine their preferences and to help us ensure that we are providing our customers with the types of services that they are looking for. In providing some of these services, we may hire outside service providers located in Canada, the United States or elsewhere to act on our behalf. In these instances, we will only transfer personal information to these organizations as is necessary for them to perform their services. We also ensure that these organizations have agreed to keep your information protected in a manner consistent with this Policy and that they agree to not use this information for any other purpose. Whenever collecting personal information for any other purpose, Thrive will disclose the purpose(s) for which the information is being collected, the manner in which Thrive plans to use the information and the entities to which the information will be disclosed. We do not collect personal information that is not necessary for the purposes we identify. We will not refuse to provide a service to an individual if they choose not to provide us with their personal information, unless their failure to provide such information makes us unable to provide such service.

OBTAINING CONSENT

In most cases, consent to the collection and use of personal information will be implied through the provision to Thrive, by a customer or other individual, of any and all information required for Thrive to provide its business services effectively. Such consent will also be implied when personal information is provided by customers through our software. Thrive will notify and obtain the consent of the individual to whom the information relates only before collecting, using or disclosing personal information out of the ordinary course of business. If we choose to use personal information already in our custody for a purpose that was not identified at the time we initially collected the information, we will seek the consent of the affected individuals before using this information for the new purpose, unless obtaining such consent is not required by law in the specific circumstances. Individuals may withdraw consent to the collection, use and disclosure of their personal information at any certain time, subject to any legal restrictions and reasonable notice. Note, however, that such withdrawal may make it impossible for Thrive to provide certain services to such individuals. Customers can contact our Privacy Officer to express their intention to withdraw their consent.

MANAGEMENT OF PERSONAL INFORMATION

Thrive has instituted policies and procedures as to how long it retains information that it collects. Personal information that is no longer required to fulfill the purposes identified when the information was collected is either destroyed, erased or rendered anonymous to prevent unauthorized parties from gaining access to the information. Thrive has implemented security safeguards to protect personal information in our control against loss, theft, misuse and interception by third parties. These safeguards include organizational, technical and physical measures designed to protect information from unauthorized access, disclosure, copying, use or modification.

Among the steps taken are:
Premises security;
Restricted file access to personal information;
Technology safeguards, including security software, firewalls to prevent hacking and other unauthorized computer access; and internal password and security policies.

If requested, Thrive will make available certain information about our policies and practices relating to the management of personal information. Any such requests should be sent to our Privacy Officer who can be contacted as set out above.

ACCURACY AND CURRENCY OF PERSONAL INFORMATION

Thrive is committed to open and fair privacy practices which comply with the Personal Information Protection and Electronic Documents Act as well as any other applicable legislation. Any individual may request access to the individual’s personal information that Thrive has in its custody by contacting Thrive’s Privacy Officer in writing. After receiving such a request, our Privacy Officer shall inform the individual of the existence, use and disclosure of their personal information and shall allow the individual to access such information. If the Privacy Officer cannot provide the individual with a list of the actual disclosures, he or she will provide the individual with a list of organizations to which THRIVE may have disclosed their personal information. In certain circumstances, access to personal information may be denied. If we deny an individual’s request for access to their personal information, we will advise such individual in writing of the reason for the refusal and they may then challenge our decision. Where personal information is used on an on-going basis, Thrive undertakes to correct any information that is shown to be inaccurate, incomplete or not up to date. Otherwise, Thrive does not routinely update personal information unless it is necessary to fulfill the purposes for which the information is collected. Thrive must be advised, by the individual to whom the information relates, of any correction to be made to their personal information. The Privacy Officer will take steps to ensure that this information is corrected. Upon notification from an individual of their desire to have any or all of their personal information in our records deleted or destroyed, Thrive may undertake to delete or destroy all such information to the extent that retention of such information is not required by law, or for any other lawful business purpose, such as the investigation of claims or the defense of an action. In the event that an individual wishes to challenge Thrive’s compliance with any of these principles, they can contact Thrive’s Privacy Officer using the contact information set out above. All complaints will be investigated. If Thrive finds a complaint to be justified, appropriate measures will be taken, including, if necessary, amending our policies and practices. If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at 112 Kent Street, Ottawa, ON K1A 1H3, 1-800-282-1376.

All policies and procedures of Thrive are reviewed periodically and, as such, we may change this Policy from time to time.