GENERAL PRIVACY POLICY

BlueSun is committed to maintaining the privacy of individuals and protecting personal information in its custody or control in accordance with privacy legislation applicable to BlueSun.

Application

This Policy describes and summarizes the practices of BlueSun and its affiliates with respect to our collection, use and/or disclosure of personal information related to all individuals other than employees and individual contractors of BlueSun; those individuals are subject to a separate policy. Employees of BlueSun dealing with personal information are expected to be familiar with this Policy.

Definitions

In this Policy, the following terms have the meanings below:

Personal information means information about an identifiable individual, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified. Personal Information also does not include business contact information, as long as business contact information is used to contact an individual in their capacity as an employee or official of an organization, and for no other purpose. Information about a corporation, firm, trust, union or other non-individual entity is not personal information.

Business contact information means an individual's name and position or title as an official or employee of an organization, as well as their business telephone number, business address, business e-mail, business fax number and other business contact information.

Privacy and our Website

We do not collect any personal information from individuals who simply visit our website. However, individuals should be aware that most web servers do collect some information about visitors, such as the browser and version being used, the operating system, and the "IP" or internet address of the visitor, which may identify the individual's Internet Service Provider or computer but not necessarily the individual using it.

BlueSun's website server also uses cookies, which are small text files containing information sent to the computer of a visitor to our website. Cookies are used to help our web server track such things as user preferences that the user may submit in order to make the website more interactive with the user and more responsive to their preferences. Information stored in cookies is used to pre-populate form fields and to remember user preference. This is done for user convenience as well as to provide us with information on which parts of our website are being viewed and by how many visitors. The tracking process is anonymous and no personal information is used.

Third Party Websites

Please note that our website may contain links to other websites which are provided as a convenience for visitors to our website only. Any third party websites will have their own privacy policies and practices, and we cannot be responsible for such third parties, their websites, or their privacy practices.

Why we collect, use and disclose personal information

BlueSun generally collects, uses and discloses personal information for the following purposes:

  1. Customers, employees of and contractors to customers: To establish, maintain, manage and terminate a relationship with a customer.
  2. Prospective or potential customers or their employees: To attempt to establish a relationship with a customer.
  3. Subscribers to BlueSun newsletters, white papers or similar types of information: To provide services, information or documentation and to solicit business.
  4. Suppliers (including non-individual contractors to BlueSun), employees of and contractors to suppliers: To establish, maintain, manage and terminate a supplier relationship.
  5. Individuals who may voluntarily choose to provide BlueSun with personal information: To fulfill the purposes for which such information was provided.
  6. BlueSun employees and individual contractors: To recruit, establish, maintain, manage and terminate an employment or individual contractor relationship. For further information, BlueSun's Employee Privacy Policy should be consulted.
  7. Shareholders and investors: To manage our relationship with and our obligations to investors and shareholders. BlueSun is required by applicable laws and regulatory authorities to collect, as well as use and disclose certain information with respect to its shareholders.
  8. Directors and officers: To manage our relationship with and our obligations to directors and officers. BlueSun is required by applicable laws and regulatory authorities to collect, as well as to use and disclose, certain information with respect to its directors and officers.
  9. Other individuals: Personal information from other individuals may be collected, used or disclosed when such individuals contact BlueSun for a variety of reasons personal to them. For example, if an individual contacts us with an inquiry, we will use the information provided to assist us in responding to that individual and communicating with them. Generally, such information is used to contact or reply to individuals who have contacted us where such contact or reply is reasonable in the circumstances, or is subject to deemed consent, or is legally required.
  10. To fulfill our legal obligations.

Disclosure of personal information

BlueSun does not disclose, trade or sell its customer or contact lists. It is the general policy of BlueSun to not disclose personal information in its custody or control except with the consent of the individual and then only for identified purposes. However, individuals should be aware that there are exceptions to the above.

Ontario law permits us to collect, use or disclose personal information about an individual in some circumstances without the individual's consent and/or knowledge. Such circumstances include (but are not limited) to where:

  1. the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
  2. collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
  3. the personal information is available to the public from a prescribed source; or
  4. the collection, use, or disclosure is required or authorized by a statute or regulation of Ontario or Canada.

BlueSun will in all cases disclose personal information as required or permitted by applicable law.

BlueSun does not disclose, trade or sell its customer or contact lists.

Security

We recognize our legal obligations to protect the personal information we have gathered about individuals. We have therefore made arrangements to secure against unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information. These arrangements may include physical security measures, network security measures, and organizational measures such as non-disclosure agreements and need-to-know access.

Contacting BlueSun

If you have any questions with respect to our policies concerning the collection, use, disclosure or handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, or if you are dissatisfied with how we handle your personal information, please contact our Privacy Contact, Jenn McLean, at:

Jenn.mclean@bluesunlife.com OR 905-333-3353 ext. 214.

If you remain dissatisfied after our Privacy Contact has reviewed and responded to your concern, or have other concerns or questions, you have the right at any time to contact the Office of the Information and Privacy Commissioner at:

Mail

Information and Privacy Commissioner/Ontario

2 Bloor Street East, Suite 1400

Toronto, Ontario M4W 1A8

Canada

Telephone

Toronto Area: 416-326-3333

Long Distance: 1-800-387-0073 (within Ontario)

TDD/TTY: 416-325-7539

Fax
416-325-9195