Committed to Protecting Your Privacy

Shell Busey's HouseSmart Referral Network Privacy Pledge

Shell Busey's HouseSmart Referral Network, recognizes that your trust is fundamental to the value of the referral network for you as a customer.

Protecting the privacy and confidentiality of your personal information has always been a fundamental principle in our relationship with you, and our referral member companies. This Privacy Pledge tells you how we will ensure the confidentiality and privacy of the information that you entrust us with.

Introduction

Shell Busey's HouseSmart Referral Network, is demonstrating its commitment to protecting the privacy of Customers' Personal Information by developing and implementing this Privacy Commitment to the Protection of Customer Information.

Shell Busey's HouseSmart Referral Network complies with or exceeds the federal Personal Information Protection and Electronic Documents Act and applicable provincial privacy laws.

Shell Busey's HouseSmart Referral Network Privacy Commitment applies to the collection, storage, use, disclosure, protection, and accuracy of Personal Information collected and controlled by Shell Busey's HouseSmart Referral Network.

Inquiries about Shell Busey's HouseSmart Referral Network privacy policies can be made by writing to: Attention Privacy Office, Shell Busey's HouseSmart Referral Network, #7, 2230 King George Highway, Surrey, BC, V4A 5A5, by email to privacyoffice@housesmartcentre.com or by calling the Shell Busey's HouseSmart Referral Network (604-542-2236).

THE PRINCIPLES

Principle 1: Accountability

An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.

The Marketing Manager of Shell Busey's HouseSmart Referral Network is accountable for company's compliance with the Privacy Commitment.

The Marketing Manager of Shell Busey's HouseSmart Referral Network has established procedures to implement the Privacy Commitment, including:

• procedures to protect Personal Information;
• procedures to receive and respond to complaints and inquiries;
• communications and training programs to provide information to Shell Busey's HouseSmart Referral Network staff about privacy policies and practices.

Principle 2: Identifying Purposes

The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

Shell Busey's HouseSmart Referral Network collects personal information for two primary purposes: to forward the customer contact information on to referral member companies based on the customer's indicated product or service need(s) with the customer's permission; and for the purpose of distributing a free home improvement newsletter to members of Shell Busey's HouseSmart Club who have indicated a desire to receive the newsletter.

Principle 3: Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Consent for the collection of personal information can be either express of implied. Express consent is either given verbally or in writing - e.g. on the Shell Busey HouseSmart Club sign-up form. Consent is implied when it can be reasonably understood by the referral request of the customer. For example, if the customer requests a referral, then Shell Busey's HouseSmart Referral Network assumes that the customer has given consent to the collection of the transaction information required to fulfill specified purposes (such as making a referral to a referral member company).

Principle 4: Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Shell Busey's HouseSmart Referral Network does not collect Personal Information indiscriminately. Both the amount and the type of Personal Information collected are limited to that which is necessary to fulfill the purposes identified - e.g. for the specific referral requested or the information necessary to receive Shell Busey's HouseSmart Club home improvement newsletter.

Principle 5: Limiting Use, Disclosure, and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Shell Busey's HouseSmart Referral Network does not use or disclose Personal Information for purposes other than those for which it is collected. Shell Busey's HouseSmart Referral Network retains Personal Information only as long as necessary for the fulfillment of those purposes.

Shell Busey's HouseSmart Referral Network does not give, rent, or sell customer information from Shell Busey's HouseSmart Club members to any organization or individual other than the referral network member to which the referral was initiated.

Principle 6: Accuracy

Personal Information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Shell Busey's HouseSmart Referral Network keeps Personal Information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

Principle 7: Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Shell Busey's HouseSmart Referral Network protects Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information. Shell Busey's HouseSmart Referral Network protects Personal Information regardless of the format in which it is held.

The methods of protection for Personal Information include:

a. physical measures, for example, locked filing cabinets and restricted access to offices;

b. organizational measures, for example, employee confidentiality agreements, security clearances and limiting access on a need-to-know basis; and

c. technological measures, for example, the use of passwords and encryption.

Principle 8: Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Shell Busey's HouseSmart Referral Network makes specific information about its policies and practices relating to the management of Personal Information readily available to customers.

Shell Busey's HouseSmart Referral Network is open about its policies and practices with respect to the management of Personal Information.

Principle 9: Individual Access

Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Customers can request access to their Personal Information held by the Shell Busey's HouseSmart Referral Network by writing to: Attention Privacy Office, Shell Busey's HouseSmart Referral Network, #7, 2230 King George Highway, Surrey, BC, V4A 5A5, by email to privacyoffice@housesmartcentre.com or by calling the Shell Busey's HouseSmart Referral Network (604-542-2236).

Upon request, Shell Busey's HouseSmart Referral Network informs the customer whether or not it holds Personal Information about that customer, and discloses details of that Customer's Personal Information, including, where available, the source type and its use.

Shell Busey's HouseSmart Referral Network responds to a request for information within thirty (30) business days of receipt of request.

Principle 10: Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.

Shell Busey's HouseSmart Referral Network has procedures in place to receive and respond to inquiries about Shell Busey's HouseSmart Referral Network policies and practices relating to its handling of Personal Information.

Inquiries about Shell Busey's HouseSmart Referral Network privacy policies can be made by writing to: Attention Privacy Office, Shell Busey's HouseSmart Referral Network, #7, 2230 King George Highway, Surrey, BC, V4A 5A5, by email to privacyoffice@housesmartcentre.com or by calling the Shell Busey's HouseSmart Referral Network (604-542-2236).

Shell Busey's HouseSmart Referral Network investigates all complaints and responds within ninety (90) business days after receipt of written correspondence. If the complaint is found to be justified, Shell Busey's HouseSmart Referral Network will take appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.