EYESPYU PRIVACY PHILOSOPHY
EyeSpyU Ltd. (“EyeSpyU”) is committed to fairly and lawfully collecting and maintaining accurate personal information and to protecting the confidentiality of all personal information that we collect, retain, use or disclose to others in the course of our business activities.

OUR CONTINUING COMMITMENT TO YOU
Protecting the privacy and confidentiality of personal information has always been fundamental to the way we do business at EyeSpyU. We strive to meet or exceed all the privacy standards established by federal, provincial and industry authorities in all our dealings with past, current and prospective customers. EyeSpyU acknowledges that it is responsible for personal information under its control and has designated Privacy Officer, who is accountable for EyeSpyU’s compliance with the following principles.

WHAT IS PERSONAL INFORMATION?
Personal information is information that identifies you as an individual. It includes your name and address, age and gender, also your personal financial records, identification numbers including your social insurance number, personal health information, personal references, and employment records.

WHAT IS IN THIS CODE?
This Privacy Code has been developed to meet the standards set out in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and similar provincial legislation. The Privacy Code describes the principles EyeSpyU will use to protect the privacy of personal information we possess about our clients, including sole proprietors and individuals carrying on business in a partnership, and establishes ethical and fair information management practices with respect to personal information collected, used or disclosed by EyeSpyU. The Code informs customers how personal information is handled within EyeSpyU.

APPLICATION OF THIS CODE
This Privacy Code applies to all EyeSpyU directors, officers, and employees with respect to any personal information in the possession or control of EyeSpyU.
This Privacy Code does not apply to information about business customers carrying on business as corporations, partnerships or in other forms of association. The confidentiality of information with respect to those entities is protected at EyeSpyU by our adherence to the applicable laws, our contracts with our business customers, and EyeSpyU’s other internal policies.

EYESPYU’S RELATIONSHIPS WITH OTHER THIRD PARTY SERVICE PROVIDERS
EyeSpyU is in the business of providing investigative services to its customers. We do not sell or license your personal information to any other party. However, in the normal course of business we may share some of your personal information with our affiliates and with third parties acting on our behalf or as permitted or required by Applicable Privacy Laws.
We may use third party service providers (for example, web hosting providers, data management providers and/or payment processers) to manage one of more aspects of our business operations, including the processing or handing of personal information. When we do use an outside company, we use contractual or other appropriate means to ensure that your personal information is used in a manner that is consistent with this Policy.
By registering for a for-fee service and providing your credit card details, EyeSpyU will use the credit card information you provide to bill you for goods and services. By providing your credit card details to us, you consent to and authorize us to provide your credit card details to payment processors and financial institutions necessary to process your payment.
To provide increased availability of the Website, some of these operations may result in personal information collected by EyeSpyU being stored outside Canada and, as a result, such personal information stored outside of Canada may be accessible to law enforcement and regulatory authorities in accordance with applicable laws of countries outside Canada.

THE REASONABLE PERSON APPROACH
PIPEDA is really about sound information management practices. It requires an ethical, common sense, “reasonable person” approach to requesting, validating and maintaining personal information as a part of our business activities. Confidentiality is a sensitive topic. Many Canadians have raised concerns about the privacy of their personal information. Within EyeSpyU we strive to understand what customers, clients and investors deem to be reasonable and then apply the principles in this Code.

EYESPYU’S PRIVACY PRINCIPLES
EyeSpyU endorses and has adopted the ten privacy principals set out in full in Schedule 1 of PIPEDA. These ten privacy principles summarized below, embody sound and prudent information management practices. These practices will provide the necessary assurances that personal information obtained and utilized by EyeSpyU in the course of its business activities will be accurate, held in confidence and be retained in a secure environment.
Principle 1: Accountability
EyeSpyU takes responsibility for protecting and maintaining personal information under its control and has appointed a Privacy Officer to ensure compliance with these principles and PIPEDA.
Principle 2: Identifying the Purposes for Collecting Personal Information
EyeSpyU will identify and disclose the reasons for which personal information is collected and used by EyeSpyU at or before the time the information is collected.
Principle 3: Consent
EyeSpyU will obtain an individual’s informed consent for the collection, use or disclosure of personal information by EyeSpyU, except as otherwise required or permitted by law.
Principle 4: Limits to the Collection of Personal Information
EyeSpyU will limit the amount and type of personal information collected to that, which is necessary for its intended purposes. Personal information will be collected by fair and lawful means.
Principle 5: Limits to the Use, Disclosure and Retention of Personal Information
EyeSpyU will 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 required or permitted by law. Personal information will be retained only as long as it is necessary to fulfill those purposes.
Principle 6: Accuracy
To minimize the possibility of inappropriate information being considered in its decision-making processes, EyeSpyU will keep personal information as accurate, complete, and up-to-date as necessary for its intended purposes.
Principle 7: Safety & Security
EyeSpyU will maintain appropriate safeguards to protect personal information from loss or theft, unauthorized access, disclosure, copying, use or modification regardless of the format in which it is retained.
Principle 8: Openness
EyeSpyU will inform its customers, clients and employees about its policies and procedures regarding the management of personal information. EyeSpyU will ensure that these policies and procedures are easily understood and readily available.
Principle 9: Individual Access
Upon request, EyeSpyU will inform an individual of the existence, use and disclosure of his or her personal information and will provide the individual access to that information to verify and or update its accuracy and completeness.
Principle 10: Handling Inquiries
An individual will be able to direct an issue or concern regarding compliance with the above principles, or EyeSpyU’s practices to EyeSpyU’s Privacy Officer or to other accountable employees.

WHAT INFORMATION DOES EYESPYU COLLECT?
EyeSpyU collects only the information that is needed for or related to the business purpose or product being requested. EyeSpyU is in the business of providing investigative services to its customers. In executing our services we perform searches and seek to and obtain information about the activity, conduct, character and reputation of the client’s spouse or significant other.

WHY AND WHAT TYPE OF INFORMATION IS COLLECTED?
EyeSpyU wants to work with you to help you achieve your goals, to provide you with value-added service on an ongoing basis, and to establish a lasting relationship with you as your needs grow and change. The better EyeSpyU knows you, the better we are able to serve you.
EyeSpyU will make sure you are aware of the purposes for collecting information when you apply for any of our products or services. Self-evident purposes should be clear, but if you have any questions, just ask us. If a new purpose for using your personal information develops, EyeSpyU will ask for your consent again.
EyeSpyU’s website uses “cookies”, a technology that installs a small amount of information on a Website user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website or engage in transactions through the Website.

DISCLOSURE OF PERSONAL INFORMATION OUTSIDE OF EYESPYU
EyeSpyU has a strict policy of not releasing personal information about our customers, subject to the important exceptions discussed below.
The most common reason for release of your personal information is that you have given your consent. Other reasons may include if we have a legal obligation, such as a court order, or if we need to protect assets (e.g. collection of overdue accounts) or the public’s interest. For example, we may release personal information about a customer to legal authorities in cases of criminal activity, or for the detection and prevention of fraud. If we release information for any of these reasons, we keep a record of what, when, why and to whom such information was released.  EyeSpyU does not sell lists of our customers to others for their use.

SHARING YOUR PERSONAL INFORMATION
Your personal information is shared, to the extent permitted by law, and to the extent necessary to provide you with the best service, within EyeSpyU. This sharing is limited to a “need to know” basis.

EXCEPTIONS TO THE “NO COLLECTION, USE OR DISCLOSURE WITHOUT CONSENT” RULES
The limited exceptions, applicable to EyeSpyU, relating to obtaining consent for the collection, use or disclosures of personal information include the following:

COLLECTION
EyeSpyU is authorized by PIPEDA to collect personal information without the knowledge or consent of the individual where:

• collection of the personal information is clearly in the interests of the individual and consent cannot be obtained in a timely manner;
• it is reasonable to expect that collection of the personal information with the knowledge or consent of the individual would compromise the availability or accuracy of the information and the collection is reasonable for purposes of investigating a breach of an agreement or contravention of federal or provincial law; or
• the information is publicly available and is specified by regulations issued by federal legislation.

USE
EyeSpyU is authorized by PIPEDA to use personal information, without the knowledge or consent of the individual, in circumstances including where:

• the personal information was originally collected without consent, express or implied, and collection was clearly in the interests of the individual and consent could not be obtained in a timely manner;
• the information was originally collected without consent, express or implied, in circumstances where collection with the knowledge and consent of the individual would compromise the availability or accuracy of the information and the collection was reasonable for the purposes of investigating a breach of an agreement or a contravention of federal or provincial law;
• EyeSpyU has reasonable grounds to believe the information could be useful in the investigation of a contravention of federal, provincial or foreign law, that has been, is being, or is about to be committed, and the information is used for the purpose of investigating that contravention;
• it is used with respect to an emergency that threatens the life, health or security of an individual;
• it is used for statistical, or scholarly study or research purposes, under limited conditions approved by the Privacy Commissioner; and/or
• the information is publicly available and is specified by the Regulations to PIPEDA.

DISCLOSURE
PIPEDA authorizes EyeSpyU to disclose personal information without the knowledge or consent of the individual in circumstances including if such disclosure:

• is made, within the Province of Quebec, to an advocate or notary or, in any other province, a barrister or solicitor who is representing EyeSpyU;
• is for the purpose of collecting a debt owed by the individual to EyeSpyU;
• is required to comply with a subpoena or warrant issued, or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records;
• is made to a government institute that has identified its lawful authority to obtain the information, and which has indicated (i) it suspects the information relates to national security, the defense of Canada, or the conduct of international affairs, or (ii) disclosure is requested for the enforcement of federal, provincial or foreign law, carrying out an investigation relating to such enforcement, or gathering intelligence for the purpose of such enforcement, or (iii) disclosure is requested for the purpose of administering a federal or provincial law;
• is made to an investigative body or government institution on the initiative of EyeSpyU, and relates to a breach of an agreement or a contravention of federal, provincial or foreign law; or where EyeSpyU suspects the information relates to national security, the defense of Canada or the conduct of international affairs;
• is made because of an emergency that threatens the life, health or security of an individual and EyeSpyU informs the individual without delay of the disclosure; and/or
• is made for statistical or scholarly study and research purposes, under limited conditions, approved by the Privacy Commissioner.

SAFEGUARDING OF PERSONAL INFORMATION
Your personal information is secure within EyeSpyU. We have comprehensive security controls to protect against unauthorized use, alteration, duplication, destruction, disclosure, loss or theft of, or unauthorized access to, your personal information.
EyeSpyU may use other companies to provide services to you on our behalf, such as the printing of correspondence, storage of your files in a secured environment or to conduct customer satisfaction surveys on our behalf. In such cases, we will have contracts in place holding these companies to the same high standards of confidentiality by which we are governed and requiring that any information provided by us must be kept strictly confidential and used only for the purposes of the contract.
EyeSpyU ensures the physical, organizational and electronic security of your personal information through the use of secure locks on filing cabinets and doors, and restricted access to our information processing and storage areas. EyeSpyU limits access to relevant information to authorized employees only, and through the use of pass keys and computer passwords and, where necessary, the encryption of electronically transmitted information.
EyeSpyU has procedures in place when destroying, deleting or disposing of personal information when it is no longer required for the purposes as set out in this Code, or by law, to prevent unauthorized access to such personal information.
Further, for your information, EyeSpyU’s website may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.

RETENTION OF YOUR PERSONAL INFORMATION
EyeSpyU only keeps your personal information for as long as we need it to meet the purposes set out in this Code. The length of time we retain your personal information is also affected by: (1) the type of product or service you have from us, and (2) any legal requirements we may have to meet such as regulatory file retention periods or for being able to respond to any concerns you may have even if you are no longer a customer of ours.

OPT OUT POLICY
You can choose not to provide us with some or all of your personal information. This may, however; severely restrict the products and services EyeSpyU can then provide. You can also withdraw your consent to our use of your personal information, as long as you give us notice in an email to: [email protected]

HOW YOU CAN HELP US PROTECT YOUR PERSONAL INFORMATION
If you wish to review or verify your personal information, or find out to whom we have disclosed it as permitted by this Code, please email one of our service representatives and request a form to sign and will help you complete the specific information we will need  from you to enable us to search for, and provide you with, the requested personal information we hold about you.  We may charge you a fee to do this and will advise you of the fee in advance.
There are a few instances where we will not be able to provide the personal information we hold about you that you request. Some of these instances include, if: it contains references to other persons;

• it is subject to solicitor-client or litigation privilege;
• it contains our own proprietary information that is confidential to us;
• it has already been destroyed due to legal requirements or because we no longer needed it for the purposes set out in this Code;
• it is too costly, in our determination, to retrieve;
• we are prohibited by law from disclosing to you.

If we are unable to provide you with access to your personal information, we will explain the reason why.
Remember that in most provinces you have the right to access and verify the personal information held about you by a credit bureau. To do so, you must speak directly to the appropriate bureau.

KEEPING YOUR PERSONAL INFORMATION ACCURATE
We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes set out in this Code. You play an active role in keeping us up-to-date. Prompt notification of any changes, for example to your address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your personal information, that amendments are required, please advise us.
If we do not agree to make the amendments that you request, you may challenge our decision. We will make a record of this challenge, which will be kept on file.

DO YOU HAVE QUESTIONS OR CONCERNS?
If you have privacy questions, concerns or complaints, we want them to be answered satisfactorily or resolved as quickly as possible, please follow the steps below:
First: Contact a Customer Service Representitive at EyeSpyU at [email protected].
Second: If the Customer Service Representative is unable to resolve the matter to your satisfaction, advise them that you wish the matter to be escallated by the Department Manager who will contact you to resolve the issue.
Third: If you are still not satisfied, please contact EyeSpyU’s Privacy Officer.
Upon completion of review by EyeSpyU’s Privacy Officer, if the above steps fail to resolve your concern to your satisfaction, your issue may be reviewed by the Privacy Commissioner of Canada who you may contact at any time in this process, by writing to:
The Privacy Commissioner of Canada, 112 Kent Street, Ottawa, ON KlA OH2 or by telephone, toll free, at 1-800-282-1376

RESPONSIBILITIES
Any EyeSpyU employee who believes personal information is not being handled in accordance with this Policy should immediately so advise their manager and the Privacy Officer.
Department Managers required to resolve privacy issues (as per the second step in our privacy question and complaint handling process) shall maintain appropriate records of the same and shall report them to the Privacy Officer.
Department Managers are responsible for oversight of this Policy within their department, including establishing, implementing and regularly reviewing the necessary procedures and standards to give effect to this Policy and to train their staff accordingly.
The Privacy Officer shall act as a resource to Department Managers in the handling of disputes and will assist Department Managers with developing procedures, standards, guidelines and interpretations, promoting awareness of privacy issues and developing staff training programs.

KEEPING THIS PRIVACY CODE CURRENT
Changes to this Privacy Code and the information handling practices of EyeSpyU will result in amendments to this document from time to time. EyeSpyU may add, delete or modify sections at its discretion.