SECURITY - PRIVACY

ORICOM INTERNET INC. CODE REGARDING THE PROTECTION OF PERSONAL INFORMATION 1 - SUMMARY

1. INTRODUCTION

This document is a summary of the Oricom Code regarding the protection of personal information (also known as the "Code" or "Oricom Code"), which is a statement designed to establish responsible and transparent practices in the management of personal information.

The full Code is available on our Web site at www.oricom.ca/confidentialite or in hard copy by calling the phone number listed on your regular invoice.

2. LIABILITY

Oricom is responsible for the Personal Information in its care and shall designate one or more individuals to ensure compliance with the principles contained in this document. At the time of this publication, it is Chantal Lafond, Direction, Oricom Internet Inc., 400 Nolin Street, Québec (QC) G1M 1E7.

For more information about Oricom’s commitment regarding the protection of Personal Information, you can contact Oricom at the telephone number shown on the invoice or on our Web site at www.oricom.ca/confidentialite or by email at support@oricom.ca.

3. PURPOSES FOR COLLECTING PERSONAL INFORMATION

When you become an Oricom Customer, the Personal Information you disclose to us allows us to provide the requested products and services to best suit your needs. We only collect the Personal Information that is strictly necessary to provide our products and services. You can always choose not to provide your Personal Information. However, if you choose this option, it is possible that we may not be able to provide the product, service or information you requested.

Except as authorized by law, Oricom will not use or pass on the Personal Information already collected for any other purpose, without first obtaining the consent of the person concerned.

4. CONSENT TO THE COLLECTION, USE OR DISCLOSURE OF PERSONAL INFORMATION

Oricom requires that the person from whom it collects Personal Information consent to the collection, use or disclosure of his or her Personal Information.

In certain circumstances, such as in an emergency in which the life, health or safety of the individual is in jeopardy, Oricom may collect, use or disclose the Information without the knowledge of the person concerned and without his or her consent.

Any person whose Personal Information is held by Oricom may withdraw his or her consent at any time, subject to the restrictions provided for by law or contract, within a reasonable time frame.

5. LIMITATION TO THE COLLECTION OF PERSONAL INFORMATION

Oricom collects Personal Information primarily from the person concerned, but sometimes the collection is made otherwise when authorized by law.

6. LIMITATION TO THE USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

Oricom retains Personal Information only as long as necessary or appropriate for the identified purposes or as required by law. This Information is then destroyed, deleted or made anonymous.

Note that under no circumstances will we sell information about our customers to anyone. Nor do we forward information about our customers to organizations, unless we have your consent to allow them to offer you their own products or services. This also applies to the e-mail address you provided to us through our Web site or our call centre.

In some cases, contests may be posted on our Web sites. If you participate, you may be asked for Personal Information. This voluntarily-disclosed information may be provided to the partners who set up this contest. Therefore, you may receive messages from one or more Oricom partners who set up the contest. In any contest on an Oricom Web site, you may choose not to receive any messages from Oricom partners.

7. ACCURACY OF PERSONAL INFORMATION

Oricom takes reasonable steps to ensure that the Personal Information is as accurate, complete and current as necessary for the purposes identified.

Any person whose Personal Information is held by Oricom may challenge the accuracy and completeness of his or her Personal Information and have it amended as needed.

8. SECURITY MEASURES

Only Oricom employees whose normal duties require it for the identified purposes have access to the Personal Information held by Oricom. All employees are required by Oricom, as a condition of employment, to respect the confidentiality of this Personal Information.

Oricom protects Personal Information by taking the necessary security measures appropriate to its degree of sensitivity. These measures protect Personal Information, regardless of the manner in which it is kept.

When you contact Oricom via the Internet or make transactions through an Oricom Web site, we want you to feel just as comfortable and confident as when we process your request by phone or in person. This is why we have adopted a business code based on the principles established jointly by the government, consumer associations and other businesses to promote the security of Internet navigation and transactions. Be assured that you can browse our Web sites securely and confidentially, for your own enjoyment or to obtain communications services.

Oricom makes every effort to protect the Personal Information submitted by you on our Web sites. SSL technology encrypts your Personal Information and makes interception and decoding virtually impossible. We require our partners to do likewise. Generally, you will find a closed padlock or an unbroken key on your browser when a connection is secure. In addition, the address will start with https instead of http. To protect your privacy, Oricom also uses other measures in the form of software and equipment.

Oricom uses cookies. These cookies identify a computer during a session and save the user preferences on that computer. A cookie cannot give access to your computer or obtain information other than what you voluntarily submit to our Web site.

9. TRANSPARENCY OF POLICIES AND PRACTICES

From time to time, Oricom sends out information to help customers to be aware of, exercise and protect their rights with regard to their Personal Information. Oricom encourages its employees to be alert and to report any situation that seems to be inconsistent with the Code to the person in charge.

10. ACCESS TO PERSONAL INFORMATION

Subject to the exceptions provided for by law, Oricom will, upon request, inform any person of the existence of any Personal Information regarding him or her, the use made ??of it and whether it has been disclosed to third parties.

Subject to the exceptions provided for by law, upon request, Oricom will allow the individual access to the Personal Information contained in his or her file. The Personal Information is provided in a clear manner, within a reasonable time frame and at minimal cost, if at all, to the person concerned.

To ensure the protection of Personal Information, the individual may be required to provide adequate identification in order for Oricom to inform him or her of the existence, use and disclosure of Personal Information and to allow access to his or her file.

11. COMPLAINTS ON THE VIOLATION OF THE PRINCIPLES OF THIS CODE

Any person may present a complaint regarding non-compliance with the principles of this Code by contacting the person responsible for enforcing the Code at Oricom.

Oricom will investigate all complaints concerning compliance with the Code. If a complaint is deemed valid, Oricom will take appropriate measures, including amending the Code and its practices as necessary. The person concerned will be informed of the outcome of the investigation into their complaint.

If a person who filed the complaint is not satisfied with the decision of the person responsible for the protection of Personal Information at Oricom, he may apply to the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, Ontario, K1A 1H2.

Revised on February 18, 2012

1 Terms not defined in this document that start with a capital letter are defined in the Code.


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