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Spark Ideas Inc. Privacy Policy

Spark Ideas Inc. (“Spark”) is a corporation registered in Ontario, Canada. It is a Toronto-based marketing, strategy and consulting company that applies creative thinking to every client project. We at Spark support businesses by providing unique marketing, branding, research and planning
advice.

Consistent with our obligations as professional consultants, we are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. These obligations apply to all employees, contractors and agents who provide services in connection with our delivery of services to our clients. Spark is committed to protecting the privacy of your personal information. We have developed this policy and related procedures to comply with the Personal Information Protection and Electronic Documents Act. This federal statute sets out ten principles:

i. Accountability
ii. Identifying Purposes
iii. Consent
iv. Limiting Collection
v. Limiting Use, Disclosure and Retention
vi. Accuracy
vii. Safeguards
viii. Openness
ix. Individual Access
x. Challenging Compliance

These principles govern our approach to respecting your privacy. Spark is responsible for personal information it holds or has under its control, including personal information it passes on to others with your permission. We have designated a Privacy Officer to ensure our compliance with legislation and this policy. Our Privacy Officer will receive and respond to your inquiries and complaints regarding the protection and privacy of your personal information, and deal with requests for access to your information.

1. What is Personal Information?

Canadian privacy legislation defines “personal information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, we rely on the definition used in the legislation. Generally speaking, personal information does not include what is considered business contact information: your name, title or position, business telephone or facsimile number, or business email address.

2. Appointment of Privacy Officer

Spark is responsible for the personal information it collects and holds. To ensure this accountability, we have developed this policy, and have appointed Jill Roussy as our Privacy Officer to support this policy.

Our Privacy Officer will receive and respond to your inquiries and complaints regarding the protection and privacy of your personal information, and deal with requests for access to your information.

3. Purposes for the Collection of Personal Information

The purposes for which personal information is collected by Spark include:

a) to understand the operations, products and services of our clients and the public perception and consumption of those operations, products and services, through techniques that include market research tools such as consumer workshops, consumer panels, product and service audits, focus groups, one-on-one interviews and web-panels which may require the collection of personal information of consumers when they participate in any of our market research efforts;

b) to administer the duties and compensation of our contractors.;

e) to administer the employment and compensation of our employees. (Spark will collect the name, address, date of birth, social insurance number of employees for taxation purposes); and

f) to meet requirements imposed by law.

4. Collection, Use and Disclosure of Personal Information

Collection

Only information required for the purpose(s) identified will be collected. Only lawful means
will be used to collect personal information.

Use and disclosure

Personal information will not be used or disclosed for purposes other than those specified, except where required by law or to protect the interests of Spark against criminal activity, fraud, and material misrepresentation.

Use of Cookies and Non-Personally Identifiable Information

To help make our site more responsive to the needs of potential clients and other visitors, we invoke a standard feature found in browser software, called a “cookie”, to assign each visitor a unique, random number; this is an anonymous user identification that resides on your computer. The cookie does not identify the visitor, nor will we know who you are, even if we assign a cookie to your computer. A cookie cannot read data off your hard drive.

Spark keeps records of certain non-personally identifiable information such as the number of hits a Web page receives, Internet Protocol (IP) address, and other aggregate data. We do not link this aggregate data with any personal information. Third parties that help us administer our
Web site may have access to this non-personally identifiable, aggregate data. Spark may also obtain non-personally identifiable data from clients’ computer systems to assist

Spark in evaluating its clients’ information and to allow Spark to fulfill its mandate. As noted above, if personal information is to be gathered from any other source, including clients, appropriate steps will be taken by Spark.

IP Addresses

Our Web servers automatically collect limited information about your computer’s connection to the Internet, including your IP address, when you visit our site. (Your IP address is a number that lets computers attached to the Internet know where to send you data – such as the Web pages
you view.) Your IP address does not identify you personally. We use this information to deliver our Web page to you upon request, to tailor our site to the interests of our users and to measure traffic within our site.

You should note that our site may include links to other Web sites whose privacy practices we do not control. Once you leave our servers (you can tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting. These parties may have privacy policies and practices that differ from ours. If you cannot find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the operator of the site directly for more information. We encourage everyone to be proactive in understanding how his or her information is collected and used online.

5. Consent To Collection, Use and Disclosure

Subject to legal and contractual requirements, you may refuse or withdraw your consent to the use, storage or disclosure of your personal information for certain of the identified purposes at any time by contacting Spark’s Privacy Officer. If you refuse to consent or withdraw your
consent, we may not be able to provide to you, or continue to provide to you, certain services or information or to include your information in our consumer research. If you provide Spark or our service providers and agents with personal information of another individual, you represent
that you have all necessary authority and/or have obtained all necessary consents from that person to enable us to collect, use and disclose the personal information provided for the purposes set forth in this Privacy Policy.

There are circumstances where collection, use or disclosure may be justified or permitted, or where we are obliged to disclose personal information without your consent. These circumstances could include:
• Where the information is publicly available;
• Where we are required to do so by law or by order of a court or tribunal;
• Where we believe, upon reasonable grounds, that there is an imminent risk to an identifiable
person or group of death or serious bodily harm;
• Where it is alleged that a member, associate or employee of Spark is guilty of a criminal
offence, or is civilly liable in a legal action or other misconduct;
• Where it is necessary to establish or collect fees.
In these circumstances, we will not collect, use or disclose more personal information than is
required.

6. Storage, Security and Protection Of Personal Information

Spark endeavours to maintain appropriate physical, procedural and technical security over our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use or modification of personal information. Your personal information may be stored
in secured physical locations and on computer network servers controlled by Spark located either at our offices or at the offices of our service providers. To help protect the confidentiality of your personal information, Spark employs physical, administrative and technological safeguards appropriate to the sensitivity of your personal information. For instance, we use secure computer data networks protected by industry standard firewalls and password protection systems. In addition, where personal information is sent to a third party for processing, we make sure, through our arrangements with them, that all personal information is kept secure.

7. Retention

It is our practice to retain our files, and the personal information contained therein for a reasonable period of time. This retention policy was developed due to tax, regulatory and business needs, as well as for the benefit of our clients. We will keep personal information only as a long as it is necessary, including for the purposes of completing our services or as required by law. When the personal information is no longer required, it will be shredded or otherwise deleted or destroyed.

8. Access and Accuracy

Upon receiving a written request, and subject to any applicable exemptions, Spark will inform you of its then currently-held version of your personal information and will give you access to that information and the opportunity to correct any errors in it. Access requests should be sent to
our Privacy Officer, using the contract information provided below. Spark endeavours to maintain the accuracy of all personal information on active matters. Personal information contained in closed files is not actively updated or maintained. We encourage our clients, contractors and consumers participating in any of our market research efforts to notify Spark of any changes to their personal information we have in our possession.

9. Changes to the Privacy Policy

Spark reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our website and, if requested, provide a physical copy to you. However, Spark will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your personal information for purposes other than those to which consent has been obtained unless otherwise required or permitted by law.

10. Questions and Further Information

Spark has appointed Jill Roussy as its Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. In the event of any questions concerning the management of your personal information, or if you have general questions regarding our privacy practices,
please contact Jill Roussy at:

Spark Ideas Inc.
106 Front Street Street East
Suite 301
Toronto, Ontario
M5A 1E1

Tel No. 416.481.2100 x223
Fax No. 647.438.7625

Info@sparkideas.ca