PRIVACY PROTECTION POLICIES and PRACTICES

At Spectra we respect your privacy, so we developed the Spectra Privacy Protection Policies and Practices to specify Spectra’s guidelines for the collection, use and disclosure of your personal information.

The Spectra Privacy Protection Policies and Practices were developed to comply with the relevant portions of the Personal Information Protection and Electronic Documents Act (Canada). We drafted these policies and practices to facilitate our compliance with this legislation and to demonstrate our commitment to protecting your personal information.

We want you to understand the purposes for which we collect personal information. We also want to make certain that we have your consent to continue to collect, use and disclose your personal information for those purposes.

The following is a brief synopsis of our privacy policies and practices:

Why do we need to collect your personal information?
As a Spectra Client, we may have collected and/or we may collect some basic information about you. We respect your privacy, which is why we collect personal information only for the following purposes:

1. To respond to your requests.
2. To ship products to you.
3. To improve our products and services for you.
4. To tell you about Spectra (newsletters, etc.).
5. To inform you about additional services, products or promotional offers that may be of interest to you.
6. To solicit your interest in our products and services.
7. To survey your satisfaction.
8. To survey your needs and potential interest in future products and services.
9. To enter you into a contest.
10. To process credit card payments for transactions you approve.
11. To deal with other customer-relationship-management issues.
12. Also, when you visit our website(s) certain technical information may be collected to improve our website(s) and to make them more responsive to your needs and interests, including your computer's IP address, the type of browser that you use and the web pages or files that you access.

What is personal information?
Personal information for the purpose of these policies and practices includes information that identifies you, as an individual. For example: your name, home address, home phone number, your personal email address, or your personal credit card number.

Personal information however does not include information that is in the public domain, nor does it include business contact information such as your name, your position in the company, company phone number, fax number, address or email address.

When do we disclose personal information?
There are circumstances where we may need to disclose some personal information about our Clients. Here are some examples:

1. To satisfy legal or regulatory requirements.
2. For purposes of risk management or credit verification and reporting, we may exchange information with reputable reference sources and credit bureaus.
3. Spectra may contract the services of mass mailers or survey service suppliers and provide them with contact information.
4. An investor in or acquirer of Spectra may need access to such information as standard due diligence in such a transaction.
5. Spectra’s external accountants may be given access to personal information to perform their consulting, accounting or auditing services.
6. To resolve a processing issue with your credit card company regarding a transaction that you have authorized.

How do we protect your personal information?
In order to protect your personal information, Spectra :

1. Will not collect, use or disclose your personal information for any purpose other than those identified above, except with your further consent;
2. Will protect your personal information with appropriate electronic and physical security safeguards;
3. Will protect the confidentiality of your personal information when dealing with other organizations by executing, where appropriate, Spectra’s Personal Information Protection Agreements:

a) Personal Information Protection Agreement – Service Suppliers
b) Personal Information Protection Agreement – List Suppliers

4. Will strive to keep your personal information as accurate and up to date as is necessary for the purposes identified above; and
5. Will honour any request you make for access to your personal information.

What are your consent choices?
We would like to have your consent to collect, use and disclose your personal information for the purposes identified above. However, you do have choices and can refuse or withdraw your consent as follows:

1. You may refuse to provide your personal information to us.
2. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.