Privacy Policy

PRIVACY POLICY

Protecting the confidentiality of

our client’s

personal information has always been an important

part of the way we do business. To ensure that we protect

their

privacy,

Baby Brands Gift Club.

has

created this

Privacy Policy

. This

Policy

sets out how and why we collect and use personal

information about our

clients

. It also explains

the

circumstances under which we

will

be required

to disclose it.

“Personal information” means information that identifies you as a specific individual, incl

ud

ing

but is not limited to:



Name;



Spouse’s or Partner’s Name;



Address;



Telephone number (s);



Email Address;



Date of birth or expected date of birth and gender of your child (ren).

The federal Protection of Personal Information and Electronic Documents Ac

t (PIPEDA) and

similar provincial legislation in Quebec, British Columbia and Alberta

set out the

rules and

principles for the use and disclosure of personal information based on the ten privacy principles

developed by the Canadian Standards Association.

Under the

legislation, an organization may collect, use or disclose personal information only for

the

limited purposes that a reasonable person would consider to be appropriate in the

circumstances.

Our Privacy

Policy sets out

how we comply with these pr

inciples

.

It explains how we ensure

that your privacy and the confidentiality of your personal information are protected.

The Ten Privacy Principles

Principle #1: Our Accountability for the Collection, Use or Disclosure of Personal

Information:

W

e are responsible for maintaining and protecting your personal information while it is under

our control. This includes any personal information

we disclose to third parties (our “Partners,

Sponsors and Advertisers”)

.

To help ensure the confidentiality of

your personal information, we have established policies and

procedures to ensure that we comply with the Personal Information Protection and Electronic

Documents Act

and substantially similar provincial legislation

. We have designated a privacy

officer wh

o is responsible for our company’s compliance with the ten privacy principles.

If you have any questions or inquiries about how your personal information is stored, or when it

may need to be disclosed to others, our privacy officer is there to assist and

explain our policies

to you.

Principle #2: Identifying Our Purpose for the Collection, Use or Disclosure of Personal

Information:

Non

–

financial, basic contact information is maintained by Baby Brands Gift Club systems

for

past and current

clients who ha

ve registered with Baby Brands Gift Club (“

Registrants

”)

. Each

Registrant’s

basic contact information such as name,

spouse’s or partner’s name,

address, email

address

,

telephone number

(s) and/or age and gender of child (ren)

will only be supplied to

Baby

Brands Gift Club Partners, Sponsors

or Advertiser

s, current or future

. Such basic contact

information is provided to the

Partners, Sponsors and Advertisers

under strict contractual

agreement that the information is for their sole use in informing the clien

t of offerings regarding

their products and/or services.

Baby Brands Gift Club may receive compensation from its

Partners, Sponsors or A

dvertisers for sharing registrant information

.

A

complete list of our

Partners, Sponsors and Advertisers can be viewed a

t

http://www.babybrandsgiftclub.ca/brands

Principle #3: Obtaining

you

r Consent for the Collection, Use or Disclosure of Personal

Information:

By completing a Baby Brands Gift Club registration card or by registering online on the Baby

Brands Gift Club website, you consent to the use of your personal information for the purposes

described in Principle 2, above.

Unless we are required by law,

Ba

by Brands

will not use or disclose any personal information

that has been collected

for any other purpose

without

documenting the new purpose and

obtaining your consent. If you have any questions about these purposes, our privacy officer will

be pleased to

explain them to you.

The Personal Information Protection and Electronic Documents Act recognizes that when

information is being collected for the detection and prevention of fraud or for law enforcement,

seeking the consent of an individual may defeat th

e purpose of collecting the information.

Seeking consent may also be impossible or inappropriate when the individual is a minor,

seriously ill, or mentally incapacitated.

Principle #4: Limiting Our Collection of Personal Information:

We will always limi

t the

personal information

that we collect

to that which is necessary for the

identified purposes.

Principle #5: Limiting the Use, Disclosure and Retention of Personal Information:

Personal information will not be used or disclosed for purposes other t

han for which it was

collected, except with your consent or as permitted or required by law.

Your

personal

information will be retained only as long as it is necessary to fulfill those purposes.

Contact information is maintained online in perpetuity; unl

ess and until,

you specifically request

in writing (email from the registered email address being acceptable) or by verifiable telephone

contact via the toll free

or office

telephone number to remove

your

records.

Then your

record is

red flagged to any Spo

nsor and Advertiser having access as “Please Remove

–

No Further

Contact!” and after one (1) complete six (6) month cycle, permanently removed from the Baby

Brands Gift Club systems.

Registrants of the systems may also elect to “Opt

–

Out” of the Baby Brands Gift Club Sponsor

and Advertiser contact for additional future

while remaining with Baby Brands Gift Club in

order to be eligible for future Club offerings and draws. This may be don

e by

specifically

requesting

that

in writing (email from the registered email address being acceptable) or by

verifiable telephone contact via the toll free

or office

telephone number. Again, the client’s

record is red flagged to

all Partners, Sponsors and

Advertisers

as “Please Remove

–

No Further

Contact!” but the record remains within the system for the client’s own access and use.

Principle #6: Keeping

you

r Personal Information Accurate:

Baby Brands

makes every effort to ensure that personal information about

you

is as accurate,

complete, and up

–

to

–

date as is necessary for the purposes for which it was collected.

If you have any questions about the accuracy and completeness of the personal informati

on that

we have collected or retained, please do not hesitate to contact our privacy officer. If you need to

update some aspect of your personal information, please contact

us

.

It is our intent to provide

you password protected access so that you may in f

act review and update your information no

later than the end of the first quarter of 2015.

Principle #7: Safeguarding

you

r Personal Information:

Baby Brands

takes steps to protect personal information with security safeguards appropriate to

the sensitiv

ity of the information.

Specifically, we have stringent security measures in place to protect personal information against

such risks as loss or theft, computer hackers, unauthorized access, disclosure, copying, use,

modification or destruction.

Baby Bra

nds

protects your personal information regardless of the format in which it is held. We

also protect personal information we disclose to

Partners, Sponsors and Advertisers

by

contractual agreements stipulating the confidentiality of the information and the

purposes for

which it is to be used.

All our employees

and any outside contractors

with access to personal information are required

as a condition of their employment

or contract

to

keep any and all

personal information

confidential

.

Principle #8: Open

ness Concerning our Privacy Practices:

Baby Brands

pursues a policy of openness about the procedures it uses to manage personal

information. We will make specific information about our policies and practices relating to the

management of their personal i

nformation available

to you

upon request.

We ensure openness by providing you with the following information:

a) the title and address of the privacy officer accountable for our compliance with the policy;

b) the name of the individual to whom inquiri

es or complaints can be forwarded;

c) the means of gaining access to personal information held by

Baby Brands

; and

d) a description of the type of personal information held by

Baby Brands

, including a general

account of its use.

Baby Brands

makes infor

mation available to help

you

exercise informed choices regarding the

use of

your

personal information.

Principle #9: Policyholder Access to Personal Information:

Baby Brands will inform

you

of the existence, use, and disclosure of their personal informa

tion

upon request and provides access to that information.

You

are able to challenge or correct the

accuracy and completeness of their personal information and have it amended when appropriate.

When a request is made in writing, we will inform you in a ti

mely fashion, of the existence, use,

and disclosure of your personal information and you will be given access to that information. In

order to safeguard your personal information, we may require you to provide sufficient

identification information to permi

t us to authorize access to your file.