The privacy of individuals connected with our business, including our customers, contractors, employees, and website visitors has always been of great importance to KM Enterprise Solutions. Regardless of how the range of products and services we offer our customers expands, and the technology we use changes, we will always strive to protect the privacy of personal information, subject to any consent an individual has provided for its use. This policy describes the principles on which KM Enterprise Solutions will protect the privacy of personal information. The policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information. While this document sets out the principles on which KM Enterprise Solutions privacy practices are based, privacy laws will vary from province to province and those laws may also govern KM Enterprise Solutions privacy practices in such province. This policy is part of KM Enterprise Solutions commitment to ensure that all personal information of individuals in its possession is protected and used in accordance with the law. Privacy laws across Canada are evolving, and therefore this policy is subject to change. Personal information is any information about an identifiable person, other than the name, title, business address and business telephone number of a person. It includes such things as a person’s home address, date of birth, social insurance number, medical and financial information. With respect to customers, such information is collected primarily in connection with services and products provided by KM Enterprise Solutions. Employees may be asked to provide such information to KM Enterprise Solutions in connection with matters relating to their employment. In all cases, KM Enterprise Solutions is committed to protecting the privacy of individuals and the integrity of their personal information. KM Enterprise Solutions collects personal information only for the following purposes:

• To establish and maintain a responsible commercial relationship with its customers and provide them with ongoing service;

• To understand its customers’ needs and develop and recommend suitable products and services;

• To manage and develop our business and operations, including personnel and employment matters; and

• To meet legal and regulatory requirements.

Customer and employee personal information will not be used for any other purpose absent consent.

Summary of Principles

Principle 1 – Accountability
KM Enterprise Solutions is responsible for personal information under its control and shall designate one or more persons who are accountable for compliance with the following principles.

Principle 2 – Identifying Purposes for Collection of Personal Information
KM Enterprise Solutions shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

Principle 4 – Limiting Collection of Personal Information
KM Enterprise Solutions shall limit the collection of personal information to that which is necessary for the purposes identified.  Chubb Canada shall collect personal information by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
KM Enterprise Solutions shall 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 by law.  KM Enterprise Solutions shall retain personal information only as long as necessary for the fulfillment of those purposes.

Principle 6 – Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 - Security Safeguards
KM Enterprise Solutions shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness Concerning Policies and Practices
KM Enterprise Solutions shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

Principle 9 – Customer and Employee Access to Personal Information
KM Enterprise Solutions shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information.  A customer or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.

Principle 10 – Challenging Compliance
A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for KM Enterprise Solutions compliance with the Code.