Market Pulse's Commitment to Privacy

At Market Pulse, we know that without the cooperation of respondents, we could not be in business. Our longstanding commitment to safeguarding your right to privacy is the reason for our reputation as a leader in the protection of privacy. Each year, we ensure that our employees sign a code of business conduct that requires the safeguarding and proper use of personal information. We also place strict controls on the protection and use of personal information within our systems and web site and ensure that our employees are trained to respect your privacy at all times.

Our Privacy Policy spells out the commitments of our company and the rights of respondents regarding personal information. We also comply fully with the Personal Information Protection and Electronic Documents Act, which has applied to our company since January 1, 2004.

In addition to the Privacy Policy, our company may also be subject to the requirements of applicable legislation and regulations.

Any time you have contact with our company, or with anyone acting as an agent on our behalf, you are protected by the rights and safeguards contained in the Policy.

Information Practices

To ensure our commitment to your privacy is upheld, we have updated our existing company policies setting out your rights and our obligations respecting the treatment of your personal information by our company. Our company policies comply with the requirements of the Personal Information Protection and Electronic Documents Act as well as the standards of the Professional Marketing Research Society (PMRS) and the Marketing Research Association (MRA).

Employees and Agents

The company policies also govern the behaviour of our employees and agents acting on our behalf. All of our employees who have access to personal information have been trained on the handling of such information. And, new employees receive training on privacy as a fundamental part of their initial company training. All of our employees must review and commit to the Privacy Policy annually.

Personal Information

Personal information is information about an identifiable individual. Publicly available information, such as a public directory listing of your name, address, telephone number, electronic address, is not considered to be personal information.

Collecting Information Helps Our Clients Serve You Better

We collect personal information only for the following purposes:

• to help our clients establish and maintain responsible commercial relations with you and provide you with ongoing service;
• to help our clients understand your needs and eligibility for products & services;
• to help our clients recommend particular products & services to meet your needs;
• to help our clients develop, enhance, market or provide products and services;
• to help our clients manage and develop their business and operations, including personnel and employment matters; and
• to help our clients meet legal and regulatory requirements.

The Market Pulse commitment to privacy

We take all of the necessary precautions to ensure the safeguarding of your information, whether it is stored electronically or in paper format. In all cases, information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required. For example, our electronic files are backed up for redundancy, password protected and accessible only by authorized employees, on a need-to-know basis.

Use of 'Cookies'

During user interaction with our web site, we may use a browser feature called a 'cookie' to allow us to remember your password for you and provide other enhancements. A cookie is a small text file containing a unique identification number that identifies your browser - but not you - to our computers each time you visit one of our sites that uses cookies. This helps us to enhance the on-line experience of visitors to our site.

Unless you specifically advise us, we will not know who you are, even though we may assign your computer a cookie. We cannot use cookies, by themselves, to disclose the individual identity of any site user, and we never combine information gathered by a cookie with personally identifiable information like your name, telephone number, or even your e-mail address without your consent.

You will find that most major web sites use cookies and most major browsers are set up to accept them. If you wish, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You do not need cookies to visit our web site. However, if you refuse to accept cookies, you may not be able to use some of the features available on our site such as personalization features.

Protection of Children

As an added protection for children, on any of our services directed to children under 13 years of age, we will obtain the permission of a parent or legal guardian before collecting, using or disclosing any personally-identifiable information about a child, e.g., for participation in a survey.

Questions or Concerns

If you have questions or concerns about your privacy, you can contact John Amato at jamato@market-pulse.ca or at (416) 960-3275.

Chief Privacy Officer

If you still have unresolved concerns with respect to the treatment of your personal information by our company or our agents, you may address these concerns, in writing, to Market Pulse's Chief Privacy Officer, who has overall responsibility for the company' compliance with this policy and applicable privacy restrictions.

You should write to:

Chief Privacy Officer
Market Pulse Inc.
180 Bloor St. W., Suite 1400
Toronto, ON M5S 2V6 Canada

Further Complaint Procedure

If the Chief Privacy Officer does not resolve the issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada by calling 1-800-282-1376 or writing to:

The Privacy Commissioner of Canada
112 Kent Street
Ottawa ON K1A 1H3
privcan@fox.nstn.ca

Market Pulse Code of Fair Information Practices

Summary of Principles

• Accountability: Market Pulse is responsible for personal respondent information under their control and shall designate one or more persons who are accountable for compliance with the following principles.
• Identifying purposes for collection of respondent information: Market Pulse shall identify the purposes for which personal information is collected at or before the time the information is collected.
• Obtaining consent for collection, use or disclosure of personal information: The knowledge and consent of a respondent or employee are required for the collection, use, or disclosure of personal information, except where inappropriate.
• Limiting collection of personal information: Market Pulse shall limit the collection of personal information to that which is necessary for the purposes identified. Market Pulse shall collect personal information by fair and lawful means.
• Limiting use, disclosure and retention of personal information: Market Pulse 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. Market Pulse shall retain personal information only as long as necessary for the fulfillment of those purposes.
• 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.
• Security safeguards: Market Pulse shall protect personal information by security safeguards appropriate to the sensitivity of the information.
• Openness concerning policies and practices: Market Pulse shall make readily available to respondents and employees specific information about its policies and practices relating to the management of personal information.
• Customer and employee access to personal information: Market Pulse shall inform a respondent 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 respondent or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.
• Challenging compliance: A respondent or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Market Pulse's compliance with the Code.