IC GROUP LP’S PRIVACY POLICY

iC Group LP (iC) is a privately held organization that is a provider of promotional insurance, online promotion technology, and risk management services to marketers worldwide. IC manages various aspects of consumer based promotions, including contest administration and prize fulfillment.

The purpose of this Privacy Policy is to inform you of what kinds of information we may collect about you when you participate in a promotional offer iC is administering, how we typically use that information and who we disclose it to. Our Privacy Policy applies only to iC and not to other companies' or organizations' web sites to which we link. We are not responsible for the content or privacy practices of other sites. Our Privacy Policy applies solely to information collected, used and disclosed by iC.

This privacy policy outlines iC’s commitment to the protection of personal information under our control, in accordance with The Personal Information and Electronics Documents Act (PIPEDA). iC adheres to Ten Privacy Principles, established by PIPEDA, to ensure personal information is protected.

WHAT INFORMATION DOES iC COLLECT ABOUT YOU?

In order for iC to administer a promotion, it must collect some personal information. We obtain all of our information about you directly from you, via online entry forms, surveys, rebate/claim forms and registrations. The information that we collect may include your name, date of birth, address, telephone number and e-mail address.

In addition, when you submit an entry to a game or contest or submit your response to a survey question, we collect your answer or any opinions or information that you may volunteer.

HOW DOES iC USE THE INFORMATION THAT IT COLLECTS?

IC uses the personal information that it has collected to contact selected entrants and to fulfill the Promotional Sponsor’s obligations in accordance with promotional rules and regulations.

In particular, iC uses the personal information collected through submissions of entries to games or contests and submissions of responses to survey questions for the purpose of awarding prizes or fulfilling rebates offered by the game, contest or survey. We also use these submissions to come up with the game or survey results, and we may publish those results in an aggregated format on our web sites and/or provide them to the Promotional Sponsor.

WHEN DOES iC DISCLOSE PERSONAL INFORMATION?

iC may disclose your personal information to the Promotional Sponsor of the promotion that you entered or otherwise participated in. If you have a question about how a particular Sponsor uses your personal information, would like to correct inaccurate information, or would like to opt out of future communication with that Sponsor, please contact that Sponsor directly. Except as described above or as required by law, under no circumstances do we sell or otherwise provide customer lists or other personal information to third parties for their use.

HOW DOES IC PROTECT THE INFORMATION THAT IT HAS COLLECTED ?

The privacy of your personal information is important to us. Regarding our online promotions, we have instituted a variety of security precautions to prevent unauthorized access to your personal information. The information is stored on secure networks and is only accessible by a limited number of individuals who are expressly authorized by iC to do so. These individuals are required to keep all information strictly confidential, and may not use the information for any purposes not described in our Privacy Policy. Similar protection is provided to personal information that we collect through the mail or in telephone discussions with you.

INFORMATION PLACED ON YOUR COMPUTER

We do not use cookies, and do not accept third party advertising on our web sites. iC’s web sites utilize online reporting to analyze statistical information and to follow user movements on our sites. This information does not link to personally identifiable information and is used to analyze trends, administer the sites and ultimately better improve your experience on our sites.

Through our online promotions, we may also collect certain information about your computer hardware and software when you visit our sites. This information can include: your browser type, Operating System Type, IP Address, access times and referring web site addresses. This information is used by us for the operation of our sites, to maintain and improve the quality of our sites, and to provide general statistics regarding use of our sites.

RETENTION OF YOUR PERSONAL INFORMATION

The length of time that we retain personal information varies, depending on the promotion in relation to which the personal information was collected and the nature of the information. This period may extend beyond the end of your relationship with us, but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

THE TEN PRIVACY PRINCIPLES

Accountability

iC is responsible for personal information under its control and shall designate a Privacy Coordinator to be accountable for iC’s compliance with PIPEDA.

Identifying Purposes

The purposes for which personal information is collected shall be identified at or before the time the information is collected. Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where required or permitted by law.

Limiting Collection

The collection of personal information shall be limited only to that which is necessary for the purposes identified. Limiting Use, Disclosure and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Openness

iC shall make readily available to individuals specific information about its policies and practices relating to the management of personal information that is under its control.

Individual Access

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for IC’s compliance.

CONCERNS?

If you have any questions or suggestions regarding how personal information is being handled, please feel free to contact iC’s Privacy Officers by:

Mail:
Donna Nilson
383 Dovercourt Drive
Winnipeg, Manitoba, Canada
R3Y 1G4
Phone: 204.487.5000
Fax: 204.489.7900

Otherwise, we will assume that we have your consent to collect, use and disclose your personal information (including personal information that we have previously collected) as described above and in a manner consistent with our Privacy Policy.