This policy statement (the “Policy”) sets out the privacy policies and practices for [principal company] and its subsidiaries and affiliates (collectively the “Tien Sher Group of Companies”) with respect to the collection, use and disclosure of personal information. This policy may be updated by the Tien Sher Group of Companies and this Policy may be supplemented or modified by agreements entered into between one or more of the Tien Sher Group of Companies and an individual from time to time. Personal information is any information about an identifiable individual, as defined under the Personal Information Protection Act (BC) or other applicable laws.

 
Collection, Use and Disclosure Purposes

Except where otherwise required or permitted by law, the Tien Sher Group of Companies will inform individuals of the purposes for the collection, use or disclosure of the individual’s personal information, prior to collecting, using or disclosing that personal information. The Tien Sher Group of Companies uses information collected from customers and potential customers to provide products or services, to respond to requests for information regarding the Tien Sher Group of Companies’ products and services, for input on preferred features for future developments, mailing contacts for the Tien Sher Group of Companies publications and newsletters, special events marketing and other marketing research activities, and for additional purposes that may be identified at or before the time that the information is collected. The Tien Sher Group of Companies also uses personal information from purchasers for accounting and transaction completion purposes. The Tien Sher Group of Companies may disclose personal information to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.

 
Accountability

The Tien Sher Group of Companies is responsible for personal information under its control and shall designate one or more persons who are responsible for the Tien Sher Group of Companies’ compliance with the principles contained in this privacy policy and for compliance with Applicable Law.

 
Identifying Purposes for the Collection of Personal Information

When required by Applicable Law, the Tien Sher Group of Companies shall identify the purposes for which personal information is collected at or before the time that the information is collected.

 
Consent for the Collection, Use or Disclosure of Personal Information

When required by Applicable Law, the knowledge and consent of a Protected Individual are required for the collection, use or disclosure of personal information.

 
Limiting the Collection of Personal Information

When required by Applicable Law, the Tien Sher Group of Companies shall limit the collection of personal information to that which is necessary for the purposes identified by the Tien Sher Group of Companies. The Tien Sher Group of Companies shall collect personal information by fair and lawful means.

 
Limiting the Use, Disclosure and Retention of Personal Information

The Tien Sher Group of Companies shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the Protected Individual or in accordance with Applicable Law. As required by Applicable Law, the Tien Sher Group of Companies 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

As required by Applicable Law, the Tien Sher Group of Companies shall protect personal information by security safeguards appropriate to the sensitivity of the information.

 
Openness Concerning Policies + Practices

The Tien Sher Group of Companies shall make readily available to Protected Individuals specific information about its policies and practices relating to the management of personal information.

 
Customer and Employee Access to Personal Information

As required by Applicable Law, the Tien Sher Group of Companies shall inform a Protected Individual of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A Protected Individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

 
Challenging Compliance

A Protected Individual shall be able to address a challenge concerning compliance with the above principles or with Applicable Law to the designated person or persons accountable for the Tien Sher Group of Companies’ compliance with this privacy policy.

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