Privacy Policy

Mindspin Studio Inc. recognizes the importance of privacy of personal information. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. This document describes our privacy policies. We encourage you to ask us any questions or raise any concerns you may have regarding our privacy policies.

What is Personal Information?
Personal information is information about an identifiable individual. Personal information includes information such as your name, home address or telephone number, age, gender, income, ethnic background, family status, health history, religious beliefs or political opinions. Personal information, however, does not include business information such as an individual's business title, address and telephone number.

It would be rare for us to collect, use or disclose any personal information without the client's express consent, but this might occur in a case of urgency or if required by law.

About Members of the General Public (Not Clients)
For members of the general public, our primary purpose for collecting personal information is to provide notice of special events (e.g. promotions or campaigns) or to make them aware of our brand identity management and business growing services and associates. Our associates may also market their services to the general public. While we try to collect work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before collecting any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our mailing list.

On our website, we only collect (with the exception of cookies) the personal information you provide and only use that information for the purpose you gave it to us (e.g. to respond to your email message by telephone or email, to send you information). Cookies are only used to help you navigate our website and are not used to monitor you. We are committed to protecting the information you give us online and we have implemented appropriate safeguards. Despite our efforts, there is no guarantee that personal information and transactions on our website or on the Internet will be maintained confidential and secure. If you do not wish to submit personal information online, we ask that you contact us by regular mail, telephone or fax, and we would be pleased to be of service.

About Contract Staff
For people who are contracted to do work for us (e.g. contractors), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g. for new projects) and for necessary work-related communication (e.g. sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency or to investigate a possible breach of law.

Other Purposes
Like most businesses, we also collect, use and disclose information for other purposes. The most common examples are as follows:

• We may invoice clients for goods or services that are not paid for at the time, process credit card payments, collect unpaid accounts through collection agencies or institute auction procedures (which may include publishing clients' names in an advertisement).
• Like all organizations, various government agencies (e.g. Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission etc.) have the authority to review our files and interview our staff as a part of their mandate. In these circumstances, we may consult with professionals (e.g. lawyers, accountants) who will investigate the matter and report back to us.
• Our company may report information suggesting serious illegal behaviour to the appropriate authorities.
• Clients or other individuals we deal with may have questions about our services after the services have been provided. We also provide ongoing services for many of our clients over a period of months or years for which previous records are helpful.
• If Mindspin Studio Inc.'s shares or assets were to be sold, the purchaser would want to conduct a review of our records to ensure that we are a viable business. This may involve a review of personal information held by us. Before being provided access to our records, we will ensure that the purchaser or its representative provides written assurances to keep all personal information confidential and to review such information only for the purpose of completing the purchase of shares or assets.

You can choose not to be part of some of these purposes (e.g. by declining special offers or promotions, by paying for our goods and services in advance). We do not, however, have much choice about some other purposes (e.g. regulatory reporting, response to law enforcement agencies or the courts).

Protecting Personal Information
We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic hardware is located on our premises and passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
• Paper information is transmitted through sealed, addressed envelopes by reputable companies.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.

Mindspin Studio Inc. uses a number of external consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include associates, consultants, bookkeepers and accountants, lawyers, temporary workers, credit card companies, and website managers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

Retention and Destruction of Personal Information
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies (e.g. tax purposes). However, we do not want to keep personal information too long in order to protect your privacy.

We keep our client files and information for several years after the last contact. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away.

We destroy paper files containing personal information by shredding or by incineration. We destroy electronic information by deleting it.

Access to Personal Information
With some exceptions, you have the right to see what personal information we hold about you. Often, all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g. short forms, technical language). Before providing you with this access, we will need to confirm your identity if we do not know you. We reserve the right to charge a nominal fee for such requests.

If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

Do You Have a Question?
Our Information Officer can be reached at:

Mindspin® Studio Inc.
325 West Street, Suite 102A
Brantford, ON Canada
N3R 3V6
Attention: Tanja Neil,
Information Officer
T 519-754-0806
F 519-758-5678
E

The Information Officer will attempt to answer any questions or concerns you may have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. The Information Officer will acknowledge receipt of your complaint and will ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some exceptions to the commitments set out above.

For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Privacy Commissioner can be reached at:

Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa, Ontario K1A 1H3
T 613 995 8210
T Toll free 1 800 282 1376
F 613 947 6850
TTY 613 992 9190
W www.privcom.gc.ca

We reserve our right to amend our privacy policies from time to time and with or without notice.

Last Modified: December 1, 2004