PRIVACY POLICY
(Last Modified: May 30, 2014)

By using the website www.claytonshagal.com of 6328156 Canada inc., doing business under the names “La Maison Clayton Shagal” and “Sumishi”, (the “Corporation”) you expressly authorize the Corporation to collect personal information for the sole purposes set out in this privacy policy (the “Privacy Policy”) and in accordance with its terms.

The Corporation respects its clients’ (“you”) privacy and commits to protect your personal information that you may provide to the Corporation from time to time through the Website (the “Personal Information”, as further detailed in Section 1 hereunder) in the way set forth in this Privacy Policy. This Privacy Policy is subject to modifications at the Corporation’s sole discretion and said modifications will be indicated by the modification of the “Last modified” date at the top of this page. Your continued use of the Website after the modification of the “Last modified” date constitutes your acceptance of the changes.

1. Information Collected and Use

The Corporation collects Personal Information for the following purposes:

• to improve its products and adapt its products to its clients’ needs;
• to manage and develop its business and activities;
• to support its sales agents in relation with the promotion, the marketing and the sales of the Corporation’s products;
• to improve its services and adapt its services to its sales agents’ needs;
• to meet legal and other regulatory requirements.

Your Personal Information, as provided to the Corporation from time to time through the Website (with respect to consumers: name, address, age, email address, telephone number, etc.; with respect to sales agents: name, address, email address, telephone number, license numbers, client data, list of clients, financial information, etc.), including surveys and comments, are stored on the Corporation’s secured servers.

The Corporation also stores some Personal Information collected through your use of the Website, such as cookies that may exclusively identify your browser.

Your Personal Information are stored in order to allow the Corporation to load the information quickly and securely and will never be used for reasons not indicated in this Privacy Policy. The Personal Information collected and stored can only be accessed by the authorized personnel of the Corporation, when required in the execution of the Corporation’s activities.

2. Personal Information Retention

The Corporation will retain your Personal Information only as long as such information is considered by the Corporation, acting reasonably, to be useful for the purposes mentioned hereinabove. The Corporation undertakes to destroy, erase and/or render anonymous your Personal Information collected within a reasonable delay following the receipt of your request to do so, or within thirty (30) days following the termination of the Corporation’s business relation with a specific sales agent.

3. Notifications and emails

The Corporation may use, subject to your express consent, your Personal Information to send you notifications and emails related to its products and services, whether required by law or for marketing or other business purposes. You may however opt out of these notifications and emails at any time by clicking on the unsubscribe link at the bottom of the notifications and emails, or by emailing the Corporation at info@claytonshagal.com.

4. Access to Information and Rectifications

You may access the Personal Information collected and held by the Corporation at any time, upon request, and require any rectifications at your own discretion. Following the receipt of such request, the Corporation undertakes to give access or make such rectifications within a reasonable delay.

The Website may provide links to third parties’ website. The Corporation will never give access, sell, share, distribute, or rent your Personal Information to said third parties, or any other third party, without your express consent. The Corporation is not responsible for the third parties’ privacy policies and practices and you remain responsible for obtaining and understanding said third parties’ privacy policies.

Notwithstanding the foregoing, the Corporation may disclose your Personal Information following the express request of a governmental entity, or if otherwise required by law.

5. Limitation

Your privacy is very important for the Corporation and that is why the Corporation is committed to apply its Privacy Policy in a strict manner with respect to the use of your Personal Information. However, the Corporation cannot guarantee you that unauthorized accesses and breaches of the Corporation’s server and security measures will never occur. You therefore acknowledge that you provide Personal Information through the Website at your own risk.

6. Complaint Procedure and Recourses

Should you have any complaint related to the Corporation’s Privacy Policy and/or practices, you may communicate with the following person: Corporate Office
info@claytonshagal.com

Complaints received will be investigated in a timely manner and the Corporation undertakes to diligently inform the complainant of the investigation’s process and results. Following the investigation, when deemed necessary by the Corporation, acting reasonably, the Corporation shall take any and all appropriate measures. You may also communicate with the governmental entities responsible to enforce the privacy acts in Quebec and Canada:

In Quebec:
Commission d’accès à l’information – Direction de l’analyse et de l’évaluation
575 Saint-Amable Street, Suite 1.10
Quebec (Quebec) G1R 2G4
Tel.: 1-888-528-7741
www.cai.gouv.qc.ca

In Canada:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa (Ontario) K1A aH3
Tel.: 1-800-282-1376
www.priv.gc.ca

For any questions, concerns, rectification or request related to our Privacy Policy, please contact us at info@claytonshagal.com, to the attention of the corporate office.