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Privacy Policy

Purpose of this Policy

Carlton Cards Limited and its affiliated, associated and related corporations, (hereinafter referred to as "Carlton Cards Limited (Canada)") has developed this Privacy Policy for implementation beginning January 1, 2004. This Policy describes the way that Carlton Cards Limited (Canada) collects, uses, retains, safeguards, discloses and disposes of the personal information of its customers.

This Policy describes the way that Carlton Cards Limited (Canada) will, subject to applicable legal requirements, adhere to all relevant federal and provincial legislative privacy requirements. The Policy follows the 10 Canadian Standards Association (CSA) principles identified in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). The Policy describes each principle and the method of implementing each. Carlton Cards Limited (Canada) will strive to meet or exceed federal and provincial legislative requirements and will ensure that it remains current with changing technologies and laws. Any and all changes will immediately be posted to the Carlton Cards Limited (Canada) web site.

To better understand our policy, Carlton Cards Limited (Canada) has set out some basic definitions to use when reading and interpreting the principles below:
Collection - the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Carlton Cards Limited (Canada). Implied consent is consent that can reasonably be inferred from an individual's action or inaction.
Customer - an individual who uses, or applies to use Carlton Cards Limited (Canada)'s products or services, where such individual is a residential customer or an individual carrying on business alone as a sole proprietorship or in partnership with other individuals.
Disclosure - making personal information available to a third party.
Personal information - information about an identifiable individual that is recorded in any form, but does not include aggregated information that cannot be associated with a specific customer. For a customer, such information does not include information that is aggregated in such a manner that it cannot be connected to him/her and/or information which is publicly listed in a written or online directory or typically made available through directory assistance.
Third party - an individual or organization outside Carlton Cards Limited (Canada).
Use - the treatment, handling, and management of personal information by and within Carlton Cards Limited (Canada).

1. Accountability
1.1 Carlton Cards Limited (Canada) will appoint a staff person (the "Privacy Officer") whose responsibilities will include those of the implementation and monitoring of the Carlton Cards Limited (Canada) Privacy Policy. The Privacy Officer will be responsible for Carlton Cards Limited (Canada)'s compliance with privacy principles. This person will also be responsible for responding to access requests in accordance with this Policy. The Privacy Officer will report to the President and the ultimate responsibility for Privacy issues will rest with the Carlton Cards Limited (Canada) Board of Directors. The Privacy Officer may at his/her discretion enlist assistance from other staff members and/or volunteers within the organization. This will not in any manner mitigate his/her responsibility for Privacy issues.
1.2 The Privacy Officer's identity will be fully disclosed and publicly accessible to Carlton Cards Limited (Canada) members and the public in general. Carlton Cards Canada Limited's Privacy Officer is privacyofficer@carltoncards.ca.
1.3 Carlton Cards Limited (Canada)'s Privacy Officer will ensure that Carlton Cards Limited (Canada) manages all personal information in its possession in accordance with this Policy including that which may be transferred to a third party. Third party organizations who handle information on behalf of Carlton Cards Limited (Canada) shall be contractually obligated to adhere to the standards of Carlton Cards Limited (Canada).
1.4 Carlton Cards Limited (Canada) will implement internal policies which will facilitate adherence to this Privacy Policy including but not limited to the following:
(a) Security measures at all levels designed to protect personal information in our possession;
(b) Implementing procedures designed to respond to complaints and/or inquiries;
(c) Staff training in all facets of information management, including awareness of Carlton Cards Limited (Canada)'s Privacy Policy and policies and procedures developed in accordance with the Policy.

2. Identifying Purposes, Type of Information Collected and Website
2.1 Carlton Cards Limited (Canada) shall only collect the information reasonably necessary to perform the services and deliver the product as agreed to with its customers. Access to our Privacy policies and procedures will be readily available. Similarly, the process by which challenges may be made to Carlton Cards Limited (Canada)'s compliance and/or adherence to the legislation in question shall be readily available and transparent. To obtain further information, contact Carlton Cards Limited (Canada)'s Privacy Officer.
2.2 Carlton Cards Limited (Canada) collects personal information from its customers and members of the public for the following purposes.
(a) to collect personal information for the purposes of extending credit or providing refunds to its customers and prospective customers and monitoring the credit of its customers in respect of providing its goods and services, and to verify the accuracy of information provided to us for both of the purposes of credit and refunds, including the establishment of customer identification;
(b) to identify products or services of value to current, past and prospective customers and to sell or promote such products and services of Carlton Cards Canada Limited, including direct marketing to provide ongoing service and improve service;
(c) to assist in the administration of our Loss Prevention Program and to protect you and us from error and fraud and so as to comply with legal and regulatory requirements;

3. Consent
3.1 Carlton Cards Limited (Canada) will use the personal information for the uses specified above in section 2 and in Sections 3.2 and 3.3 below.
3.2 In addition to using personal information for the providing of security services, Carlton Cards Limited (Canada) may from time to time wish to use customer names, addresses and contact information for the purposes of providing promotional opportunities, including by providing the information to Carlton Cards Limited (Canada)'s marketing and sales departments and other third parties who Carlton Cards Limited (Canada) believes provide services or goods that may be of interest to you. Carlton Cards Limited (Canada) and any such third parties may contact you to with promotions. Carlton Cards Limited (Canada) will provide an opportunity for the recipient to consent to these opportunities during the registration process. If you consent but later wish to opt out of this use of information later, you may do so by contacting us as described at Section 3.3 below.
3.3 If at any time you wish to withdraw your consent to the use of your information for any purposes, you may do so by contacting the Privacy Officer for Carlton Cards Limited (Canada). We will do our best to accommodate your request in a timely fashion without diminishing the services we provide to you. We will explain to you the impact of your withdrawal on any services we provide to you.
3.4 Carlton Cards Limited (Canada) may collect personal information without consent where reasonable to do so and where permitted by law.

4. Limiting Collection
4.1. All information shall be collected fairly and lawfully within the criteria as set forth in our Privacy Policy. Our customers' personal information may be collected in a number of ways as, for example, the completion of manual or electronic forms, including Credit Applications, Refunds and Return documentation.
4.2 Carlton Cards Limited (Canada) shall not indiscriminately collect information. The amount and type of information we collect shall be limited to that which is required to fulfill our identified purposes. Certain information, such as driver's license, although convenient for identification, is voluntary. It is up to you whether you want to provide this or other suitable identification.
4.3 Carlton Cards Limited (Canada) will not use any form of deception in gaining personal information from its customers.

5. Limiting Use, Disclosure and Retention
5.1 Subject to applicable legislation, Carlton Cards Limited (Canada) shall limit use of personal information it collects to purposes that we have disclosed in Sections 2 (Identifying Purposes) and 3.2, (Consent), and shall not, without the customer's express or implied consent, disclose the personal information to any third persons, except:
(a) Carlton Cards Limited (Canada) may from time to time enlist the services of third party vendors in order to provide technical and support services. Prior to enlisting the services of these firms we will contractually commit them to treat your personal information consistent with the Privacy Policy of Carlton Cards Limited (Canada);
(b) Carlton Cards Limited (Canada) may at some point be involved in the sale, merger, transfer or reorganization of its activities. We may disclose personal information to the other party in such a transaction. Carlton Cards Limited (Canada) will ensure that we contractually obligate the other party to treat this information in a manner consistent with our Privacy Policy;
(c) Carlton Cards Limited (Canada) may disclose the personal information collected by it to a government authority that has asserted its lawful authority to obtain the information or where the association has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court, person, or body with jurisdiction to compel the production of the information or otherwise as permitted by applicable law;
(d) Carlton Cards Limited (Canada) may at its discretion release personal information for the purposes of collecting debts which may be owed to Carlton Cards Limited (Canada) and may disclose in this regard the personal information it collects to credit reporting agencies;
(e) Carlton Cards Limited (Canada) may promise to share its customers' information with its affiliated and association corporations, including American Greetings Corporation and Carlton Cards U.S.;
(f) in certain circumstances, Carlton Cards Limited may have to collect, use, discharge or release personal information for its protection. For example, it may do so to detect or prevent fraud.
5.2 Carlton Cards Limited (Canada) shall maintain documents for certain periods of time dependant upon necessity.
5.3 Certain documents may be subject to legislated retention periods either federally or provincially and these will be respected at all times by Carlton Cards Limited (Canada).

6. Accuracy
6.1 Carlton Cards Limited (Canada) shall strive to ensure to the extent it can that the information entrusted to us is maintained in an accurate manner. We shall try to maintain the interests of the individual and attempt to ensure that decisions are not made for or about an individual based on personal information that is flawed.

7. Safeguards
7.1 Security safeguards have been implemented to ensure that the personal information collected by Carlton Cards Limited (Canada) is protected from theft as well as unauthorized access, disclosure, copying, use or modification thereof.
7.2 TThe level of safeguards employed shall be directly related to the level of sensitivity of the personal information collected. The more sensitive the information, the higher the level of security employed.
7.3 Methods of protection and safeguards to be employed shall include but in no way be necessarily limited to locked files, offices and storage areas, security clearances and need to know access as well as technological measures such as passwords and encryption.

8. Openness
8.1 Carlton Cards Limited (Canada) will, upon request, disclose the methods by which it handles personal information.
8.2 The information available includes:
(a) The name address and phone number of the Carlton Cards Limited (Canada) Privacy Officer;
(b) The forms which one may use to access one's information or change your information;
(c) A description of the type of personal information held by Carlton Cards Limited (Canada) and our general uses thereof.

9. Individual Access
9.1 Subject to applicable legislation, upon request by the individual concerned Carlton Cards Limited (Canada) shall disclose whether or not it actually holds personal information on an individual. We shall disclose the source of this information when requested and provide an account of third parties to whom the information may have been disclosed.
9.2 Carlton Cards Limited (Canada) may request sufficient information to confirm your identity before releasing your personal information to you.
9.3 Subject to applicable legislation, Carlton Cards Limited (Canada) shall endeavour to provide this information within 30 days of receipt of the information requested and only charge nominal fees for the purpose of off-setting its expenses incurred in supplying the requested information. This information shall be provided in an understandable format, at the time you make a request.
9.4 Any inaccurate information that is brought to our attention shall be corrected by Carlton Cards Limited (Canada) as quickly as possible and any pertinent third parties shall be apprised of the corrections in due course.

10. Challenging Compliance
10.1 Carlton Cards Limited (Canada) has in place procedures for the resolution of grievances in the administration of its Privacy Policy.
10.2 Upon receipt of a complaint Carlton Cards Limited (Canada) shall make available the complaint procedures which will be simple and easy to access.
10.3 Carlton Cards Limited (Canada) shall investigate all complaints. If the complaint is deemed justified Carlton Cards Limited (Canada) shall take the appropriate steps to ensure that compliance is achieved and will make changes to its policies to allow for compliance in the future.
10.4 All complaints shall be addressed to the Carlton Cards Limited (Canada) Privacy Officer.

11. Guidelines for Internet/Website Users
There are additional guidelines that apply to persons who use our Websites and portals. In addition to the principles outlined above, Carlton Cards Limited (Canada) may permit third parties to offer users with subscription and/or registration-based services through the Websites. In such circumstances, Carlton Cards Limited (Canada) cannot be responsible for any actions or policies of such third parties. Users should check the applicable privacy policy of each third party when providing any personal information or even when simply visiting a third party website.

Carlton Cards Limited (Canada) also reminds users that voluntarily disclosed information online in discussion areas or other public areas of our Websites can be collected and used by third parties and may result in unsolicited messages from third parties. Unfortunately, such activities are beyond the control of Carlton Cards Limited (Canada).

In some cases, users' non-personal information and data may be automatically collected through the standard operation of Carlton Cards Limited (Canada)'s internet servers or through the use of "cookies". "Cookies" are small text files that are used by websites to: (a) recognize repeat users; (b) track usage behavior; and (c) compile aggregate data that will permit content improvements and targeted advertising. Carlton Cards Limited (Canada) cannot control or prevent the use of cookies or any information obtained through such cookies by advertisers or third parties. If you do not want information collected through the use of cookies, most browsers permit you to disable the cookie feature. However, cookies may be required for the use of certain features on our Websites.

Any submissions made to discussion areas or other public areas on our Websites are done so with a user's understanding that they are accessible to third parties. If comments are not intended for third parties, you are advised not to make any submissions.

In any event, users can request Carlton Cards Limited (Canada) to cease from sending electronic mail or advertising from Carlton Cards Limited (Canada) or its authorized agents at any time by simply contacting us below.

Carlton Cards Limited (Canada)'s policy generally and in connection with Internet use is subject to the requirements or provisions of any applicable legislation, regulations or agreements, or order of any court, or other lawful authority. Your use of our Websites is also subject to these requirements.

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