Privacy Policy

At TSC Stores L.P. we recognize that protecting the privacy of personal information is a very important principle in building and maintaining our relationship with our customers.

This policy describes the commitment of TSC Stores L.P. and the rights of our customers regarding personal information. It complies fully with the Personal Information Protection and Electronic Documents Act (the "Act") and is based on the Canadian Standards Association Model Code for the Protection of Personal Information.

This policy applies to the collection, storage, use, disclosure, protection, and accuracy of Personal Information collected and controlled by TSC Stores L.P.

Definitions:

Collect - to gather, acquire, or obtain Personal Information from any source, including third parties.
Consent - voluntary agreement with what is being done or proposed. Consent can either be express or implied. Express consent is given explicitly, either orally or in writing. Implied consent may reasonably be inferred from the action or inaction of the customer or employee.
Direct Marketing - direct communication targeted to Customers, including mail, fax or electronic mail.
Personal Information - information about an identifiable Customer recorded in any form. Although the kind of Personal Information depends largely on the specific purpose, TSC Stores L.P. may typically collect name, address, phone number, date of birth, e-mail address, credit card number, gender, language preference, merchandise category preferences, driver's licence number. Does not include name, title, business address and phone number.
Supplier - a company under contract to provide services, data collection, or processing services to TSC Stores L.P.

Summary of Principles:

PRINCIPLE 1: Identifying Purposes

TSC Stores L.P. shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

1.1 TSC Stores L.P. provides Customers with information that explains why the Personal Information is needed and how the Personal Information will be used or disclosed.

1.2 TSC Stores L.P. obtains consent of Customers before using Personal Information for a purpose that has not been specified, unless the new purpose is required by law.

1.3 TSC Stores L.P. collects Personal Information for the following purposes:

• to communicate information and offers to Customers';
• to understand and analyze Customers' sales, needs and preferences;
• to develop, enhance, market and provide products and services to meet Customers' needs;
• to enable Customers to participate in promotions and contests;
• to enable Customers to participate in Customer research;
• to process exchanges or product returns;
• to respond to requests or complaints;
• to bill customers, ship product;
• to process credit applications

Customers can opt out of receiving direct marketing and promotional communications in electronic, printed or verbal format by writing to:

Chief Privacy Officer
TSC Stores L.P.
1950 Oxford Street E.
London, Ontario
N5V 2Z8

Or by e-mail to: chiefprivacyofficer@tscstores.com

PRINCIPLE 2: Consent

Every reasonable effort is made by TSC Stores L.P. to ensure that the Customer and Employees understand the purpose of Personal Information collection. A Customer or Employee's consent is obtained as required for the collection, use or disclosure of his or her Personal Information.

2.1 TSC Stores L.P. provides information about the purpose of the Personal Information through printed materials and our Web site.

2.2 TSC Stores L.P. obtains consent for the collection, use or disclosure of Personal Information. This consent is usually obtained verbally-in Store, in writing, electronically, on customer comment forms, survey forms and/or during telephone conversations with Customers. It may also be obtained verbally from Customers through our Store staff (for example, in conjunction with participation in our Marketing Program).

2.3 Consent to provide Personal Information is not a condition for TSC Stores L.P. selling a product to Customers, unless the information requested is required to fulfil an explicitly specified and legitimate purpose.

2.4 A Customer may withdraw their consent at any time per section 1.3 above at which time TSC Stores L.P. will make them aware of the implication of their withdrawal.

PRINCIPLE 3: Limiting Collection

TSC Stores L.P. limits the amount and type of information it collects to what is necessary for the identified purposes.

3.1 TSC Stores L.P. does not collect Personal Information indiscriminately. The amount and type of Personal Information collected are limited to that which is necessary to fulfil the purposes identified.

3.2 TSC Stores L.P. collects Personal Information from the Customer:

• through e-mail orders or sales transactions with TSC Stores L.P.
• through interaction with our Customer Service and Sales Associates
• through telephone, paper, surveys and contests;
• through exchange and refunds of product transactions;
• through mail or phone orders.
• through rainchecks.

PRINCIPLE 4: Limit Use, Disclosure and Retention

TSC Stores L.P. does not use or disclose Personal Information for purposes other than those for which it is collected, except with the consent of the Customer, or when the use or disclosure is authorized by the Act or as required by law. TSC Stores L.P. only keeps Personal Information for as long as is necessary to satisfy those purposes.

4.1 TSC Stores L.P. does not give, rent or sell Customer lists to any organization or individual other than the business units of TSC Stores L.P., agents, and companies contracted to process and manage Customer transactions, analyze data, handle direct mailing or arrange Customer research.

4.2 As TSC Stores L.P. develops its business, it might sell or buy assets. In such transactions, Personal Information may be one of the transferred business assets. Also, in the event that TSC Stores L.P. assets are acquired, Personal Information may be one of the transferred assets.

4.3 TSC Stores L.P. retains Personal Information in accordance with guidelines and procedures established by TSC Stores L.P. The Personal Information is collected and retained for as long as is necessary to satisfy identified purposes.

4.4 TSC Stores L.P. has procedures to govern the destruction of Personal Information that is no longer required to fulfil the identified purposes. Customer transaction records-including e-mail orders, phone orders, and Customer mailing lists that are inactive after two (2) years-are deleted from TSC Stores L.P. data base(s). "Inactive" means that no purchases or returns have been recorded during the previous twenty-four (24) consecutive months.

PRINCIPLE 5: Accuracy

TSC Stores L.P. keeps Personal Information as accurate, complete and up-to-date as necessary, taking into account its use and the interests of the Customer.

5.1 TSC Stores L.P. updates Personal Information as it is made available by Customers.

5.2 Customers are responsible for informing TSC Stores L.P. about changes to their Personal Information, as appropriate.

5.3 TSC Stores L.P. does not normally update Personal Information unless such a process is necessary to fulfill the purposes for which the Personal Information is collected.

PRINCIPLE 6: Use of Safeguards

TSC Stores L.P. protects Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held.

6.1 The methods of protection for Personal Information, depending on the type of Personal Information, include:

• physical measures; for example: locked filing cabinets, restriction of access to offices, and company alarm systems;
• technical tools; for example: passwords and encryption software;
• organizational controls; for example: confidentiality agreements, limiting access on a "need-to-know" basis, staff training and security clearances.

6.2 When TSC Stores L.P. uses a third party to process information on its behalf, legal agreements require the third party to protect the privacy and confidentiality of the Personal Information. Further, these agreements ensure that the Personal Information is retained only as long as necessary to complete the assigned task and that the third-party organization only uses it for the specified purposes for which it is given.

6.3 TSC Stores L.P. has appropriate training programs and provides employees with information about its policies and procedures for protecting Customers' Personal Information and the importance of maintaining the confidentiality of Personal Information.
6.4 Following its limited use, Personal Information is disposed of or destroyed with care, following its limited use, to prevent unauthorized parties from gaining access to the information.

PRINCIPLE 7: Openness

7.1 TSC Stores L.P. is open about its policies and practices with respect to the management of Personal Information.
7.2 TSC Stores L.P. makes information about its privacy policies and procedures available to its Customers through written materials (a copy of this Policy is available upon request) and its Web Site (www.tscstores.com).

PRINCIPLE 8: Accountability

TSC Stores L.P. is responsible for the Personal Information under its control, including Personal Information disclosed by TSC Stores L.P. to a third party for data and list processing and shall designate one or more persons who are accountable for compliance with the Privacy Policy.

8.1 The Executive Committee is accountable for TSC Stores L.P. compliance with the Privacy Policy.

8.2 TSC Stores L.P. has appointed an internal Chief Privacy Officer. This person oversees TSC Stores L.P. compliance with the Privacy Policy.

8.3 TSC Stores L.P. uses privacy protection agreements to provide a comparable level of protection for Personal Information while the information is being processed by an authorized third party.
8.4 The Management of TSC Stores L.P. has developed procedures to implement the Privacy Policy, such as procedures to protect Personal Information, to receive and respond to complaints and enquiries, to inform and train our employees on privacy policies and procedures, and to make available information about the Privacy Policy to Customers.

PRINCIPLE 9: Individual Access

TSC Stores L.P. gives Customers access to their Personal Information and an account of its use and disclosure.

9.1 All Customer requests for access to Personal Information held by TSC Stores L.P. must be in writing and directed to: Chief Privacy Officer, TSC Stores L.P., 1950 Oxford Street E., London, Ontario N5V 2Z8, or e-mailed to: CPO@tscstores.com. Upon request, TSC Stores L.P. informs the Customer whether or not it holds Personal Information about that Customer, and discloses details of that Customer's Personal Information, including, where available, the source, its use, and third parties to which it has been disclosed.

9.2 TSC Stores L.P. may request sufficient information from the Customer including adequate identification to verify the identity of the Customer when requesting the existence, use and/or disclosure of Personal Information held by TSC Stores L.P. TSC Stores L.P. will assist any Customer who informs TSC Stores L.P. that he or she needs assistance in preparing for access.

9.3 TSC Stores L.P. responds to a request for information within thirty (30) business days of receipt of request.

9.4 Responding to a Customer request for information will usually be done at no or minimal cost to the Customer. However, a fee for reasonable costs incurred may be charged in responding to more complex requests, provided the Customer is informed of the fee in advance. The Personal Information requested is provided to the Customer in a form that is generally understandable.

9.5 TSC Stores L.P. amends the Personal Information contained in TSC Stores L.P. data bases or elsewhere, as required, when an individual demonstrates the inaccuracy or incompleteness of the Personal Information. An amendment may involve the correction, deletion or addition of information.

9.6 A Customer has the opportunity to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate. When a challenge is not resolved to the satisfaction of the Customer, TSC Stores L.P. will keep a written record of the challenge, and the existence of the challenge is transmitted to third parties who have received the challenged Personal Information.

9.7 When it is not possible to provide a list of third parties or agents to which TSC Stores L.P. has disclosed Personal Information about a Customer, TSC Stores L.P. provides a list of the third parties or agents to which it may have disclosed such Personal Information about the Customer.

9.8 If TSC Stores L.P. is unable to provide access to all the Personal Information it holds about a Customer, the reasons for denying access are provided to the Customer.

PRINCIPLE 10: Challenging Compliance

Any challenge to TSC Stores L.P.'s compliance with this policy may be addressed with the individual identified in paragraph 9.1. A Customer is able to address a challenge concerning TSC Stores L.P. compliance with the above principles with the individual identified in Section 1.2.

10.1 TSC Stores L.P. will respond to inquiries about its policies and procedures related to the handling of Personal Information.

10.2 TSC Stores L.P. investigates all complaints and responds within ninety (90) business days after receipt of written correspondence. If the complaint is found to be justified, TSC Stores L.P. takes appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.