Privacy

Acadian Timber Corp. ("Acadian") respects the privacy of all stakeholders. Acadian is committed to keeping personal information accurate, confidential, secure and private in accordance with applicable laws. The Acadian Privacy Policy is a formal statement of principles and guidelines concerning the protection of personal information collected, used and disclosed by Acadian.

INTRODUCTION

Acadian is a leading supplier of primary forest products in Eastern Canada and the Northeastern U.S.

In the course of its business activities, Acadian may collect certain personal information about its individual customers, suppliers and other stakeholders, in accordance with applicable laws.

“Personal information” means information about an identifiable, individual person. This may include, without limitation, the individual’s address, age, gender, income, employment status, credit history, debts and liabilities, personal preferences and other information. Personal information does not include the name, title, business address or telephone number of an employee of an organization.

The Acadian Privacy Policy is based on and will be applied to comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable privacy and data protection laws. For more information about Privacy in Canada, visit the official web site of the Privacy Commission of Canada at www.privcom.gc.ca. The Acadian Privacy Policy describes the ten principles Acadian follows to ensure protection of personal information when the company collects, uses or discloses it in the course of carrying on commercial activities. Acadian's corporate headquarters are in Canada, but as a North American company, Acadian may collect and transfer personal information across borders and between legal entities within Acadian. Accordingly, to the extent applicable, Acadian must comply with PIPEDA, provincial privacy legislation as it is enacted, and privacy legislation in jurisdictions where Acadian carries on business. Acadian believes that this Privacy Policy, as supplemented by additional requirements of other jurisdictions where Acadian conducts business and additional requirements that apply to certain types and sources of personal information, meets the requirements set out in PIPEDA and other applicable privacy laws. Acadian businesses in the United States with different privacy laws are expected to make all reasonable efforts to meet the requirements of this Privacy Policy. Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against Acadian or any third party or any of their respective directors, officers, employees, agents or representatives (collectively, the “Acadian Group”); nor will the existence of this Privacy Policy or its application impose any obligations or liability upon the Acadian Group, or add to any such obligation or liability, that the Acadian Group does not already otherwise have to any individual or person at law or otherwise.

All Acadian employees with access to personal information must adhere to the Acadian Privacy Policy and its application. To this end, Acadian’s Chief Financial Officer is designated as Acadian’s Privacy Officer to ensure compliance by all Acadian employees.

THE TEN PRINCIPLES OF PRIVACY

Principle 1 – Accountability
Acadian is accountable for all personal information in its possession, including personal information disclosed to third parties for purposes of providing products and services requested by customers, employees, suppliers and other stakeholders.

Principle 2 – Identifying Purposes for Collection of Personal Information
Acadian will identify the purpose for which it is collecting personal information, before or at the time the information is collected. Some of the purposes for which Acadian collects, uses or discloses personal information are described in section 3 below.

Principle 3 – Consent for Collection, Use or Disclosure of Personal Information
An individual’s knowledge and consent is required for the collection, use or disclosure of his or her personal information, unless otherwise permitted by law. Consent can be express or implied and may be given through an authorized representative. Consent can be withdrawn at any time upon written request to the Acadian Privacy Officer, subject to legal or contractual restrictions and reasonable notice. Acadian may collect, use or disclose personal information without knowledge or consent in exceptional circumstances, such as where permitted or required by law.

Principle 4 – Limiting Collection of Personal Information
The information collected from an individual will be limited to those details necessary for the purposes identified by Acadian. Information will be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
Personal information will only be used or disclosed for the purposes for which it was collected, unless the individual has otherwise consented, or when it is required or permitted by law. Personal information will be retained by Acadian only as long as necessary to fulfill the purposes for which it was collected.

Principle 6 – Accuracy of Personal Information
Acadian will keep personal information as accurate, complete and current as necessary for the purposes for which it is to be used. An individual may have his or her information amended as appropriate where it is found to be inaccurate or incomplete.

Principle 7 – Safeguarding Personal Information
Personal information is safeguarded using measures appropriate to the sensitivity of the information.

Principle 8 – Openness Concerning Policies and Practices

Acadian will make information available to individuals about its policies and practices related to the management of personal information. This information is available on the Acadian web site, www.acadiantimber.com, or through alternate means upon request to the Acadian Privacy Officer.

Principle 9 – Access to Personal Information

As required by applicable laws, Acadian will inform an individual of the existence, use and disclosure of his or her personal information upon request, and subject to certain exceptions, will give the individual access to that information. If Acadian declines to provide such access for lawful reasons, Acadian will explain the reasons, except where prohibited by law.

Principle 10 – Addressing Complaints and Suggestions
Individuals may challenge Acadian’s compliance with this Privacy Policy. Acadian has policies and procedures to receive, investigate and respond to complaints and questions. Please contact the Acadian Privacy Officer to express concerns or request access to personal information. Contact information is provided in section 4 below.

APPLICATION OF THE TEN PRIVACY PRINCIPLES

What kind of information does Acadian collect?
Acadian gathers and uses personal information in order to provide customers, suppliers and other stakeholders with the products and services requested or to offer additional products or services these stakeholders may be interested in. Providing Acadian with personal information is the choice of each individual. However, Acadian may not be able to provide certain products or services if certain information is not provided.

The nature of each request will determine the kind of personal information Acadian might request.

Acadian may keep a file with contact history to be used for inquiry purposes so that it may ensure that individuals are satisfied with Acadian’s products and services.

How does Acadian use personal information?
Acadian and its agents, affiliates and service providers may collect, use and/or disclose personal information for the following purposes:

  1. To communicate with stakeholders and maintain commercial relations in order to provide products and services, to administer accounts, make and receive payments, and fulfill contractual obligations;

  2. To monitor its products and service and report back to individuals to ensure their satisfaction with the provision of such products and services;

  3. To consider whether Acadian or any of its affiliates should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and to confer with banking institutions;

  4. To distribute our promotional information and other material to individuals on our mail and e-mail lists;

  5. To develop, enhance, market, sell, provide and inform individuals of Acadian’s products and services;

  6. To manage and develop Acadian’s and its affiliates’ businesses and operations;

  7. As permitted by, and to comply with, any legal or regulatory requirements or provisions; and

  8. For any other purpose to which an individual consents.

When May Acadian Disclose Personal Information?
Acadian is obliged to keep personal information confidential except as described in this Privacy Policy, including under the following circumstances:

  1. When authorized by the individual Certain of the products and services offered by Acadian may require it to obtain personal information in order to perform the services it has been engaged to provide. Acadian will use this information to tailor programs to meet the needs and objectives of the person requesting the services.

  2. When required by law The type of information Acadian is legally required to disclose usually relates to government taxation and employment reporting requirements. In some cases, such as under a court order, Acadian may be required to disclose certain information to persons specified in the court order.

  3. When permitted by law Privacy legislation provides for certain situations where Acadian is legally permitted to disclose personal information without consent. Examples include without limitation situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.

With Whom May Acadian Share Information?
Acadian cannot share information without consent unless otherwise permitted by law. However, from time to time Acadian may need to provide information to the following persons for the purposes set out above.

  1. Acadian Employees
    In the course of daily business, access to personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Acadian employees are required to follow all applicable laws and regulations, including this Privacy Policy and Acadian’s Code of Business Conduct. Unauthorized use or disclosure of confidential client information by a Acadian employee is prohibited and may result in disciplinary measures including dismissal.

  2. Acadian Affiliates
    Acadian may share personal information with its affiliates for the purposes described in this Privacy Policy.

  3. Acadian Third Party Suppliers
    Acadian may engage and coordinate third party suppliers to provide certain services on Acadian’s behalf or otherwise for the purposes described in this Privacy Policy. Such suppliers are only given the information required to provide the specific service for which Acadian contracts them to provide. Suppliers are required to protect the confidentiality of personal information, and are prohibited from doing anything with this information that Acadian has not authorized them to do. They are required to treat all personal information in a manner consistent with the Acadian Privacy Policy.

  4. Financial Institutions
    Acadian may disclose personal information to a financial institution, or other organization or individual retained by Acadian for the purposes described in this Privacy Policy, including without limitation, to evaluate creditworthiness, to collect debts outstanding on an account, or in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements.

  5. Agents of the Individual
    Acadian may collect or disclose personal information for the purposes described in this Privacy Policy from or to a person who, in the reasonable judgment of Acadian, is providing or seeking the information as the agent of the subject individual.

  6. Other Third Parties
    Acadian may disclose personal information to third parties with the consent of the subject individual or where disclosure is required or permitted by law.

How Does Acadian Safeguard Information?
Acadian has controls in place to maintain the security of its information and information systems. Appropriate controls are placed on Acadian’s computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

Is Acadian’s Web Site Secure?
Acadian offers customers access to certain information through its web site. www.acadiantimber.com provides general information about Acadian and the products and services it offers.

Acadian will ensure that any information accessed or provided through these sites remains secure.

In order to facilitate navigation on the Acadian web site and those of its subsidiaries and preserve settings between visits, Acadian may use “cookie” technology. Acadian does not use cookies to store information about its visitors. Cookies are small pieces of data stored by Internet browser on a computer’s hard drive, which makes browsing easier when pages are revisited. Web browsers may be set to notify the user when a cookie is received or to prevent cookies from being sent. Please note, however, that by not accepting cookies, the functionality provided to visitors to these sites may be limited.

Acadian’s subsidiaries may collect information that identifies users who require secure access to Acadian sites or who send Acadian correspondence via the internet. Acadian’s various systems log information about which users access the system and what options are used. In the case of correspondence to Acadian, Acadian only uses information contained within such communications to respond to the user or to identify how to best resolve the situation outlined in the message. Acadian may collect such correspondence, but no further information (other than what is needed to resolve the matter) will be collected.

The Acadian’s Privacy Policy does not apply to external web sites to which its site links. Acadian makes no representation about the privacy policies on external web sites, and is not responsible for the privacy practices employed by other web sites.

How do I access and amend my information?
To access personal information in accordance with Principle 9, individuals should make a written request to the Acadian Privacy Officer.

How do I opt out or withdraw my consent?
Should an individual not want to share their personal information with Acadian’s employees, affiliates or third party suppliers, subject to legal restrictions, consent can be withdrawn for certain of the purposes described in this Privacy Policy by contacting the Acadian Privacy Officer.

QUESTIONS, CONCERNS AND COMPLAINTS

Questions, concerns or complaints about personal information, or about the Acadian Privacy Policy, should be directed to the Acadian Privacy Officer at the following address:

Acadian Timber Corp.
Chief Financial Officer
Suite 458 – 550 Burrard Street
Box 51, Bentall V
Vancouver, BC V6C 2B5
Tel: (604) 669-3141
Fax: (604) 687-3419

©  2017. Acadian Timber Corporation.