CUSTOMER DATA PRIVACY POLICY

Effective:  October 1, 2011

At Wallenstein Feed & Supply Ltd., the privacy and confidentiality of your information has always been an important aspect of how we operate.  Wallenstein Feed & Supply Ltd wishes to advise all of our customers that we have taken all the required measures to become compliant with the Personal Information Protection and Electronic Documents Act, (“PIPEDA”) by developing our own Privacy Policy and by communicating this to our customers along with our continuing commitment to the protection of their personal information.

We recognize the importance of privacy of personal information and we are committed to treating any such information which we collect, use or disclose in a responsible manner and only as reasonably necessary for our purposes.

Introduction

This Privacy Policy governs our dealing with. “personal information”.  Personal information means any information about an identifiable individual including information such as age, gender, religion, ethnic background, family status, political affiliations, health, home address and home phone number.  Personal information does not include business information such as the name, title, business address, or telephone number of an employee of an organization.

Accountability

We are responsible for all personal information in our possession or control.  This would extend to information to which third parties who provide goods or services to our firm (such as our accountants, contractors, or consultants, security and maintenance persons, information technology advisors, delivery persons, temporary personnel, website managers, cleaners, bankers) may have access.  We restrict such access to such third parties as much as is reasonably possible and request their assurances that they follow appropriate privacy principles.

Why we collect Personal Information

The primary purposes for which we collect, use and disclose personal information is to serve our customers and potential customers, to market our services and other purposes which would be considered related or otherwise reasonable in the circumstances.

For example, we primarily collect, use and disclose personal information for the following reasons:

• To permit us to market or promote our services to customers and prospective customers

We also collect, use and disclose personal information for secondary purposes such as:

• To advise customers on industry trends in advertising
• To invoice customers, process or collect accounts
• To provide mailings, seminars or invitations to special events
• To communicate new developments at our company, in the industry or in other matters of interest to our customers or prospective customers
• To assess and evaluate the performance of our staff and services

If we plan to use or disclose personal information we have collected for a purpose not previously identified, we will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the personal information has been collected before use or disclosure.

Consent

Generally all personal information is held in strict confidence and we will obtain consent, either express or implied, to use or disclose personal information about an individual unless otherwise permitted or required by law.

The way in which we seek consent, including whether it is express or implied, will vary depending upon the sensitivity of the information and the reasonable expectations of the individual.  Provided that we are informed of same, an individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

There are some circumstances where we are permitted or required under law to collect, use or disclose personal information without the knowledge or consent of the individual.  These circumstances include:  where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of an agreement or a contravention of a law; to act in respect to an emergency that threatens the life, health or security of an individual; for debt collection; or to comply with subpoena, warrant, court order or Canadian Feed Inspection Agency (CFIA).

Safeguarding

Wallenstein Feed & Supply Ltd. will take appropriate steps to ensure adequate safeguards are in place to protect the personal information which we obtain.

Our safeguards include ensuring the paper information is stored in a supervised or secure location, including locked  filing  cabinets  and restricted  access  to our  offices and that electronic information is also secure with restricted third party access and through the use of passwords.  Our staff is trained to ensure that they are aware of the sensitivity of such information and that they will collect,  use  and  disclose  personal  information only as necessary to perform their duties and in accordance with this policy.  Our third party contractors or agents who have access to personal information will be required to confirm that they follow appropriate privacy practices.

Retention

While we do not intend to keep personal information for longer than is reasonable, we do keep personal information for some time so that we are able to answer questions about our services and to account to normal business audit procedures.  Inactive customer files are generally destroyed after seven years.  Our customer contact information and directories are kept longer unless you advise us that you wish to have the same removed.  Our accounting and financial files are normally kept for a minimum of seven years.

We destroy paper files with personal information by shredding or discarding same in garbage receptacles; we destroy electronic information by deleting it.  We may also send or return the personal information to our customers.

Openness and Access

With some exceptions, we will give you access to the personal information we retain about you upon request.  We will need to confirm your identity before providing such access.  We ask that you provide any request or identify any problem relating to such personal information in writing.  We will respond with 30 days with the information requested or if this is not possible we will advise you of the reason.

Other exceptions may include information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record.

Amendments

We will from time to time review and revise our privacy practices and this Privacy Policy.  In the event of an amendment, a notice will be posted on our website: www.wfs.ca or in our offices or other appropriate firm communications.  Any changes will apply from the date of posting on the website.

Questions

Any questions or complaints about our Privacy Policy can be directed to our Privacy Officer, the Human Resources Manager at Ph: (519) 669-5143 Ext # 230 or email: privacy@wfs.ca.