Nelson Education Ltd. - Privacy Policy

A. SCOPE AND APPLICATION OF THE NELSON EDUCATION LTD. PRIVACY POLICY (the “Privacy Policy”):

The Privacy Policy applies to Personal Information about Individuals who interact with Nelson Education Ltd. that is collected, used or disclosed by Nelson Education Ltd.

The Privacy Policy applies to the management of Personal Information in any form whether oral, electronic or written. Nelson Education Ltd. reserves the right to amend this Privacy Policy from time to time.

The application of the Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations or agreements (such as collective agreements), or the order of any court or other lawful authority.

Exclusions from privacy protection:
The Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Nelson Education Ltd.: a) aggregate information that cannot be associated with a specific Individual, such as demographic statistics about Nelson Education Ltd. customers, or number of visitors and average time spent on a website; or b) information that is otherwise determined not to be Personal Information pursuant to, or is not regulated by, applicable privacy legislation. This Privacy Policy does not apply to personal information about our employees.

Note to Children
Although parts of Nelson Education Ltd.’s website provides information and activities for or relating to students, we do not knowingly accept any Personal Information from or about children. Teachers and parents must provide their own information (Personal Information or otherwise) in order for students to participate in our services or products.

Nelson Education Ltd. encourages parents and teachers to spend time with children and to monitor their online activities. Please protect your child’s privacy by instructing them to never provide Personal Information on this website or any other, or within any software registration process, without your permission.

Purposes for Collection and Use of Personal Information:
Nelson Education Ltd. has collected, continues to collect and use Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individuals’ needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest.

As examples of the above:

i) Nelson Education Ltd. may from time to time use an Individual’s Personal Information to contact the Individual about changes, enhancements or similar notices related to Nelson Education Ltd.’s products and services;

ii) if an Individual indicated that he/she was interested in receiving offers or information from Nelson Education Ltd. or certain of our selected sponsors or advertisers, Nelson Education Ltd. may send the Individual materials about products and services that Nelson Education Ltd. feels may be of interest to the Individual;

iii) if an Individual enters a contest or other promotion offered on a Nelson Education Ltd. website, Nelson Education Ltd. may, under the rules of the promotion, use the Individual’s name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion;

iv) if an Individual applies for a position with Nelson Education Ltd., Nelson Education Ltd. will collect Personal Information contained in and generated in relation to the Individual’s application, in order to evaluate the Individual’s application and assess whether to offer the Individual employment, which information is kept for a reasonable period of time, and may include Personal Information collected from Third Parties acting as references for the Individual.

Purposes for Disclosure of Personal Information and Transfer of Information:
Nelson Education Ltd. discloses Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individuals’ needs; c) to develop, enhance, market or provide products and services in which we reasonably believe you may be interested in; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest.

From time to time, we may be required to provide Personal Information in response to a court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may release certain Personal Information when we believe that such release is reasonably necessary to protect the rights, property and safety of others and ourselves.

You also understand that Nelson Education Ltd. may use your Personal Information and disclose your Personal Information to Third Parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction, and you consent to such disclosure. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing Personal Information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your Personal Information for substantially the same purposes as described in this Privacy Policy. In the event that the transaction does not go through, we will require by contract the other parties to not use or disclose your Personal Information in any manner whatsoever and for any purpose and to return or destroy same.

Nelson Education Ltd. sometimes transfers Personal Information to others, including to affiliated entities or unrelated companies (“service providers”), that carry out certain functions on our behalf, such as order fulfillment, data processing, accounting and administrative services, customer service and information technology services including, without limitation, hosting and data storage services. In those cases, we require those service providers not to use or disclose Individuals’ Personal Information for any purpose other than as directed by Nelson Education Ltd. Some of these service providers may be located outside of Canada, including in the United States or elsewhere outside of Canada for the purposes described in this Privacy Policy. Nelson Education Ltd. takes reasonable contractual or other measures to protect Individuals’ Personal Information while processed or handled by these service providers. If an Individual’s Personal Information is located outside of Canada it will be subject to legal requirements in those foreign countries applicable to Nelson Education Ltd.’s service providers, for example, lawful requirements to disclose Personal Information to government authorities in those countries.

Obtaining Consent:
If we require new or additional Personal Information, or if we use your Personal Information in a manner different than as expressed herein, Nelson Education Ltd. will inform Individuals how their Personal Information will be used by Nelson Education Ltd. and Nelson Education Ltd. will obtain consent from Individuals before or when it collects or uses the Personal Information. Nelson Education Ltd. will not attempt to deceive Individuals into giving consent.
An Individual’s consent can be express, implied, or given through an authorized representative. An Individual can withdraw consent at any time, with certain exceptions noted herein. Nelson Education Ltd., however, may collect, use or disclose Personal Information without the Individual’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

Note: If any Individual at any time has any questions or concerns about Nelson Education Ltd.’s Privacy Policy or privacy practices contained herein, the Individual can either:

i) write to the Chief Privacy Officer – Marlene Nyilassy, Vice President, Privacy, Nelson Education Ltd., 1120 Birchmount Road, Toronto, ON, M1K 5G4; or

ii) provide information to Nelson Education Ltd. through the form on its Internet Privacy page.

Refusing or withdrawing Consent:
Subject to legal and contractual requirements, an Individual can refuse to consent to Nelson Education Ltd.’s collection, use or disclosure of Personal Information about the Individual, or an Individual may withdraw the Individual’s consent to Nelson Education Ltd.’s further collection, use or disclosure of Personal Information at any time in the future by giving Nelson Education Ltd. reasonable notice, unless: i) the consent is otherwise required by law or ii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If an Individual refuses to consent or withdraws his or her consent where such consent relates to the production services requested, Nelson Education Ltd. may not be able to provide the Individual, or continue to provide the Individual, with such products, services or information.

Internet Aspects:
Information may be collected when an Individual visits all websites of Nelson Education Ltd. (“Nelson Education Ltd. Sites”). Although the information collected, used or disclosed on the Internet as described below often does not constitute Personal Information (and to the extent that such is the case, then the obligations under the Privacy Policy do not extend to such information), Nelson Education Ltd. provides the details below about Internet aspects of Nelson Education Ltd. Services for the purposes of disclosure about Nelson Education Ltd. Services.

Internet Protocol Address (IP Address)
When an Individual’s web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address." For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time the user logs on.
Nelson Education Ltd. may use the user’s IP Address to:

facilitate the diagnosis and remedy of a technical problem reported by the user’s or Nelson Education Ltd.’s technical team;
display (or allow the display by Third Party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user’s geographic area; and
estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.

Cookies
A cookie is a small text file, which often includes an anonymous unique identifier, that is sent to the user’s web browser from a web site's computers and is stored on the user’s computer's hard drive. Cookies cannot be used to run programs or deliver viruses to a user’s computer.

Nelson Education Ltd. may use cookies to:

improve the operation and performance of the Nelson Education Ltd. services and to make Nelson Education Ltd. services easier and more convenient to use. For example, cookies help Nelson Education Ltd. provide more personalized services by recalling user preferences on subsequent visits (e.g. language preference). Cookies also allow Nelson Education Ltd. to save passwords and preferences for a user so that the user will not have to re-enter them on the next visit to a Nelson Education Ltd. Site;
measure aggregate user traffic and demographic statistics related to Nelson Education Ltd. Services and advertisements (e.g. number of users, average time spent, average age and similar statistics). This information helps Nelson Education Ltd. to better understand when to update, change or offer new services and provides Nelson Education Ltd. with details as to the performance of Third Party advertisements and content. This information may be reported, in aggregate form only, to Nelson Education Ltd.’ current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports;
Nelson Education Ltd. and Third Party advertising providers may use cookies when serving advertisements on Nelson Education Ltd. Sites. In some cases, advertisements from Third Party advertisers are delivered to users (in conjunction with Nelson Education Ltd. Services) by such Third Party advertisers, or by separately contracted advertising providers on their behalf, and not by Nelson Education Ltd.; as such, the Third-party advertisers' use of cookies is subject to their own privacy policies, not the Privacy Policy, and users should consult the privacy policies of such Third Party advertisers.

Most browsers are initially set up to accept cookies. If a user prefers, the user can reset his/her browser either to notify the user when the user has received a cookie, or to refuse to accept cookies. The user should understand that while Nelson Education Ltd. do not require a user to use cookies, certain Nelson Education Ltd. Services will not function properly if a user sets his/her browser to not accept cookies. In most circumstances, the information captured cannot identify you as an Individual.

Tracking pixels consisting of a clear gif (also known as web beacons) are used in combination with cookies to help Site operators understand how visitors interact with their websites. A clear gif is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site. The use of a clear gif allows the Site to measure the actions of the visitor opening the page that contains the clear gif. Nelson may use clear gifs on this Site, in our e-mails, or in our advertisements on other web sites. Nelson utilizes clear gifs to measure visitor behavior, to help us improve visitor experience, and to manage site content.

Nelson uses analytics technology to obtain information to improve the usefulness of the Site. We measure and analyze non-identifying, aggregate usage, and volume statistical information from Site visitors in order to administer the Site, and to constantly improve the quality of our service and site performance. Information gathered may include, but is not limited to, the following: the activity of the Site visitor's browser when the visitor is viewing the Site; the site path of visitors; general information regarding the visitor's internet service provider and host, and the time visitors come to the Site. Please note that this is not personal information, only general summaries of our visitors' usage of the Site.

Web Beacons
Certain Nelson Education Ltd. Services may contain electronic images known as “Web beacons” – sometimes called single-pixel gifs – that allow Nelson Education Ltd. to count users who have visited those pages and to deliver co-branded services. Web beacons are not used to access Personal Information; they are a technique used to compile aggregated statistics about Nelson Education Ltd. service usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. Certain Nelson Education Ltd. Services web pages may also contain Web beacons placed there by Nelson Education Ltd.’ advertising partners to help Nelson Education Ltd. determine the effectiveness of Nelson Education Ltd. ’ Internet advertising campaigns.

Links To Other Sites And Advertisements
A Nelson Education Ltd. Service may contain links to other websites and services. While Nelson Education Ltd. tries to link only to sites and services that share Nelson Education Ltd.’s high standards and respect for privacy, a user should understand that Nelson Education Ltd. is not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Policy applies only to the Nelson Education Ltd. services related to this Privacy Policy.

Additional Information
Nelson Education Ltd. automatically collect certain information about the user’s computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring Web site addresses. This information is used by Nelson Education Ltd. to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the Nelson Education Ltd. Sites.

Certain Nelson Education Ltd. Services may be co-branded and offered in conjunction with another company. If a user registers for or uses such services, both Nelson Education Ltd. and the other company may receive information collected in conjunction with the co-branded services.

Changes to Privacy Policy

This Privacy Policy is effective as of May 20th, 2010. If Nelson Education Ltd. makes a material change to this Privacy Policy, we will post a notice of same on our website and highlight the changes. We will also notify Individuals via email and give Individuals an opportunity to opt-out of the new data uses.
Questions or Queries
If you have any questions or queries about this Privacy Policy or Nelson education Ltd.’s handling of your personal information, please contact our Chief Privacy Officer.

The Chief Privacy Officer is Marlene Nyilassy, Vice President, Privacy, and can be contacted at 1120 Birchmount Road, Toronto, Ontario, M1K 5G4, (416) 750-6670 or by fax at (416) 508-1091, or by email at marlene.nyilassy@nelson.com.

B. The PRIVACY Policy in Detail

Definitions

Nelson Education Ltd. – means Nelson Education Ltd. and all companies providing services under the brands of Nelson Education Ltd., including but not limited to affiliates and related entities, and any successor company or companies thereof, as a result of corporate reorganization or restructuring.

collection - the act of gathering, acquiring, recording or obtaining Personal Information from any source, including Third Parties, by any means.

consent - voluntary agreement by an informed Individual with respect to 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 Nelson Education Ltd. Implied consent is consent that can reasonably be inferred from an Individual’s action or inaction.

disclosure - making Personal Information available to a Third Party.

Individual - an individual who (a) corresponds with Nelson Education Ltd., including complaints and including applications for employment; (b) enters a contest sponsored by Nelson Education Ltd.; (c) uses, or applies to use, the products or services of Nelson Education Ltd.; (d) viewers, readers, subscribers, advertisers and Internet users who are exposed to the media content of Nelson Education Ltd. and about whom Nelson Education Ltd. collects Personal Information.

Personal Information - information that can identify an Individual directly or indirectly or through other reasonably available means, a) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; b) information collected, used or disclosed in the course of journalistic, literary or artistic activities; c) aggregate information that cannot be associated with a specific person, such as demographic statistics about Nelson Education Ltd. customers, or number of visitors and average time spent on a website; or d) information that is determined not to be Personal Information pursuant to applicable privacy legislation.

Third Party – a person other than an Individual or his agent, or an organization other than Nelson Education Ltd.

use - the treatment, handling, and management of Personal Information by Nelson Education Ltd.

Privacy Principles Described

Principle 1 - Accountability
Nelson Education Ltd. is responsible for Personal Information under its control and shall designate one or more persons who are accountable for Nelson Education Ltd.’s compliance with the following principles.

1.1 Responsibility for ensuring compliance with the provisions of the Privacy Policy rests with the senior management of Nelson Education Ltd., which shall designate one or more persons to be accountable for compliance with the Privacy Policy. Other people within Nelson Education Ltd. may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information.

1.2 Nelson Education Ltd. has designated a Chief Privacy Officer to oversee compliance with the Privacy Policy. The Chief Privacy Officer is Marlene Nyilassy, Vice President, Privacy, and can be contacted at 1120 Birchmount Road, Toronto, Ontario, M1K 5G4, (416) 750-6670 or by fax at (416) 508-1091, or by email at marlene.nyilassy@nelson.com.

1.3 Nelson Education Ltd. is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. Nelson Education Ltd. shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7).

1.4 Nelson Education Ltd. has implemented policies and procedures to give effect to the Privacy Policy, including: a) implementing procedures to protect Personal Information and to oversee Nelson Education Ltd.’s compliance with the Privacy Policy; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about Nelson Education Ltd.’s policies and practices; and d) developing public information to explain Nelson Education Ltd.’s policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information
Nelson Education Ltd. has collected and collects Personal Information for the purposes set out below, and shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

2.1 Nelson Education Ltd. has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individuals’ needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest.

As examples of the above:
i) Nelson Education Ltd. may from time to time use an Individual’s Personal Information to contact the Individual about changes, enhancements or similar notices related to Nelson Education Ltd. products and services;
ii) if an Individual indicated that he/she was interested in receiving offers or information from Nelson Education Ltd. or certain of our selected sponsors or advertisers, Nelson Education Ltd. may send the Individual materials about products and services that Nelson Education Ltd. feels may be of interest to the Individual; and
iii) if an Individual enters a contest or other promotion offered on a Nelson Education Ltd. Site, Nelson Education Ltd. may, under the rules of the promotion, use the Individual’s name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion.

Further references to “identified purposes” mean the purposes identified in this Principle 2.

2.2 Nelson Education Ltd. shall specify orally, electronically or in writing the identified purposes to the Individual at or before the time Personal Information is collected. Upon request, persons collecting Personal Information shall explain these identified purposes or refer the Individual to a designated person within Nelson Education Ltd. who shall explain the purposes.

2.3 Unless required by law, Nelson Education Ltd. shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Individual.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an Individual are required for the collection, use or disclosure of Personal Information, except where inappropriate.

3.1 Generally, Nelson Education Ltd. shall seek consent to use and disclose Personal Information at the same time it collects the information. However, Nelson Education Ltd. may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.

3.2 In obtaining consent, Nelson Education Ltd. shall use reasonable efforts to ensure that an Individual is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Individual.

3.3 Where Personal Information is required for the supply of a product or service, Nelson Education Ltd. will not be able to collect, use or disclose Personal Information of an Individual for the purpose of supplying such product or service unless the Individual has consented to the collection, use or disclosure of Personal Information for such identified purpose.

3.4 In determining the appropriate form of consent, Nelson Education Ltd. shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Individuals.

3.5 In general, the use of products and services by an Individual constitutes implied consent for Nelson Education Ltd. to collect, use and disclose Personal Information for all identified purposes, so long as the Individual, as applicable, has been made aware of the terms of this Privacy Policy.

3.6 An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. An Individual may contact Nelson Education Ltd. for more information regarding the implications of withdrawing consent.
3.7 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Individual. For example, Nelson Education Ltd. may collect or use Personal Information without knowledge or consent if it is clearly in the interests of the Individual and consent cannot be obtained in a timely way, such as when the Individual is a minor, seriously ill or mentally incapacitated.
Nelson Education Ltd. may also collect, use or disclose Personal Information without knowledge or consent if seeking the consent of the Individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

Nelson Education Ltd. may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual or property is threatened.

Nelson Education Ltd. may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein.

Principle 4 - Limiting Collection of Personal Information
Nelson Education Ltd. shall limit the collection of Personal Information to that which is necessary for the purposes identified by Nelson Education Ltd.
Nelson Education Ltd. shall collect Personal Information by fair and lawful means.

4.1 Nelson Education Ltd. collects Personal Information primarily from Individuals.

4.2 Nelson Education Ltd. may also collect Personal Information from other sources including credit bureaus (only to the extent that credit is being extended to an Individual), employers or personal references, or other Third Parties that represent that they have the right to disclose the information.

Principle 5 - Limiting Use, Disclosure and Retention of Personal Information
Nelson Education Ltd. shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Individual or as required by law. Nelson Education Ltd. shall retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected.

5.1 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Individual. (See Principle 3.7)

5.2 In addition, Nelson Education Ltd. may disclose an Individual’s Personal Information to: a) another person for the development, enhancement, marketing or provision of any of the products or services of Nelson Education Ltd.; b) a person who, in the reasonable judgment of Nelson Education Ltd., is seeking the information as an agent of the Individual; c) Nelson Education Ltd. to permit the provision of services requested by the Individual, and d) a Third Party or Third Parties, where the Individual consents to such disclosure or disclosure is required or permitted by law.
You also understand that Nelson Education Ltd. may use and disclose your personal information to Third Parties connected with the proposed or actual financing, insuring, sale, securitization, assignment or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and/or performing the proposed transaction. These purposes may include, as examples, permitting such parties to determine whether to proceed or continue with the transaction, fulfilling any reporting or audit requirements to such parties, and/or disclosing Personal Information as part of concluding a sale or transfer of assets. Our successors and assigns may collect, use and disclose your Personal Information for substantially the same purposes as described in this Privacy Policy.

5.4 Only those employees of Nelson Education Ltd. who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of Nelson Education Ltd., are granted access to Personal Information about Individuals.

5.5 Nelson Education Ltd. shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about an Individual, Nelson Education Ltd. shall retain, for a period of time that is reasonably sufficient to allow for access by the Individual, either the actual information or the rationale for making the decision.

5.6 Nelson Education Ltd. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information
Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1 Personal Information used by Nelson Education Ltd. shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an Individual.

6.2 Nelson Education Ltd. shall update Personal Information about Individuals as and when necessary to fulfill the identified purposes or upon notification by the Individual.

Principle 7 - Security Safeguards
Nelson Education Ltd. shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.

7.1 Nelson Education Ltd. shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Nelson Education Ltd. shall protect the information regardless of the format in which it is held.

7.2 Nelson Education Ltd. shall protect Personal Information disclosed to Third Parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

7.3 All employees of Nelson Education Ltd. with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.

Principle 8 - Openness Concerning Policies and Practices
Nelson Education Ltd. shall make readily available to Individuals specific information about its policies and practices relating to the management of Personal Information.

8.1 Nelson Education Ltd. shall make information about its policies and practices easy to understand, including: a) the title and address of the person or persons accountable for the compliance with the Privacy Policy and to whom inquiries or complaints can be forwarded; b) the means of gaining access to Personal Information held by Nelson Education Ltd.; and c) a description of the type of Personal Information held by Nelson Education Ltd., including a general account of its use.

8.2 Nelson Education Ltd. shall make available information to help Individuals exercise choices regarding the use of their Personal Information.

Principle 9 - Access to Personal Information
Nelson Education Ltd. shall inform an Individual of the existence, use and disclosure of his or her Personal Information upon request and shall give the Individual access to that information.

An Individual shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

9.1 Upon request, Nelson Education Ltd. shall afford to an Individual a reasonable opportunity to review the Personal Information in the Individual’s file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Individual.

9.2 In certain situations, Nelson Education Ltd. may not be able to provide access to all of the Personal Information that they hold about an Individual. For example, Nelson Education Ltd. may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, Nelson Education Ltd. may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or if the information was collected as part of journalistic, literary or artistic activities. If access to Personal Information cannot be provided, Nelson Education Ltd. shall provide the reasons for denying access upon request.

9.3 Upon request, Nelson Education Ltd. shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Nelson Education Ltd. shall provide a list of organizations to which it may have disclosed Personal Information about the Individual when it is not possible to provide an actual list.

9.4 In order to safeguard Personal Information, an Individual may be required to provide sufficient identification information to permit Nelson Education Ltd. to account for the existence, use and disclosure of Personal Information and to authorize access to the Individual’s file. Any such information shall be used only for this purpose.
9.5 Nelson Education Ltd. shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Individual’s file. Where appropriate, Nelson Education Ltd. shall transmit to Third Parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.

9.6 An Individual can obtain information or seek access to his or her Personal Information by contacting a designated representative at Nelson Education Ltd. principal office.

Principle 10 - Challenging Compliance
An Individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of Nelson Education Ltd. with the Privacy Policy.

10.1 Nelson Education Ltd. shall maintain procedures for addressing and responding to all inquiries or complaints from Individuals about Nelson Education Ltd.’s handling of their Personal Information. If any Individual at any time has any questions or concerns about Nelson Education Ltd.’s Privacy Policy or privacy practices as herein contained, the Individual can either:
i) write to Marlene Nyilassy, Vice President, Privacy, at Nelson Education Ltd., 1120 Birchmount Road, Toronto, ON, M1K 5G4, or by email at marlene.nyilassy@nelson.com; or
ii) provide information to Nelson Education Ltd. through the form on its Internet Privacy page.

10.2 Nelson Education Ltd. shall inform Individuals about the existence of these procedures as well as the availability of complaint procedures.

10.3 The person or persons accountable for compliance with the Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 Nelson Education Ltd. shall investigate all complaints concerning compliance with the Privacy Policy. If a complaint is found to be justified, Nelson Education Ltd. shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual shall be informed of the outcome of the investigation regarding his or her complaint.

Most recently amended May 25, 2010.
6514360.4




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