Pacific Customs Brokers Ltd. Privacy Code

Pacific Customs Brokers Ltd. understands that privacy is an important issue for our clients, and one that we have taken steps to protect. This Policy outlines the principles and procedures we apply in protecting the confidentiality and security of personal client information. It is based on the Canadian Standards Association (CSA) Model Code for the protection of personal information, and designed to comply with the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") as well as applicable Provincial privacy legislation (the "Act"). In doing so we have tailored our own privacy principles to meet the specific needs and expectations of our business.

This Policy applies to personal information collected about Pacific Customs Brokers Ltd. clients and individual representatives of corporate clients. "Personal Information" is information about an individual that is connected to that person as an individual. It does not include the name, title or business address or telephone number of an employee of an organization.

Accountability

Pacific Customs Brokers Ltd. is responsible for all Personal Information under its control.

Accountability for our compliance with privacy principles rests with our Privacy Officer or Officers as named on this website, even though other individuals within Pacific Customs Brokers Ltd. have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Privacy Officer.

Pacific Customs Brokers Ltd. is responsible for Personal Information in our possession or custody, including information that has been transferred to a third party for processing. We will use contractual or other means to provide a comparable level of protection when the information is being processed by a third party.

Identifying Purposes

Pacific Customs Brokers Ltd. will identify and document the purposes for which we collect, use, or disclose Personal Information at or before the time of collection.

The purposes will be limited to those which are related to our business and which a reasonable person would consider are appropriate in the circumstances. We collect, use, and disclose Personal Information concerning our customers for the following reasons:

• To provide timely, reliable and value-added services to customers including domestic and international shipping, shipment tracking, customs brokerage, account management and billing, global logistics, supply chain management, information management and technical support, e-commerce, and related services;
• To establish a customer relationship and to communicate with customers;
• To develop, implement, market, and manage services for customers;
• To assist in law enforcement purposes, to collect unpaid debts, for credit reporting and rating purposes, and to protect the business interests of Pacific Customs Brokers Ltd. and its customers;
• To manage and promote the business activities of Pacific Customs Brokers Ltd.; and
• To meet requirements imposed by law.

We collect, use, and disclose Personal Information concerning our employees for the following reasons:

• To recruit, train, recognize, and retain a highly qualified and motivated workforce;
• To establish and maintain harmonious employer-employee relations;
• To administer Pacific Customs Brokers Ltd. policies and procedures, including investigations related thereto;
• To manage and promote the business activities of Pacific Customs Brokers Ltd.;
• To administer compensation and benefits;
• To develop, manage, and promote employee services; and
• To meet requirements imposed by law.

If Pacific Customs Brokers Ltd. plans to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.

We will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the Personal Information is collected either at the time of collection or after collection but before use. We will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.

Consent

Personal Information will only be collected, used, or disclosed with the knowledge and consent of the individual, except where inappropriate.

The way in which Pacific Customs Brokers Ltd. seeks consent, including whether it is express or implied, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. We will inform individuals of any implications of withdrawing consent.

Typically, we will seek consent for the use or disclosure of information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (such as where we want to use information for a purpose not previously identified).

Pacific Customs Brokers Ltd. will not, as a condition of the supply of services, require an individual to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill the explicitly specified and legitimate purposes.

In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include: Personal Information which is subject to solicitor-client privilege or is publicly available as defined by regulation; 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 a subpoena, warrant or court order.

Limiting Collection

Pacific Customs Brokers Ltd. will only collect personal information for the purposes identified, and only use methods that are lawful. We do not collect information indiscriminately.

Limiting Use, Disclosure, and Retention

Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as necessary to fulfill the identified purposes.

Personal Information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, erased, or made anonymous.

Accuracy

Pacific Customs Brokers Ltd. will use our best efforts to ensure that Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

We will use our best efforts to ensure that Personal Information that is used on an ongoing basis, including information that is disclosed to third parties and information that is used to make a decision about an individual, is accurate,complete, and up-to-date.

Safeguards

Pacific Customs Brokers Ltd. will protect Personal Information with safeguards appropriate to the sensitivity of the information.

Our safeguards will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will make our employees aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.

Our methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances and limiting access on a "need-to-know" basis), and technological measures (for example, the use of passwords and encryption).

Openness

Pacific Customs Brokers Ltd. will make specific information about our policies readily available, except to the extent this is confidential commercial information.

The information we will make available will include: how to gain access to Personal Information; the type of Personal Information held by us, including a general account of its use; general information concerning our Code and policies; what Personal Information is made available to related companies; and how to contact our Privacy Officer.

Individual Access

Upon written request, Pacific Customs Brokers Ltd. will inform an individual of the existence, use, and disclosure of his or her Personal Information and we will give the individual access to that Personal Information. An individual can challenge the accuracy and completeness of his or her Personal Information and have it amended as appropriate.

Pacific Customs Brokers Ltd. will respond to an individual's written request within a reasonable time (generally within 30 days) unless we require additional time to fulfill the request. In such cases, we will send a notice of extension advising of the new time limit and the reasons for extending it so that the client may properly consider his/her remedies. We will assist any individual who informs us that they need assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of Personal Information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is generally understandable. Where possible, we will indicate the source of the information.

In providing an account of third parties to which we may have disclosed Personal Information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed Personal Information, we will provide a list of organizations to which we may have disclosed the information.

If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the Personal Information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law.Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.

Challenging Compliance

Any individual can address a challenge concerning our compliance with any of the privacy principles to our Privacy Officer.

Pacific Customs Brokers Ltd. will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.

Pacific Customs Brokers Ltd. Privacy Officer

Michel Avoine
Phone: 604-538-1566
michel@smgi.ca
101 - 17637 1st Avenue
Surrey, BC V3Z 9S1

Of course, at any point in that process the individual may also write to the Privacy Commissioner.

Information captured on Pacific Customs Brokers Ltd. Website

Every computer that connects to the Internet has an IP (Internet Protocol) Address which is an unique number for identification purposes. IP addresses of computers used to visit our Website may be logged. In addition, we automatically collect other information such as email addresses, browsers types, operating systems and the URL addresses of sites clicked to and from our Website.

Personal Information

We receive and store information you enter. You can choose not to provide certain information, but then you might not be able to take advantage of some of our features. We use the information that you provide for such purposes as responding to your requests, customizing future services for you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, Zip/Postal code, City, Country
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's internet Protocol address (e.G. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifier and other diagnostic data.

Use of Information

We may use your information to help us identify the type of Website content our customers value most and to provide a customized experience. We then use this information to improve the services we offer and to improve the Website. We also use this information to be able to communicate with you, including by sending you e-mail notifications about updates to the Web site, and for marketing purposes.

We may send you special offers from time to time, unless you choose to opt-out of receiving such offers. In addition, we may also send you special offers from other companies. Again, you may opt-out. If we send information from other businesses,we do not share your personal information with them. The offers come directly through us.

As we continue to develop our business, we might sell or buy business assets. In the unlikely event Pacific Customs Brokers Ltd. is acquired (purchased) by another company, then customer information will be one of the acquired business assets.

Links to Third Parties

Parts of our Website consist of products and services hosted by business partners and other third parties. When you leave our Website to visit one of their sites, the only information transferred to the third part is the fact that you came from our Website. This practice allows the third party to monitor its own Website traffic, but does not provide them with any information about you. Pacific Customs Brokers Ltd. is not responsible or liable for the privacy policies or content of third party sites. You should consult the privacy policies at those sites to determine how your information may be used.

Cookies

Like many websites, we may use "cookies". Cookies are small files that we transfer to your hard drive in order to provide Pacific Customs Brokers Ltd. with the capability to customize information for certain segments of its customer base and in some instances, cookies are used to allow Pacific Customs Brokers Ltd. the opportunity to associate individual customers with their information profiles.

A cookie is a series of data characters that, when programmed into a Website, is placed by the Web Server into the browser's application folder on your computer. Once placed onto your machine, the cookie will allow the Website to "recognize" you as a unique individual.

If you do not want us to use cookies, you can easily disable them by going to the toolbar of your web browser and clicking on the "HELP" button. Follow the instructions that will prevent the browser from accepting cookies or set the browser to inform you when you receive a new cookie. Additionally, you may visit this and other websites anonymously through the use of utilities provided by other private companies.

Legal Basis for processing personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), the legal basis for collecting and using the personal information described in this Privacy policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interest and it's not overridden by your rights
• For payment processing purposes
• To comply with the law

Opt-Out

It is your choice whether you want to receive emails or special offers from Pacific Customs Brokers Ltd. Our default settings are as follows:

• Please send me email or other mail informing me of special offers of your products or services;
• Please send me email or other mail informing me of special offers of related products or services from other companies.

You may choose to opt-out of receiving email or other mail from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Protection of Your Personal Information

We protect your personal information by encryption through SSL (Secure Sockets Layer) software, firewall protection and taking every reasonable precaution to assure that your personal information is secure. We also limit access to your personal information within Pacific Customs Brokers Ltd. on a "need to know" basis.

You can also take steps to protect your personal information by protecting unauthorized access to your password and to your computer. Be sure to sign off your computer when you are finished, especially if it is a shared computer.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics
• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy &Terms web page: https://policies.google.com/privacy?hl=en

Payments

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

• CyberSource. Their Privacy Policy can be viewed at https://www.cybersource.com/privacy/

Amendments to Policy

Pacific Customs Brokers Ltd. reserves the right to amend the privacy policy at any time with or without notice. Please check back frequently in the event of changes.

Your use of Pacific Customs Brokers Ltd. Website constitutes your agreement to this privacy policy.

Last Updated: December 31 2018

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