Campbell Company of Canada Privacy Policy Updated June 2005 This website is owned and operated by Campbell Company of Canada. At Campbell, we recognize that many visitors to our site are concerned about the information they provide to us and how we treat that information. Our Internet Privacy Policy is based on guidelines from the Canadian Government's Personal Information Protection and Electronic Documents Act (PIPEDA) and our own beliefs about what is appropriate in this sensitive area. We will update the Policy on a bi-annual basis, so please check in occasionally. Please note that by submitting personal information to Campbell Company of Canada, you are consenting to the use of the personal information as described in this Internet Privacy Policy. Our Privacy Policy At Campbell Company of Canada, we do not collect personally-identifiable information from individuals unless it has been provided voluntarily and knowingly. This means viewers are not required to register or provide personally-identifiable information to Campbell in order to view any of its sites. If a viewer registers in order to use one or more of the many features of the Campbell sites, in addition to other purposes described in this Internet Privacy Policy, the personally-identifiable information supplied will be used for the purpose of providing the services requested. These features may include: Campbell's Cookbook Send to a friend Recipe Box Recipe Sharing Power2Cook News and Tips Depending on the feature registered for use, Campbell Company of Canada may collect one or more of the following types of personally-identifiable information: Name, address, phone number, email address, username and password. If this information is not provided, viewers may not be able to register. Viewers can always access and review their personally-identifiable information by visiting any of the sites on which they have registered. In addition, individuals can correct factual errors in their personally-identifiable information by editing their profile on any of Campbell Company of Canada sites. Creating, viewing and editing an individual's personally identifiable information can only be done with a valid member-provided user identification and password. If an individual agrees to receive follow-up communications by Campbell Company of Canada or asks to be put on its mailing list when registering, Campbell may contact that individual from time to time. Individuals can always change their preference for follow-up contacts or opt out of any further contact or services by emailing Campbell Company of Canada at any time. However, unless an individual is specifically registered to receive communications from a site, that site will not contact the individual. Campbell Company of Canada may use information you provide about yourself to improve its marketing and promotional efforts; to statistically analyze website usage; and to improve its features and the content of its sites. Campbell Company of Canada may also use information you provide to customize the content that its sites' deliver. For example, Campbell may customize recipes, product information and promotions it delivers to viewers based upon the information provided to Campbell. Except as described in the Internet Privacy Policy, Campbell Company of Canada does not share personally-identifiable information with anyone outside of the Campbell Company of Canada family of companies, unless the information is requested by law enforcement personnel or is required by law to disclose. We identify to whom, and for what purposes, we disclose the viewer's personallyidentifiable information at the time we collect such information and obtain the viewer's consent to such disclosure. Keep in mind, viewers are prohibited from using Campbell Company of Canada sites to post or transmit any unlawful, threatening, libelous, defamatory, obscene, scandalous, inflammatory, pornographic or profane material or any material that could constitute or encourage unlawful conduct. Campbell Company of Canada will monitor or review material transmitted or posted using this site and reserves the right to delete any material the company deems inappropriate. Campbell Company of Canada is under no obligation to do so and assumes no responsibility or liability arising from any material transmitted or posted using this site. Personally-Identifiable Information Personally-identifiable Information is any information that is identifiable with the viewer. The information may include but is not limited to your name, mailing address, phone numbers, gender, birth date, email address, financials, identification numbers, etc. Cookies Like most companies, Campbell Company of Canada uses "cookie" technology on its sites to collect "aggregate" information (in other words, the personal information of the viewer is pooled into a group of similar information, such that the personal information cannot be identified with that individual). When the viewer logs onto a Campbell Company of Canada site, the cookie indicates whether the viewer has visited the site before or is a new visitor. This allows Campbell Company of Canada to measure the appeal of its sites to new and return visitors. The cookie does not track any personal information about viewers or provide any way to contact the viewer, and the cookie does not extract any information from your computer. Cookies are the best way for Campbell Company of Canada to be able to offer visitors to the site the most enjoyable and hassle-free online environment. Note: Viewers can choose to set their computer to warn them each time a cookie is being sent or disable all cookies through their Internet Browser, such as Internet Explorer and Netscape Navigator. Contest and Sweepstakes Campbell Company of Canada sites sometimes include notices of contests, sweepstakes or other promotions it is conducting, and may permit viewers to participate electronically in some cases. If that occurs, the personal information provided will be used for the purpose of conducting the contest, sweepstakes or promotion. In addition, Campbell Company of Canada may participate in internet-related promotions sponsored by reputable third parties. In these instances, if an individual is a participant in such promotions, Campbell Company of Canada may provide certain personallyidentifiable information to these third parties in furtherance of the promotion. These parties have agreed to hold this information in confidence according to the Personal Information Protection and Electronic Documents Act, not use it for any purpose except to carry out the requested service, and honor the Campbell Company of Canada privacy and security policies in the way this information is handled. Questionnaires and Surveys From time to time, Campbell Company of Canada sites may conduct surveys. Survey information will be treated like all of the information Campbell Company of Canada collects. It is used to help improve the appeal of its products and websites to consumers. Third Parties Service Providers Campbell Company of Canada sometimes employs other companies and individuals to perform services for us. For example, agencies are enlisted to help administer consumer promotions, to analyze data, to fulfill orders placed, and to provide customer service. These parties are required to maintain any personal information received from the individuals in confidence and may only use it in connection with the services being provided to Campbell. Links to Other Sites Campbell Company of Canada websites may contain links to other approved sites. While we do our best to make sure that every link to a site send you a helpful place on the Internet, we cannot guarantee the content of these sites. The sites will always have their own privacy policies. You should always check the privacy policy of the specific site you're visiting to understand your rights. Security Campbell Company of Canada takes your privacy and security seriously. For this reason, it has always maintained physical security measures including locked doors and files, electronic security and managerial controls that limit the potential for misuse of information by employees and contractors. Please note, however, that the Internet itself is not secure. As a result, Campbell Company of Canada cannot unequivocally guarantee the complete security of your information through its websites. Children's Privacy Policy Campbell Company of Canada recognizes the need to provide additional privacy protections for children who visit Campbell sites. Some Campbell sites may directed in whole or in part to children under the age of 13. Campbell Company of Canada does not, however, directly or indirectly collect personally-identifiable information from children under the age of 13 in these areas. Children should always get permission from their parents or guardians before sending information about themselves over the Internet. If a child has mistakenly provided Campbell Company of Canada with personally-identifiable information, a parent or guardian of the child should contact Campbell Company of Canada. Questions or Concerns? Any questions or concerns about the Campbell Company of Canada Internet Privacy Policy, or if an individual would like to access their information, update it or opt out of a service previously requested, please contact the Privacy Officer for Campbell Company of Canada at: Campbell Company of Canada Attention: Privacy Officer – Mark Childs 60 Birmingham Street Toronto, Ontario M8V 2B8 1-800-410-7687 Our offices are open from 9 a.m. - 7 p.m. Eastern Time, Monday through Friday. A representative will address your questions or concerns. Campbell Company of Canada Privacy Statement Updated June 2005 Our Pledge Campbell Company of Canada is committed to protecting the privacy and managing the responsible collection and retention of all personal information, i.e. information about an identifiable individual. We do not collect personal information from individuals unless it is voluntarily and knowingly provided. We are proud to demonstrate our commitment to privacy through this Privacy Statement, which is entirely based on the privacy laws and regulations in Canada including the Personal Information Protection and Electronic Documents Act. Campbell Company of Canada abides by 10 principles of fair information practices - a summary is included at the end of this policy. To view the Personal Information Protection and Electronic Documents Act, visit www.privcom.gc.ca or contact the Office of the Privacy Commissioner of Canada for more information: The Office of the Privacy Commissioner of Canada 112 Kent Street Ottawa, ON K1A 1H3 1-800-282-1376 Collection and Retention of Information In an effort to continuously offer consumers with products and information that meet evolving interests, Campbell Company of Canada will obtain permission from individuals before asking for their personal information. Information may be obtained from a variety of sources, including Internet, telephone or contest ballot forms. Campbell Company of Canada may also collect Personal Information from third party service providers, obtained by your consent to do so or as otherwise permitted by law. The personal information supplied will only be used for the purpose of providing the services requested. Campbell Company of Canada will only ask you for information it needs and only when necessary. When personal information is required, Campbell Company of Canada will explain why it is needed and how it will be used. Personal information will be retained only as long as it is necessary to fulfill the purposes of its identified use. Use and Disclosure of Personal Information Campbell Company of Canada may use the personal information provided to improve its services and products; to enhance its marketing and promotional efforts; to statistically analyze website usage; and to improve the features and content of its websites. Consumers would never be opted into a service or be contacted if they did not request the communication. If a consumer has agreed to receive follow-up contact by Campbell Company of Canada or has asked to be put on a mailing list, Campbell Company of Canada may also contact the consumer from time to time. Consumers can always change their preference for follow-up contact by Campbell Company of Canada at any time. Except as described in this document, Campbell Company of Canada does not share personal information provided by our consumers with anyone outside of the Campbell Company of Canada family of companies, unless the information is requested by law enforcement personnel or required by law to be disclosed. Contests and Promotions If a consumer enters a contest, sweepstakes or other promotion conducted by Campbell Company of Canada (either directly or through a third-party partner), the personal information provided by the consumer will be used for the purpose of conducting the contest, sweepstakes or promotion (i.e. to contact the winner). In addition, Campbell Company of Canada may participate in promotions sponsored by reputable third parties. In these instances, Campbell Company of Canada or a participant in such promotions may provide personal information to these third parties in furtherance of the promotion. These parties have agreed to hold this information in confidence according to the Personal Information Protection and Electronic Documents Act, not use if for any purpose except to carry out the requested service, and honour Campbell Company of Canada privacy and security policies in the way this information is handled. Security Assurance Campbell Company of Canada takes your privacy and security seriously. For this reason, it has always maintained physical security measures including locked doors and files, electronic security and managerial controls that limit the potential for misuse of information by employees and contractors. Please note, however, that the Internet itself is not secure. As a result, Campbell Company of Canada cannot unequivocally guarantee the complete security of your information through its websites. Principles of Fair Information Practices Campbell Company of Canada stands by the 10 principles under the Personal Information Protection and Electronic Documents Act. These principles include: 1. Accountability Campbell Company of Canada takes responsibility for personal information under its control and has designated a Privacy Officer who is accountable for its compliance to the Personal Information Protection and Electronic Documents Act. 2. Identifying Purposes Campbell Company of Canada will identify the purposes for which personal information is collected at or before the time it is collected, unless such purposes are obvious. Campbell Company of Canada will ensure that the purposes for which personal information is collected and the way in which the information may be used are clear to the individual. In some cases, the purpose will be clear from the context of the interaction; in other circumstances, a written or verbal explanation may be required. 3. Consent Campbell Company of Canada will not collect, use or disclose personal information without the individual's knowledge and consent, except in certain limited circumstances permitted by law, such as where immediate health of a person is at risk, or in connection with the breach of an agreement or law. Consent may be expressed or implied, given orally, electronically or in writing and provided by an action or inaction. Consent may also be given through a legally appointed representative or a legal guardian. 4. Limit Collection of Personal Information The collection of personal information will be limited to what is necessary for the purpose identified by Campbell Company of Canada. 5. Limiting Use, Disclosure and Retention Campbell Company of Canada will 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. Personal information shall be retained only as long as necessary for the fulfillment of those purposes. 6. Accuracy Campbell Company of Canada will make responsible efforts to ensure that personal information of individuals is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. 7. Safeguarding Personal Information Campbell Company of Canada will protect personal information by the use of security safeguards appropriate to the sensitivity of the information. Security safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification by employing various methods including physical measures such as locked filing cabinets and restricted access to offices; organizational measures such as security clearances; and technological measures such as the use of passwords and encryption. 8. Openness Campbell Company of Canada will readily make information available to individuals about its policies and practices relating to the management of personal information. All such information will be made available in both English and French. 9. Individual Access Upon request, Campbell Company of Canada will inform an individual of the existence, use, and disclosure of his or her personal information, and shall be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. 10. Challenging Compliance An individual can address a challenge concerning compliance with the above principles to the designated individual accountable for Campbell Company of Canada compliance. Questions or Concerns? Any questions or concerns about the Campbell Company of Canada Internet Privacy Policy, or if an individual would like to access their information, update it or opt out of a service previously requested, please contact the Privacy Officer for Campbell Company of Canada at: Campbell Company of Canada Attention: Privacy Officer – Mark Childs 60 Birmingham Street Toronto, Ontario M8V 2B8 1-800-410-7687 Our offices are open from 9 a.m. - 7 p.m. Eastern Time, Monday through Friday. A representative will address your questions or concerns.