Privacy

Drive For Life Inc. recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting and keeping confidential any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.

Your Privacy Rights

From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act, and the Canadian Standards Association Model Code for the Protection of Personal Information, which it incorporates. These obligations extend to organizations such as ours. The Act gives you rights concerning the privacy of your personal information.

Drive For Life Inc. is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and trained our lawyers and support staff about our policies and practices.

Why Drive For Life Inc. Need Personal Information

Drive For Life Inc. simulator training will allow you to have a wider range of driving experiences and to be challenged by hazards and dangers that are prevalent on the road today. The personal information provided to us, will also assist Drive For Life Inc. in providing you the services for which you have registered. If we did not collect and use your personal information we could not provide you with those services.

What Personal Information Do We Collect?

Personal information is any information that identifies you, or by which your identity could be deduced. The personal information that we collect is the information provided by our customers or potential new customers when they register for the drive for life program through our "Register" link or the "Credit Card Authorization Form" on our internet website or otherwise provided to us at the time of registration if you register in person or by phone. We also record attendance to the various training sessions and other information related to your participation and performance in the drive for life program.

How Do We Collect Your Personal Information?

We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you, when you register for the drive for life program through our "Register" link or the "Credit Card Authorization Form". We also keep records of your attendance to the sessions and your performance as well as of material communications between you and us.

Sometimes we may obtain information about you from other sources: for example, your insurance company, your insurance broker or your employer, if you register for the drive for life program at its request.

Consent

In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent.

Sometimes, your consent may be implied through your conduct with us such as when you use the "Register" link or the "Credit Card Authorization Form" on our website, register in person or by phone or attend or fail to attend your training sessions. Your consent will also be implied when the services we are providing to you requires us to give your information to third parties (for example authorized insurance providers -including insurance brokers- that perform certain services or functions on your behalf).

How Do We Use Your Information

We use your personal information for the following purposes:

• to register you and to process your payment;
• to determine if you meet our customer requirements;
• to determine if you meet our requirements for establishing an open credit account, if you are a commercial customer;
• to monitor and manage course participation of our customers;
• to send you mailers or faxes when specials are announced. If you tell us that you do not wish to receive information about our services or about specials, we will not send any further material;
• to conduct research and monitor the effectiveness of our training programs;
• to act in respect of an emergency that threatens your life, health or security;

In order to provide and process the services you request, Drive For Life Inc. shares information with authorized insurance providers (including insurance brokers) that perform certain services or functions on your behalf. Insurance providers need information to confirm your participation in the drive for life program. Although Drive For Life Inc. provides this information to insurance providers that we believe to be reputable, we have not placed limitations on these providers from using or disclosing your information without your permission. Therefore, we encourage you to review the information privacy practices of these companies.

Drive For Life Inc. does not disclose your personal information to any third party (other than authorized insurance providers) to enable them to market their products and services. For example, we do not provide our client mailing lists to third parties that are not insurance companies.

Disclosure of your Personal Information

Under certain circumstances, Drive For Life Inc. will disclose your personal information:

• when we are required or authorized by law to do so, for example if a court issues a subpoena;
• when you have consented to the disclosure;
• when the services we are providing to you requires us give your information to third parties (for example authorized insurance providers that perform certain services or functions on your behalf) your consent will be implied, unless you tell us otherwise;
• where it is necessary to collect registration fees;
• if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy;
• if the information is already publicly known.

Updating Your Information

Since we use your personal information to provide our services to you, it is important that the information be accurate and up-to-date.

If during the course of your participation in the drive for life program, any of your information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?

Drive for Life Inc. takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;
• restricted file access to personal information;
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security policies.

Access to Your Personal Information

You may ask for access to any personal information we hold about you.

Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.

Correcting Errors

If Drive for Life Inc. holds information about you and you can establish that it is not accurate, complete and up-todate, Drive for Life Inc. will take reasonable steps to correct it.

Can I be Denied Access to My Personal Information?

Your rights to access your personal information are not absolute.

We may deny access when:

• denial of access is required or authorized by law (for example, when a record containing personal information about you to do so would reveal confidential commercial information about the drive for life program;
• to reveal the personal information could reasonably be expected to threaten the life or security of another individual;
• when granting you access would have an unreasonable impact on other people's privacy;
• when to do so would prejudice negotiations with you;
• to protect our company's rights and property;
• where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct information, we shall explain why. Drive for Life Inc. does not use your Social Insurance Number as a way of identifying or organizing the information we hold upon you. Drive for Life Inc. may, however, use your driver's licence information for such purpose.

Can I request anonymity

Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website). The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires us to confirm the identity of all new clients. It may also require us disclose information to FINTRAC in relation to certain large cash transactions.

Credit Bureaus

To help us make credit decisions about clients, prevent fraud, check the identity of new clients and prevent moneylaundering, we may on occasion, request information about you from the files of consumer reporting agencies.

Communicating with Us

You should be aware that e -mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

Since Drive for Life Inc. regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access

If you have any questions, or wish to access your personal information, please write to our Privacy Contact at:

Drive for Life Inc.
2225 Erin Mills Parkway,
Mississauga, Ontario,
L5K 1T9.

Attention: Paul Chadder

Telephone: 905-822-0111
Fax: 905-822-0185
Email address: info@driveforlife.ca

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street,
Ottawa Ontario,
K1A 1H3
1.800.282.1376.

Employment Inquiries

If you apply to Drive for Life Inc. for a job, we need to consider your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.

Web Site

Our website contains links to other sites, which are not governed by this privacy policy.

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

If you have questions or concerns please email us info@driveforlife.ca or contact us at 905-822-0111.

DFL / Privacy Policy 05/05