Privacy Policy

VTech Technologies Canada Ltd. Privacy Policy Statement:

It is the policy of VTech Technologies Canada Ltd. or "VTech" to control the collection, use, and disclosure of customer and employee personal information in accordance with all requirements set out in the Personal Information Protection and Electronic Documents Act (PIPEDA).

Purpose

The purpose of this document is to show how VTech Technologies Canada Ltd. adheres to government regulations and acts relating to our customer's personal information and privacy.

Responsibility

All VTech Technologies Canada Ltd. employees, who collect, maintain and/or use personal information must do so in accordance with this policy and relevant procedures.

The Privacy Officer assigned by VTech is responsible for supervising compliance with the legislation and for initiating procedures, guidelines and schedules that will be developed to effect this policy.

The Privacy Officer is accountable for the VTech Technologies Canada Ltd.'s policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.

Contact Information

Your feedback is important to us. If you have any questions, comments, or concerns on the approach taken to collect, use or disclose your personal information, we would like to hear from you.

VTech Technologies Canada Ltd.'s head office address for privacy policy inquiries is:

VTech Technologies Canada Ltd.
13888 Wireless Way Suite 222
Richmond, British Columbia
Canada V6V 0A3

Attention: Privacy Officer

By phone: (604) 273 - 5131
By E-mail: privacyofficer@vtech.ca

Privacy Policy

This Web Privacy Policy is a condensed version of our main Privacy Policy. This main policy carries more details on our means and methods of adhering to the Ten Principle Requirements as laid out by the PIPED Act.

Latest Revision Number: 2
Revision date: April 17th, 2005

1 VTech Technologies Canada Ltd. Customer Privacy Policy

1.1 Introduction

In Canada, two federal privacy laws protect all citizens. The Privacy Act covers the personal information-handling practices of the federal government and the Personal Information Protection and Electronic Documents (PIPED) Act is Canada's new private sector privacy law, which came fully into effect on January 1, 2004.

VTech Technologies Canada Ltd. must rely on personal information to identify and stay in touch with their customers, and information about their employees, so that they can administer benefits and ensure a safe and productive workplace. Obtaining and using that personal information in ways that don't offend the fundamental human right of privacy is the challenge for modern businesses. Respecting and protecting privacy is a key element of good customer relations, and that makes it a key element of competitive advantage. Our customers want privacy and our employees need it.

VTech Technologies Canada Ltd.'s privacy policy conforms to the Canadian Federal Privacy Act (PIPEDA). Since the European Union has formally endorsed PIPEDA, we feel that our adherence to this Act enables us to be in compliance with key, basic elements of major international Personal Information Privacy Acts.

1.2 The PIPED Act in brief

The Personal Information Protection and Electronic Documents (PIPED) Act sets out ground rules for how private sector organizations can collect use or disclose personal information in the course of commercial activities. It balances an individual's right to privacy with the need of organizations to collect, use or disclose personal information for legitimate business purposes.

1.2.1 The Basic PIPED Act outlined:

• If your business wants to collect, use or disclose personal information about people, you need their consent, except in a few specific and limited circumstances
• You can use or disclose people's personal information only for the purpose for which they gave consent
• Even with consent, you have to limit collection, use and disclosure to purposes that a reasonable person would consider appropriate under the circumstances
• Individuals have a right to see the personal information that your business holds about them, and to correct any inaccuracies
• There's oversight, through the Privacy Commissioner of Canada, to ensure that the law is respected, and redress if people's rights are violated

1.3 Requirements

This Privacy Policy has been developed in accordance with the standards set out in PIPEDA and is modeled after the Canadian Standards Association Model Code (the "CSA Code") for the Protection of Personal Information. CSA has identified ten principles of fair information practices, which represent a formal statement of the minimum requirements to be adhered to for the protection of personal information collected from customers and employees.

These principles, which have been adopted by VTech Technologies Canada Ltd., are:

1. Accountability

Organizations must appoint an individual(s) responsible for maintaining compliance with the Act. These individuals are required to develop, implement, and monitor personal information policies and practices.

2. Identifying Purposes for Collection of Personal Information

Organizations must disclose why personal information is collected, how it will be used, and whether such information will be shared with third parties at the time or prior to collection.

3. Obtaining Consent for Collection, Use or Disclosure of Personal Information

Organizations need to obtain an individual's consent at the time personal information is collected, and whenever a new use for the previously collected information is identified, except where exempted by law.

4. Limiting Collection of Personal Information

Organizations are required to limit the collection of personal information to that which is deemed necessary for the purposes identified.

5. Limiting Use, Disclosure, and Retention of Personal Information

Organizations may only use information for the purpose for which it was collected, unless consent is received from the individual or the new use is specifically permitted by the Act. Information may be retained only as long as needed and should be destroyed or anonymized according to a predetermined retention policy.

6. Accuracy of Personal Information

Organizations are required to maintain personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

7. Security Safeguards

Organizations must protect personal information, regardless of format, against unauthorized access, disclosure, copying, use, or modification. The degree of protection should be commensurate with the sensitivity of the information.

8. Openness Concerning Policies and Practices

Organizations must inform customers and employees of policies and practices relating to the management of personal information. These policies must be easily understandable and readily accessible.

9. Customer and Employee Access to Personal Information

Upon request, organizations are required to inform individuals of the existence, use, and disclosure of personal information pertaining to that individual. Individuals should be able to challenge the accuracy and completeness of the information, and have it amended as appropriate.

10. Challenging Compliance

Organizations need to provide simple and readily accessible mechanisms for individuals to challenge compliance with the Act. Organizations should inform individuals of the avenues of recourse, including internal recourse mechanisms, responsible industry associations, regulatory bodies, and ultimately, the Privacy Commissioner of Canada.

1.4 Key Points Regarding Collection of Personal Information

1.4.1 Obtaining Consent for Collection, Use and Disclosure

VTech does not collect, Use, or disclose any personal information unless consent is voluntarily provided. Consent may be given orally, in writing or, electronically at the time of collection.

1.4.2 Collecting Your Personal Information

VTech will express orally or in writing the purposes for which your personal information is being collected.

Reasons for collecting personal information:
• To provide better services or benefits.
• To understand your needs and preferences.
• To develop and manage products and services to meet your needs.
• To contact you directly for products and services that may be of interest to you.
• To register you as a member of our web site.
• To register your product's warranty.
• To ensure a high standard of service.
• To meet regulatory requirements.
• To improve ways of communication for better understanding and better results.
• To evaluate your application for any available position.

What we may collect:
• First and Last name,
• Mailing address,
• Phone number,
• E-mail address,
• Products ordered,
• Valid Credit Card information from customers who are at least 18 years of age,
• Your comments, suggestions and feedback.

Why we collect personal information:
• For identification purposes.
• To respond to your inquiries.
• To process your request.
• To notify contest winners.
• To send you additional information on our products and services *.

* Customers who prefer not to receive special promotion or additional product information can "Unsubscribe" by emailing us at unsubscribe@vtechcanada.com and, on the subject field state "Unsubscribe".

1.5 Protection of Your Personal Information

VTech Technologies Canada Ltd. is committed to:
• Protecting your personal information from loss, theft and unauthorized & inappropriate access.
• Maintaining strict confidentiality of all personal information collected.

Methods and Tools used to honor our commitment:
• Organizational procedural safeguards.
• Strict electronics and technical measures including firewalls and encryption technologies.
• SSL technology to protect credit card data during the transmission.

1.6 Retention

We will store your personal information as long as it remains necessary or relevant to conducting business with you or for as long as required by law.

1.7 Links To Third Party Web Sites

VTech Technologies Canada Ltd. will not disclose any of your personal information to third parties without your knowledge and consent unless the disclosure is to prevent fraud, illegal activity, potential threats to the physical safety of any person, violations of VTech terms and use or is required by law.

To provide you with our best service in helping to meet your needs, our web site may contain links to other sites. Please note that:
• We do not have jurisdiction over these sites.
• We are not responsible for the content, products or services offered.
• We have no control over the privacy and security practices over these sites.

1.8 Cookies

A cookie is a small piece of information sent by a web server to store on a web browser so it can later be read back from that browser. This is useful for having the browser remember some specific information.

1.8.1 Frequently Asked Questions Regarding Cookies

1.8.1.1 Does VTech Technologies Canada Ltd. collect cookies?

Yes. Cookies will be collected in the event of product registration and online purchasing.

1.8.1.2 How do VTech's cookies end up on my hard drive?

Via cookies, a web site visitor's personal information is formatted by the Web server, transmitted to, and saved by the user's computer.

• The Web server creates a specific cookie (a tagged string of text containing the user's preferences) and transmits it to the user's computer.
• If cookie-savvy, the user's Web browser receives the cookie and stores it in a special file called a cookie list.
• This happens without any notification or user consent.

1.8.1.3 What information is collected in VTech cookies?

We may collect the following standard types of information:
• User ID's, passwords.
• Internet Protocol (IP) addresses of the computers being used to access our sites.
• The operating systems and the types and versions of browsers used to access our sites.
• The Internet Service Providers used by visitors to our sites.
• The dates and times users access our sites.
• The pages visited.
• The key words users enter into our search engine.
• The names and sizes of files requested.

1.8.1.4 Why does VTech collect cookies?

To store passwords, user ID's and for online purchasing (user preferences).

1.8.1.5 Where can a visitor to VTech's web site get more information on cookies?

Privacy Commissioner Information on Cookies:
https://www.priv.gc.ca/en/privacy-topics/technology/online-privacy-tracking-cookies/cookies/frequently-asked-questions-about-cookies/

1.8.1.6 Can I delete VTech cookies and what will happen if I do?

Yes one can delete VTech Cookies off their hard drive, but, the next time the user visits our site (vtechcanada.com) they will have to set or customize their web information/preferences again.

1.8.1.7 How do I set my browser to reject cookies?

Netscape (Platform: PC)

Disabling cookies for Netscape on a PC (v.3 or higher):
1. Go to the "Options Menu" and select the "Network Preferences" menu item.
2. From the Window that appears, select "Protocols".
3. Locate the section "Show an Alert Before", check the box labeled "Accepting a Cookie".

Netscape (Platform: Mac)

Disabling or enabling Cookies in Netscape running on a Mac:
1. On the "Netscape Menu", click "Preferences".
2. Under "Privacy & Security", click "Cookies".
3. Click "Disable Cookies".

Internet Explorer (Platform: PC)

Enable or disable Cookies on IE (PC):
1. On the "Edit" menu, click "Preferences".
2. Under "Receiving Files", click "Cookies".
3. On the "When receiving Cookies" pop-up menu, click the option you want.

Internet Explorer (Platform: Mac)

Enable or disable Cookies on IE v.5.2 (Mac):
1. On the "Explorer" menu, click "Preferences".
2. Under "Receiving Files", click "Cookies".
3. On the "When receiving Cookies" pop-up menu, click the option you want.

1.8.1.8 Are VTech's Cookies a threat to my privacy?

No. We only use cookies solely for the user's ease of use of our (vtechcanada.com) site.

1.8.1.9 My Internet Explorer VTech Cookies had my username on them! Can other servers see my username?

Only our (vtechcanada.com) site or web server can have that information. The Cookie information contains IP addressing specific to this web transaction (yours and ours). Other servers (with different IP addresses) will not be actively involved, thus not receive this data.

1.9 Frequency of Review

Yearly, or, dependant on prevailing legislative changes.

1.10 Methods used to review operation of the Policy

• Audit tool
• Check list
• Performance indicator (data collected on a routine basis to demonstrate level of performance)

1.11 References

Personal Information Protection and Electronic Documents Act
VTech Technologies Canada Ltd. Privacy Policy Rev 2

1.12 Links

Canadian Federal Privacy Act: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-privacy-act/pa_brief/

Federal Privacy Commissioner: www.priv.gc.ca

1.13 Appendices

Privacy Inquiry Form

Privacy Complaint Form