Cost.U.Less

Legal/Privacy

The North West Company is concerned about protecting your privacy. For detailed information, please view the following statements:

• Privacy Policy
• Customer Privacy Statement

For more information regarding the NWC Privacy Code, please contact the Privacy Office at 1 (800) 563-0002 or via e-mail at PrivacyOffice@northwest.ca.

Access requests, change requests, inquiries or complaints should be addressed in writing to:

Privacy Office
The North West Company
77 Main Street
Winnipeg, Manitoba R3C 1A3

Privacy Policy

(Drafted on July 3, 2007. Revised May 2013)

At The North West Company Inc., respecting privacy is an important part of our commitment to our customers and employees and is committed to protecting the personal information we collect. That is why we have developed The North West Company Privacy Policy. This Privacy Policy is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information by all of The North West Company family of operations (collectively, "The North West Company"), which includes Northern, NorthMart, Quickstop, Crescent Multi Foods, Value Lots, Solo Market, Inuit Art Marketing Service, Fur Marketing Branch, AMDOCS, Sealift Express, North West Telepharmacy Solutions, Northern NorthMart Pharmacy, Giant Tiger, Cost-U-Less, Alaska Commercial Company, AC Value Centers, Island Fresh IGA, Northstar Meats, Pacific Alaska Wholesale, Span Alaska Sales, Link Financial Services, Link Tax Services, We Financial, and those banners' web-sites.

In addition to this Privacy Policy, The North West Company has published Employee, Customer, and Pharmacy Privacy Statements and Privacy Brochures to provide summary information to individuals on how we collect, use and disclose the personal information provided to us.

"Personal Information" referred to in this Privacy Policy means information about an identifiable individual, such as the name, address, and date of birth of that individual, and includes non-personal information that we link to Personal Information. Throughout this document, when referring to personal information, we also mean personal health information, where applicable.

"Customer and employees" referred to in this Privacy Policy includes candidates for employment, whether or not they are hired, former employees, applicants for store credit, whether or not they are approved for credit, and any other individual who has entrusted us with their personal information by whatever means including through technology.

This Privacy Policy does not apply to the collection, use and disclosure of Personal Information by franchisees, or companies with which we have business relationships, if any now or in the future, unless we receive Personal Information or non-personal information that is linked to Personal Information from such entities, then this Privacy Policy will apply.

The practices that we have adopted reflect requirements set out in all provincial and federal legislation. This includes the Personal Information Protection and Electronic Documents Act (PIPEDA), which applies to the collection, use, and disclosure of personal information in the course of commercial activities, including pharmacy services and retail stores.

The North West Company...

• is accountable for the personal information that we collect and have in our custody and has entrusted to its authorized agents or third party service providers.
• will inform employees and customers, where practical, as to why we must collect any of their personal information before the information is collected.
• will obtain consent (implied or informed) before or when we collect, use, or disclose personal information an individual. When allowed by law or contract, individuals may withdraw their consent at any time.
• limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.
• will use or disclose personal information only for the reasons that such information was provided it to us. We will keep personal information only as long as is necessary to accomplish these purposes.
• will endeavor to maintain the accuracy of the personal information in our possession or control.
• protects personal information with safeguards deemed appropriate to the sensitivity of the information.
• will be open about the policies and practices used to manage personal information.
• will, at an individual's request, advise that individual of what personal information we have in our possession or control about, what it is being used for, and to whom and why it has been disclosed.

Principle 1

The North West Company is accountable for the personal information that is given to us.

The North West Company is accountable for all personal information in our possession or control. This includes any personal information that we must share with third parties in order to provide services to our customers and employees. We have established policies and procedures aimed at maintaining the privacy of our customers and our employees. We have appointed a Chief Privacy Officer to oversee privacy issues for The North West Company and its banners. We have also educated our employees about our Privacy Policy and their role in protecting an individual's privacy rights. If an individual has questions about our privacy practices, please contact our Chief Privacy Officer.

Principle 2

The North West Company will inform individuals as to why we must collect any personal information before the information is collected.

How we use and disclose personal information

We may use personal information to provide individuals with services. We may use personal information to co-ordinate care or services with other service providers or organizations as we have always done in the past. Examples include filling a customer's prescription or speaking with past employers, or contacting financing institutions with which individuals do business with for clarification purposes.

We may use and disclose personal information in order to receive payment for the products or services provided.

North West Company staff, using their professional judgment, may disclose personal information to other service providers that is directly relevant to services rendered.

We may contact individuals to provide reminders or information about services that may be of interest to them. We may also contact individuals about store openings or closings in their area.

We may use and disclose personal information to tell customers about services that may be of interest to them.

In order to keep personal information up-to-date, North West Company staff at any of our locations could discuss with individuals the personal information we have in our records. They will also remind customers and employees why they require certain personal information and, if required, will ask for consent to collect and use it.

Other reasons that we may require personal information

From time to time, the North West Company and its affiliated banners may offer promotions, loyalty programs and other in which customers may want to participate. In order to provide our customers with the full benefit of these services, we may ask for certain personal information. At the time of collection, we will advise of the specific purpose for which the information is required and we will provide the option to consent to the collection, use and/or disclosure of that information. If individuals choose to withhold their consent, we may not be able to provide the service contemplated.

Principle 3

The North West Company will obtain consent before or when we collect, use or disclose personal information. An individual may withdraw their consent at any time.

Why does our staff need an individual's consent?

Under Canadian privacy legislation, staff must get express consent (informed) to collect, use and disclose certain personal information (such as personal health information). This may include information we currently have on record and have always collected, used and disclosed to provide pharmacy, credit, and other services. Legislation requires us to formally ask for consent to collect, use and disclose personal information as well as to document the consent provided to us. However, implied consent can be attained under certain, limited service agreements fulfilled between the individual and the North West Company.

How will we ask for an individual's consent?

When first visiting one of our banner stores and requesting service from us, our staff will provide a description of why personal information is required and to whom they must disclose it. Individuals may be asked to confirm their consent and this will be documented in our files. On occasion, individuals may be asked to update this consent to ensure that our records remain accurate.

There may be times when customers or employees want us to share personal information with a family member or authorized representative or, alternatively, to specifically restrict with whom we may share the information. We will comply with those specific requests upon receipt of written notification to one of our customer service representative or to the Chief Privacy Officer.

What happens if an individual chooses not to give their consent or withdraws consent at a later date?

If a customer or employee chooses not to provide us with their consent to collect and use the personal information, we will still be obliged to comply with all the federal and provincial laws that require us to keep a record of services or products we have provided to . If an individual does withdraw their consent, we may not be able to provide or continue to provide that individual with certain services or products.

Exceptions to requiring consent

The North West Company will collect, use or disclose personal information without consent of an individual only in limited circumstances as permitted by law.

There have always been, and may continue to be, instances where we may collect, use or disclose personal information without an individual's consent. These instances are permitted under privacy legislation in order to ensure that the consent requirement is not a hindrance to anyone's health and safety.

Personal information may be collected without consent where the collection is clearly in the interest of the individual and consent cannot be obtained in a timely way.

Personal information and non-personal information may be collected through the use of technology such as through video surveillance at our stores, warehouse, and office or through electronic means such as when individuals visit one of our social media sites.

Personal information may be used or disclosed without consent where it's use or disclosure is needed for the purpose of acting in response to an emergency that threatens the life, health or security of an individual.

The collection, use and disclosure of information required by third party service providers essential for the provision of the services, or required by our regulators, including self-regulatory organizations, do not need specific consent from individuals. Some of our service providers are located outside of Canada. As a result, an individual's personal information may be accessible to regulatory authorities in accordance with the law of these jurisdictions.

Principle 4

The North West Company limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.

We will limit the collection of personal information to that which is required to accomplish the purposes for which it is being collected.

Principle 5

The North West Company will use or disclose personal information only for the reasons that the individual provided it to us. We will keep personal information only as long as is necessary to accomplish these purposes.

In order to provide customers and employees with quality products and service while complying with existing federal and provincial legislation, we keep a record of the transactions conducted with our customers and our employees for a prescribed period. We will retain personal information (including transactional information) for the period of time that is required by various legislations or by self-regulatory organizations.

We will not share personal information with any third parties, except as expressly consented by our customers or employees, through implied consent provided by individuals entering into an agreement or contract with us, or as may be required by law or self-regulatory organizations.

Other purposes

Where we have collected personal information in relation to a loyalty program, contest, promotion or some other purpose, we will use that personal information only for those purposes and for any other related purpose that we have disclosed to our customers and employees and to which we have received that individual's informed or implied consent. We will keep personal information only as long as is necessary to provide with those our services.

If we intend to use an individual's personal information for a new purpose, not previously identified, we will obtain consent prior to use for the purpose. When personal information is no longer required, it will be destroyed or depersonalized.

Principle 6

The North West Company will endeavor to maintain the accuracy of the personal information in our possession or control.

In order to provide our customers and employees with a high degree of professional service, we must ensure that the personal information that we collect about an individual is accurate, complete and current. From time to time, customers and individuals will be asked by our customer service representative, human resources or payroll, or our pharmacist to update certain personal information.

Individuals are encouraged to advise us of any changes to their personal information that may be relevant to the services we are providing. At any time, individuals can request in person to allow access to review their own personal information we have on hand about them and, where necessary, individuals will be able to immediately provide updated information so that personal information can be corrected and to ensure that it is accurate within our system.

Principle 7

The North West Company protects personal information with safeguards appropriate to the sensitivity of the information.

We protect personal information by using physically secure facilities, industry-standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to prevent the loss, misuse and alteration of the information under our control. To prevent unauthorized electronic access to personal information, we maintain information collected in password-protected environments.

Principle 8

The North West Company will be open about the procedures used to manage personal information.

Principle 9

At receipt of written request, The North West Company will confirm the authenticity of the requestor, advise of what personal information we have in our possession or control, what it is being used for, and to whom and why it has been disclosed.

Each person has the right to review and obtain a copy of his or her personal information on record with limited exceptions. This information can include applications for credit or employment, transactional information, loyalty programs, prescription and billing records. To find out what information The North West Company has in its records, contact them by writing to our Chief Privacy Officer. In most instances, they will respond to an individual's request within 30 days of receiving the request. The North West Company reserves the right to charge an administration fee to cover the cost of retrieving and providing copies personal information.

If an individual has any concerns about the access provided to their records, or if he or she wish to amend the information, they are encouraged to discuss it with our staff, who will be pleased to assist in any way they can.

Principle 10

Individuals may challenge The North West Company's compliance with this Privacy Policy.

The North West Company will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.

To challenge compliance with this Policy in relation to products or services or personal information collected, please bring any concerns in person to the attention of one of our customer service representative, by calling our toll free number (1-800-563-0002), or in writing to the Chief Privacy Officer who is responsible for investigating complaints and responding to the person making the request (or their authorized designate) in a timely fashion and will do so, in most instances, within 30 days of receiving the request.

Where it is believed that legitimate concerns have not been satisfactorily addressed, contact the Chief Privacy Officer directly (please see Contact Information, page 6). The Chief Privacy Officer will ensure that a complete investigation of any complaints have been undertaken and will report their findings to the originator of the complaint within 30 days of receiving the complaint.

Privacy and Our Employees

We have taken steps to help ensure that our employees govern themselves in accordance with this policy. In addition, our employees' own privacy rights are important to us, and we have taken steps to protect the information they provide to us in the employment environment, including:

• Limiting the information collected on employment and benefits applications to the information that is necessary to administer their employment and benefits.
• Safeguarding their employment information.
• Providing them with personal access to their employment files, with limited exceptions.
• Providing them with an opportunity to challenge our privacy practices.

Our Web site Privacy Statement

Our Customer Privacy Statements are provided on our North West Company web site as a summary of our complete Privacy Policy.

Contact information

For more information regarding the North West Company's Privacy Policy, please contact the Chief Privacy Office at 1-800-563-0002 or via e-mail at PrivacyOffice@northwest.ca. Access requests, inquiries or complaints should be addressed in writing to:

Privacy Office
The North West Company
77 Main Street
Winnipeg, Manitoba R3C 2R1

The North West Company reserves the right to amend this Privacy Policy from time to time without prior notice.

Please feel free to visit the Privacy Commissioner of Canada's web site at www.privcom.gc.ca. 2013, The North West Company Inc.

2013, The North West Company Inc

Customer Privacy Policy

Respecting your personal information is an important part of our commitment to you. Our Customer Privacy Statement summarizes when and how we use your personal information, as detailed in our Privacy Policy.

1. When you buy or order a product from us or use or apply for one of our services, you give us permission to collect, use, keep and disclose personal information that we have already collected from you as well as any additional personal information that you may provide to us, but only for the following reasons:

• To carry out our business activities, like answering your questions, processing your order, arranging for payment, confirming your identity, maintaining tax records, etc.
• To send you catalogues, flyers and offers by varying types of media about our products or services.
• To comply with legal or regulatory requirements.

2. We will not give your personal information to any other business, other than our affiliated companies, except under the following conditions:

• If we sell, lease, reorganize or dispose of any of our businesses, we will ask the new owner/operator to agree to treat your personal information in the same way that we do.
• We might compile data and provide it to another business. For example, a manufacturer might ask for the number of warranty claims filed against a certain product. If we do this, we will make sure that you cannot be individually identified.
• Other businesses may ask us if our customers would like to know about their products or services. If we think that you might be interested and you give us permission, we would give your contact information to that business, but only so that they could offer you their products or services.
• We may not perform all the services we make available to you. If another business is performing a service for us or for you, we may provide them with that portion of your personal information that they need to know to perform that service. Some of these businesses may be located outside of Canada. As a result, your personal information may be accessible to regulatory authorities in accordance with the law of these jurisdictions.

3. If you ask us to, we will remove some or all of your personal information from our records, unless there is a reason why we have to keep it. If we have to keep it, we will remove it as soon as we can. You may withdraw your consent to collect, use, keep, or disclose your personal information unless you are legally or contractually restricted from doing so. If you do withdraw your consent, however, we may not be able to provide you with certain services or products.

4. In order to request copies of your personal information we have on file or to withdraw your consent and request removal of your personal information from our records, you must make such a request in writing to the Privacy Officer.

For more information about our Privacy Policy, please visit our website at www.northwest.ca, call 1-800-563-0002, or e-mail us at PrivacyOffice@northwest.ca.