Preface

Orion Technologies Inc. (referred to as “Orion Technologies”) is committed to keeping the personal information of its customers accurate, confidential, secure and private. Our Privacy Policy has been designed to inform employees, customers, and third parties/partners of Orion Technologies of our commitment and recognition to our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Contents

Our Privacy Policy describes the principles by which Orion Technologies protects the privacy of personal information in its possession. It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the customers’ rights in respect of this information. Our Privacy Policy incorporates and expands on the 10 principles for the protection of personal information, as devised by the Canadian Standards Association (CSA).

The Privacy Policy applies to personal information about the customers of Orion Technologies and other individuals that is collected, used or disclosed by Orion Technologies. This Privacy Policy does not apply to information about the employees of Orion Technologies. Orion Technologies does, however, protect the confidentiality of such information in accordance with the law and our own policies.

Personal Information Protection Principles

1. Accountability

Orion Technologies is accountable for the protection of all personal information within the organization’s possession or control, including any personal information that has been transferred to a third party for regulatory, legal or processing purposes. Orion Technologies will require a comparable level of protection of this information from its third parties/partners relations.

Orion Technologies has established a Privacy Office, which has overall responsibility for our protection of personal information and for Orion Technologies’ compliance with this Privacy Policy.

2. Identifying Purposes

Personal information that Orion Technologies collects from customers includes:

• the customer’s name and address and other contact information, such as telephone numbers, email address and job title.

Orion Technologies will make the individual aware of the purposes for which Orion Technologies is requesting the personal information. If Orion Technologies identifies other purposes for which the personal information may be used, Orion Technologies will seek the individual’s consent prior to such use. Orion Technologies will advise that it is the individual’s right to refuse permission for Orion Technologies to use personal information for any new purposes.

Additional purposes for collecting personal information may be identified to an individual before or at the time of his request for products and/or services. However, at a minimum Orion Technologies will collect personal information for the following purposes:

• To verify the customer’s identity;
• To determine the customer’s eligibility for products or services;
• To register for sales trainings, presentations and/or webinars;
• To assist us in updating the customer’s credit worthiness and the collection of accounts;
• For pre-authorized payments for products and/or services;
• To prevent fraud with respect to both the customer and our company;
• To meet legal, regulatory and settlement requirements.

3. Consent

The knowledge and consent of an individual are generally required for the collection, use or disclosure of personal information and Orion Technologies will seek to obtain consent before or when it collects, uses, or discloses personal information about an individual. An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly. However, Orion Technologies will collect, use or disclose personal information without an individual’s knowledge and consent only in limited circumstances and as permitted by law, such as in the case of an emergency where the life, health or security of an individual is threatened. Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.

All new and existing customers will be informed of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting Orion Technologies with any inquiries.

4. Limiting Collection

Orion Technologies limits the amount and type of personal information it collects to that which is necessary for its business and as permitted by law. Each third party/partner of Orion Technologies will be responsible for its own collection, use and disclosure of information. Personal Information will be collected using procedures that are fair, transparent and lawful.

5. Limiting Use, Disclosure and Retention

Orion Technologies will only use the personal information for the purpose for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose or as is required by law. Orion Technologies will develop explicit retention periods for closed accounts, after which the personal information will be destroyed or made anonymous.

Under certain exceptional circumstances, Orion Technologies may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.

6. Accuracy

Orion Technologies shall take all reasonable steps to ensure that all personal information will be kept accurate, complete and up to date.

Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.

7. Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, Orion Technologies will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis and the use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.

8. Openness

Orion Technologies will make its policies and practices relating to the protection of personal information available to its customers. Orion Technologies will keep its customers informed of these policies and practices and customers shall be provided access to all related policies and procedures via Orion Technologies’ web page. The information will be available in a format that is easy to understand.

9. Individual Access

Any customer of Orion Technologies can have access to the personal information about them that Orion Technologies has in its possession or control. Any customer may request that their personal information be amended for purposes of accuracy and completeness.

Customers can make their requests by telephone (1-866-333-0668), via email (privacy@oriontechnologies.ca) or in writing (3551 boul. St-Charles, suite 143, Kirkland, Quebec, Canada, H9H 3C4, Attention: Privacy Officer).

Response to an individual’s request will be made in a timely and efficient manner.

10. Challenging Compliance

Any customer of Orion Technologies may challenge Orion Technologies’ compliance with this Privacy Policy by contacting Orion Technologies directly. Orion Technologies has policies and procedures to receive, investigate and respond to individuals’ complaints and questions.