ACL Services Ltd. ("ACL") respects your privacy and is committed to protecting your personal information. This policy outlines how we handle the collection, use and disclosure of your personal information. Our policy is guided by the provincial and federal privacy laws applicable in British Columbia, Canada.

What Information Do We Collect?

In the course of conducting business with you, ACL will collect information from you such as: your name, title, company or organization, address, telephone number, fax number, and email address. We may also collect your credit card details if you choose this payment option when purchasing any of our products and services.

If you participate in our surveys or contests, your survey opinion and submissions for our contests will be collected. If you provide your resume to us through, for instance, the Careers section of our web site, we will also collect this information.

On our web site, we may collect your Internet Protocol (“IP”) address and cookies. Your “IP address” is a unique 32-bit numeric address that distinguishes your computer from another computer. “Cookies” are small text files that contain information about you, such as your user name and password, which are stored on the web browser of your computer. ACL uses a high encryption algorithm on its cookies so that only our server can read and decrypt the contents within it and other parties will not be able to access such information.

What Privacy Principles Are Followed By ACL?

1. Accountability
ACL is responsible for ensuring the protection of the information you have provided to us. The Privacy Manager is responsible for ensuring that ACL takes the steps outlined in this policy to comply with its privacy obligations.

2. Why Do We Collect Your Information?
We collect information from you for the following reasons:

• to provide products and services to you (which may involve processing your order, invoicing and processing payment, and providing new product versions and updates);
  
• to provide information on our products and services that may be of interest to you;
  
• to verify your identity for the purpose of obtaining access to our products and services (for instance, the ACL Support Center is only available to our supported users);
  
• to contact you, when necessary, regarding issues concerning your use of our products and services;
  
• to obtain information about your use of our products and services, potentially through a survey to better understand your needs, as input to future product development plans;
  
• to gather general aggregate information based on IP addresses to track information about ACL web site usage (such as, the number of visitors, frequently viewed pages, number of downloads, etc.);
  
• to make it easier for you to use our web site (for instance, if you are a supported user, we will collect cookies of your email address and password so that you will not need to re-enter your password to log on to the ACL Support Center);
  
• to obtain information about your qualifications and skills if you submit your resume to us for the purposes of applying for a position with ACL; and
  
• the information may be legally required.
  

Our privacy policy, however, does not limit ACL from collecting and using information that is publicly available. This means, for instance, your name and business email address could be added to our email and/or postal communication list so that we can provide further information to you on our products and services.

We will, however, respect your choice not to be contacted. All our marketing email messages contain an option to automatically “opt-out” of receiving messages from us. You may also elect not to receive communication from us by sending an email to info@acl.com with your email address and (if applicable) your postal address to request that we remove your email, address and name from our mailing lists.

4. Limiting Collection
ACL will only collect information about you that is necessary to achieve the purposes identified in this policy.

5. Limiting Use, Disclosure and Retention
ACL will use the information you provide only for the purposes identified in this policy. We will not use this information for any other purpose unless we have obtained your consent.

ACL will only disclose information about you to its affiliated companies, distributors, and to authorized agents that assist us in performing our functions for the limited purposes listed above. Our agents may include companies and individuals that deliver packages, provide marketing assistance and process credit card transactions.

We will not sell or otherwise disclose the information collected from you to other third parties, except in those limited cases where we are legally required to do so (such as in response to a court order, or disclosure to a public body to assist in an investigation).

We will retain the information that we have collected from you only so long as it is necessary to achieve our stated purposes or if it is legally required that we retain such information.

6. Ensuring Accuracy
ACL will make reasonable efforts to ensure that the information we collect from you is accurate and complete. If you notice any errors in the information that we have collected from you or wish to update your information, please notify your ACL contact or email info@acl.com. You can advise us as to where you saw the incorrect information so that we can then correct or update such information. If you are a supported user, you may directly update your profile online at our Support Center.

7. Safeguards
ACL has taken reasonable steps to assure the security of any sensitive information that is transmitted to and from our web site. We use the VeriSign Server Digital ID certificate to ensure the security of all credit card transactions. Despite this, as the security of information transmitted over the Internet cannot be guaranteed, ACL is not responsible for any information transmitted to and from ACL over the Internet.

All our employees and contractors with access to any information you have provided are required to respect and preserve the confidentiality of your information in accordance with this policy.

8. Openness
ACL will endeavour to make our privacy policy readily available to you. If you need further clarification of our privacy policy and practices, you may contact our Privacy Manager. Upon your written request, we will also provide you with a record of information that we have collected about you. There may be some cases where we may not be able to disclose certain information about you if it would mean disclosure of personal information of another person or other confidential information, or if it would compromise our security systems.

9. Individual Access to Information.
If you require access to your own information, please write to us by fax, email or post, with your request. We will respond to you within thirty (30) days of receiving your request.

10. Compliance and Complaints
If you have any questions or concerns with our privacy policy and practices, you may contact our Privacy Manager by writing to:

ACL Services Ltd.
1550 Alberni Street,
Vancouver, BC,
V6G 1A5, Canada
Attn: Privacy Manager
Email: Privacy Manager

Tel: (604) 646-4284
Fax: (604) 692-1397

You may also contact the Privacy Commissioner of Canada (for international matters and inter-provincial matters) or the Information and Privacy Commissioner of British Columbia Privacy Commissioner (for British Columbian matters).

This Privacy Policy was last revised in September 2003.