We will inform our clients and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy outlines the principles and practices we will follow in protecting clients’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients and customers’ personal information and allowing our clients and customers to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to TGNA and its subsidiaries, Liptay Auctions and Remarketees Inc. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of TGNA.

Definitions

Personal Information –means information about an identifiable individual [ E.g., first and last name, age, home address and phone number, mobile phone number, driver’s license number, date of birth]. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy.

Privacy Officer – means the individual designated responsibility for ensuring that TGNA complies with this policy.

Policy 1 – Collecting Personal Information 1.1 Unless the purposes for collecting personal information are obvious and the client or customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client and customer information that is necessary to fulfill the following purposes: • To verify identity; • To identify client and customer preferences; • To open and manage a profile and/or account; • To obtain vehicle registrations • To provide requested products and services • To enrol the client in a program; • To send out organization information and marketing materials; • To ensure a high standard of service to our clients and customers; • To meet regulatory requirements; • To collect and process payments;

Policy 2 – Consent

2.1 We will obtain client and customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent). 2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client or customer member voluntarily provides personal information for that purpose. 2.3 Consent may also be implied where a client or customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client or customer does not opt-out. 2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and customers can withhold or withdraw their consent for TGNA to use their personal information in certain ways. A client’s or customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client or customer in making the decision. 2.5 We may collect, use or disclose personal information without the client’s or customer’s knowledge or consent in the following limited circumstances: • When the collection, use or disclosure of personal information is permitted or required by law; • In an emergency that threatens an individual's life, health, or personal security; • When the personal information is available from a public source (e.g., a telephone directory); • When we require legal advice from a lawyer; • For the purposes of collecting a debt; • To protect ourselves from fraud; • To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose client and customer personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as: • To conduct client, customer, member surveys in order to enhance the provision of our services; • To contact our clients and customers directly about products and services that may be of interest. • To provide information to Provincial Government Agencies for obtaining and transferring motor vehicle registrations. 3.2 We will not use or disclose client and customer personal information for any additional purpose unless we obtain consent to do so. 3.3 We will not sell client and customer lists or personal information to other parties [unless we have consent to do so].

Policy 4 – Retaining Personal Information 4.1 If we use client or customer personal information to make a decision that directly affects the client or customer, we will retain that personal information for at least one year so that the client or customer has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain client and customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client and customer personal information is accurate and complete where it may be used to make a decision about the client or customer or disclosed to another organization. 5.2 Clients and Customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client and customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 6.2 We will use appropriate security measures when destroying client’s and customer’s personal information such as shredding and/or incinerating documents, deleting electronically stored data when disposing of computer hardware. 6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Clients and Customers Access to Personal Information

7.1 Clients and Customers have a right to access their personal information, subject to limited exceptions. 7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. 7.3 Upon request, we will also tell clients and customers how we use their personal information and to whom it has been disclosed if applicable. 7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. 7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client or customer of the cost and request further direction from the client or customer on whether or not we should proceed with the request. 7.6 If a request is refused in full or in part, we will notify the client or customer in writing, providing the reasons for refusal and the recourse available to the client or customer.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer or designated individual is responsible for ensuring TGNA’s compliance with this policy. 8.2 Clients and Customers should direct any complaints, concerns or questions regarding TGNA’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client or customer may also write to the Information and Privacy Commissioner of New Brunswick.

Contact information for TGNA’s Privacy Officer or designated individual(s):

Mary Liptay mary@tgna.ca (506) 382-2777