Personal Information Privacy Policy

Personal Information Privacy Principles

Mighty Oaks has an ongoing commitment to protect the privacy and confidentiality of personal information held on Mighty Oaks' employees, sub-contractors, clients and others. This policy outlines how Mighty Oaks handles collection, use, retention, safeguarding, disclosure and access to this personal information.

In the course of its commercial activities, Mighty Oaks collects personal information about its employees, sub-contractors, clients and others. This information may be used for contact purposes, for general human resources purposes, to communicate with our clients and others with respect to business affairs relevant to them and in the course of providing contracted services to clients from Mighty Oaks' sites. Any personal information provided by clients is used solely for the purpose of providing contracted services to the client. Personal information does not include contact information, such as the name, title, business address or telephone number of an employee of an organization. In the context of this policy, the term "clients" includes all current, former and prospective clients.

Mighty Oaks recognizes the importance of protecting the personal information that it holds on its clients, employees, subcontractors and others. All client personal information collected by Mighty Oaks will comply with the policies and procedures established by the client and/or Mighty Oaks.

Why Does Mighty Oaks Collect Personal Information?

Mighty Oaks collects personal information in order that it may provide business services and products to its clients and others.

How Do We Collect Personal Information?

Mighty Oaks collects personal information only by lawful and fair means and only that which is reasonably necessary for the purposes identified. Whenever possible, we collect personal information about clients and other individuals directly from those parties or through referrals by persons whom such parties have requested to provide us with such information.

Sometimes we may obtain information about you from other sources including:

• Government agencies or registries
• Credit bureaus
• Other third parties that represent they have the right to disclose such personal information

How Do We Use Personal Information?

Mighty Oaks may use your personal information for the following purposes:

• To provide business services
• For billing, record-keeping and other client contact and service matters
• For audit and record-keeping purposes
• For account collection purposes
• To manage and develop its business and operations
• To learn about the needs of current and potential clients, to develop or offer services and products tailored to those needs and to communicate with those clients regarding current and future products and services
• To follow up on client comments and suggestions

In the normal course of business, we do not share or sell any personal information to third parties. We may share information in an anonymous aggregate form, and we reserve the right to share information among our affiliates.

Disclosure of Personal Information

Mighty Oaks will only disclose personal inforation for purposes related to providing services to its clients, or with your express consent, or if required or authorized by law. For example, we may disclose personal information:

• When the business services we are providing to you requires us to give your information to third parties
• Where it is necessary to establish or collect fees
• If we engage third party service providers on your behalf
• If a court issues a subpoena

Mighty Oaks will establish criteria for the retention of personal information, including, as appropriate, minimum and maximum retention periods and criteria and procedures for destruction of personal information which is no longer necessary or relevant for this identified purpose or required by law.

Personal information that has been used to make a decision about an individual will be retained for a reasonable period to allow the individual access to the personal information after the decision has been made.

Consent

We will obtain your consent to our collection, use and disclosure of your information either expressed for stated purposes, or implied when the purposes are not stated expressly but it would be reasonable in the circumstances to conclude that one would consent to such use, if asked. You may withdraw or amend any consent previously given by contacting our Chief Privacy Officer, subject to any legal or contractual restrictions and upon reasonable notice to us.

Your consent to our collection of certain personal information may be required in order for us to provide business services. However, we will not require, as a condition of providing a service that personal information not related to providing such service be collected.

Updating or Correcting Information

It is important that your information be accurate and up-to-date.

If any of your information changes, please inform us so that we can make any necessary changes.

If we hold information about you and you advise us that it is not accurate, complete and up-to-date, where appropriate, we will take reasonable steps to correct it.

Is Personal Information Secure?

Mighty Oaks uses appropriate and reasonable security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information under our control. Such measures will vary depending on the sensitivity, amount, format, nature and storage of the personal information, and will involve, as applicable, physical, organizational or electronic security measures.

Mighty Oaks requires that third party service providers to whom personal information may be transferred provide a level of security for such personal information that meets standards established by Mighty Oaks.

Access to Your Personal Information

We will respond promptly to any request for access to your personal information. There will be no cost for reasonable requests to such access, unless you request copies of records, or retrieval costs are excessive. We will advise you of the cost, if any, prior to the retrieval of such records or information. Mighty Oaks will not respond to requests for access to personal information where it is not required by law to do so, including frivolous or vexatious requests.

In certain circumstances, we may be unable to provide access to some or all of the personal information that we hold about you. Such circumstances include those in which the personal information cannot be separated from the records of others, cannot be disclosed for reasons of personal security or commercial confidentiality (including, in relation to Mighty Oaks or its clients) or is protected by professional standards relating to confidentiality or solicitor-client privilege.

Changes to our Personal Information Privacy Policy

As part of our regular review of all of our policies and procedures, we may change our policy from time to time.

Web Site

Please refer to our public Web site www.mightyoaks.com for an explanation of our Web site privacy practices.

Questions, Concerns, Requests for Access

If you have any questions or concerns, wish to access your personal information or wish to change your preferences regarding our use of your information, please write to:

Chief Privacy Officer,
Mighty Oaks
209-3347 Oak Street,
Victoria, BC, V8X 1R2
Email: privacy@mightyoaks.com