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Commitment to Privacy of Personal Information
Competitive Computing Consultants Inc. (CCCI) is committed to protecting the privacy of all personal information it collects and uses. This Privacy Policy is designed to be compliant with applicable legislation, as well as established guidelines for business organizations and its own internal policies and procedures.

This Policy may be updated from time to time to reflect developments in Sarakinov Consulting Inc. practices, technology or in the law. Updates will be made available in the same way as the Policy.

Personal Information
Personal information is any information that can be used to distinguish, identify or contact a specific individual. This information can include an individual’s opinions or beliefs, as well as facts about or related to the individual.

Business contact information and other publicly available information are not generally considered personal information.

Accountability
CCCI is responsible for all personal information under its custody or control, including information which it may transfer to a third party for processing. CCCI has a designated Privacy Officer to oversee the handling of personal information.

The Privacy Officer may be contacted at:
Competitive Computing Consultants Inc.
1 Yonge Street, Suite 1801
Toronto, ON, M5E 1W7, Canada
Phone: (416) 214-7746
e-mail: privacy@competitivecc.com

CCCI is responsible for all personal information sent to third parties for processing or to service providers who provide services to CCCI. CCCI requires any such third parties to use the personal information only for the purposes for which it is provided to them and to protect the security of the personal information in accordance with privacy laws.

Purposes for Collecting, Using and Disclosing Personal Information
CCCI collects and uses personal information only for the following purposes:

• For the purposes of providing services.
• For research purposes.
• To inform individuals of future events and      opportunities related to our company.

CCCI will identify the purposes for which the information is being collected before or at the time of collection. If information is to be used for a purpose not previously identified, CCCI will identify this purpose prior to use and provide individuals with an opportunity to opt out of this activity.

Consent
Except as otherwise permitted or required by law, CCCI, uses and discloses personal information only with the consent of the individual. CCCI will seek consent either at the time information is collected or after collection but before the information is used.

An individual may withdraw consent to the use of his or her personal information for any purposes at any time by contacting CCCI at the address set out above.

CCCI will explain the consequences of withdrawing consent. Please allow us a reasonable time to process any request to withdraw consent.

Consent to the Collection of Information from the Website
Personal information may be collected via our website. Any personal information provided by an individual over the website will be treated in accordance with this Policy.

Submission of your personal information via our website will imply your consent for the information to be used for the purposes for which it was collected (identified before or at the time of collection).

You may withdraw consent for the use of your personal information for any purposes at any time by contacting CCCI at the above address.

Accuracy
CCCI seeks to ensure that the personal information it uses is accurate and up to date. Please assist us by advising us of any inaccuracies you may notice and we will make appropriate corrections.

Limiting Disclosure and Retention of Personal Information
CCCI limits the collection of personal information to that which is necessary for the purposes for which it is collected.

Only employees, contractors and agents with a need to know for the purposes of carrying out their duties are granted access to personal information.

CCCI retains personal information only as long as is necessary for the specified purposes, or for a period dictated by applicable legal requirements.

Safeguards
CCCI protects personal information against such risks as loss or theft, unauthorized access, disclosure, copying, modification and destruction by using appropriate security measures. CCCI is committed to protecting the information regardless of the format in which it is held.

The employees, contractors and agents of CCCI with access to personal information are required to respect the confidentiality of that information by signing a Confidentiality Agreement, participating in privacy training and implementing methods of protection that include:

Physical measures such as locked filing cabinets and restricted access to offices
Organizational measures such as limiting access to a “need to know” basis
Technological measures such as passwords, encryption, etc.

Access
Upon request, CCCI will inform an individual of the existence, use and disclosure of his or her personal information. Requests may be made in writing to the Privacy Officer.

On receiving a request, CCCI may require sufficient information to confirm an individual’s identity before releasing personal information. Upon receiving a request, CCCI may disclose: whether or not it holds personal information about the individual, the source of the information, an account of third parties to whom the information has been disclosed.

CCCI may also allow the individual to view the information or receive copies of the information. There may be some circumstances in which CCCI cannot provide access to the information requested. This includes information about third parties and information that cannot be disclosed for legal or security reasons. CCCI will explain its inability to provide access to the information in those circumstances.

Subject to applicable legislation, CCCI will endeavor to provide this information within 30 days of receipt of a request. CCCI may seek to extend this time period as permitted by law.

CCCI will correct or amend any personal information that is shown to be inaccurate or incomplete.

Non-personal Information
Use of Cookies on Our Site
CCCI uses “cookies” for functional aspects of our website.
We honour “Do Not Track” if it is set on your web browser. A cookie is a text file that a user’s web browser places on their hard drive for record-keeping purposes and sometimes to track information about users. Cookies cannot be used to run programs or deliver viruses to your computer. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you choose to decline the use of cookies, you will be able to fully experience all of the CCCI website.

Display Advertising, Re-marketing & Audience Data
CCCI does not use Third party vendors or other platforms to advertise online.
We do not display advertising to show relevant offers to our website visitors.
We do not use Third party vendors (including Google), first party cookies (e.g., Google Analytics cookie) and third party cookies (e.g., DoubleClick cookie) together to inform, optimize, and serve advertisements based on someone’s past visits to our website.

Questions and Complaints
For further information about the information handling practices of CCCI, or to make a complaint, please contact the Privacy Officer. CCCI will investigate all complaints and will take appropriate action to address the results of the investigation.