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Privacy Policy

Policies and Procedures

Premise

NFL Canada Inc. is committed to protecting individual's personal privacy. This includes all information collected from individuals by NFL Canada Inc. directly or through a partner acting in combination with NFL Canada Inc. The following document outlines the processes, securities and commitments NFL Canada Inc. has to manage how information is to be used and how to protect it.

Information Collection / Permission Marketing

In coherence with Bill C-6 (see below for details), NFL Canada Inc. understands the importance of being upfront with consumers in its desire to initiate future direct communications. NFL Canada Inc. (along with its partners) will ensure that all personal information collected will be done following permission marketing best practices.

It is a mandatory policy to present on all data collection opportunities the option for each individual to partake in an event by supplying personal information, while opting to refuse to receive further communications from NFL Canada Inc. (or it's partners). NFL Canada Inc. can assist in the design of all data collection processes to ensure the consumers are being well informed and this policy is being followed. Any personal information collected that has not presented the consumer this option will not be accepted by NFL Canada Inc. and therefore will not be eligible to inclusion in future communications.

Following this policy properly will allow both NFL Canada Inc. and its partners to maximize the direct communications through co-branded marketing and promotional activities.

Security of Information

NFL Canada Inc. use industry standard technologies to keep personal Information as secure as possible. Access to personal Information is permitted among our employees only on a need-to-know basis, and any outside contractors with access to such information must first sign a confidentiality agreement with us.

Ownership of Information

Personal information collected by NFL Canada Inc. independently will remain in the sole control of NFL Canada Inc.

In those circumstances where NFL Canada Inc. participates in a joint data collection promotion or event with one or more of its partners (in a co-branded communication) the information collected will be co-owned by NFL Canada Inc. and the partners participating in the event. In these cases NFL Canada Inc. is committed to associate all information collected to a specific source code, date and event. This tracking will identify (by record) those parties that will have access to the information collected. Each record will be assigned "Ownership" to personal information, allowing for information to have one or more then one "Owner". At no point in time will NFL Canada Inc. distribute or share (written or electronically) the information collected with another party, unless written authorization is received by all parties considered to hold "Owner" rights on said information.

Sharing of Information

When NFL Canada Inc. collects or is provided personal information it will be securely stored in a relational database system. This system (as outlined above) will associate date, event and source codes to ensure that proper ownership tracking can be maintained.

At such time NFL Canada Inc. (on its own or in relationship with a partner) wishes to utilize the information available to communicate directly with consumer the database system will become the primary source. To ensure no conflicts with ownership rights or privacy policies NFL Canada Inc. will at no time distribute or sell the list of personal information to an outside party. NFL Canada Inc. will retain control of the data itself and the purpose for which it will be used. If the data to be used is not solely "Owned" by NFL Canada Inc., they will advise each "Owner" partner of the intentions to use the information. If this intention in any way interferes with existing partner information guidelines or privacy policies, NFL Canada Inc. will negotiate a satisfactory resolve prior to moving forward. It must be understood that NFL Canada Inc. intends on developing a long term communication relationship with consumers interested in understanding more about the "NFL" and it is for this reason that NFL Canada Inc. partners must agree to share personal information when it is collected using NFL branding, offers, contests, etc.

Personal Privacy Legislation

Bill C-6 Summary

The "Personal Information Protection and Electronic Documents Act" (better known as Bill C-6) has been in effect since January 1st 2001. The bill sets rules for how the information will be collected and used by corporations. The guiding principle surrounding Bill C-6 is the responsibility for all corporations to collect permission from consumers to use their personal information for communication purposes.

NFL Canada Inc. remains committed to personal privacy and will make every effort to understand, follow and remain up to date as to how the Government of Canada proceeds with personal privacy, data collection and direct communication legislation. As such, NFL Canada Inc. expects its partners to do the same. Any and all consumer (or partner) complaint regarding personal privacy will be considered with due respect and responded to in a timely manner.

NFL Canada Inc. has identified the following key points from the Bill C-6 legislation to become its primary basis for information management policies and procedures:

The purpose for which personal information is collected shall be identified by the organization at or before the time the information is collected.

The organization shall document the purposes for which personal information is collected in order to comply with the Openness principle (Clause 4.8) and the Individual Access principle (Clause 4.9)

When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is required by law, the consent of the individual is required before information can be used for that purpose.

An organization is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing.

Individuals can give consent in many ways. For example:

(a) An application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses.

(b) A check off box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;

(c) Consent may be given orally when information is collected over the telephone; or

(d) Consent may be given at the time that individuals use a product or service.

Source: Parliament of Canada

Technical Security

Along with the policies and procedures listed above, NFL Canada Inc. has established the proper technical infrastructure to manage all personal information collected within a relational database system. Combining the properly skilled personal with a system that uses industry standard hardware and software all data collected will be treated with the respect and controls it requires. In conjunction with the systems platform information security will be reinforced through the use of UPS power management controls and appropriate backup and disaster recovery procedures. Complete with off site storage of regular backup files will ensure that electronic information may be maintained safe from most expected disasters.

In terms of outside interference, the information maintained is restricted from access to only those personal provide individual level security. Outside interferences are controlled through the use of a Linksys router with firewall protection.