Privacy

At Peacehold, our customers’ privacy is of utmost importance. We are deeply committed to safeguarding the personal and sensitive information entrusted to us. Every step we take is guided by a strict adherence to privacy laws and ethical standards, ensuring that all data is securely handled and protected.

Our customers’ trust is the foundation of our business, and we continuously strive to maintain and strengthen that trust by prioritizing their privacy in everything we do.

Peacehold Inc. General Policy on Privacy

Protecting the privacy and confidentiality of Peacehold Inc.’s customers’ and employees’ personal information has always been an important aspect of Peacehold Inc.’s operations.

It is the responsibility of all Peacehold Inc. employees to follow Peacehold Inc.’s Privacy Code and related policies when collecting and handling the personal information of Peacehold Inc. customers or employees.

Personal information is defined as any piece of information, either factual or subjective, about an identifiable individual. Personal Information does not include the name, title, business address or telephone number of an employee of an organization.

It is Peacehold Inc.’s policy that we obtain an individual’s consent when an employee or website collects, uses or discloses personal information.

Peacehold Inc. will also inform its customers and employees of the purpose for the collection, use and disclosure of personal information.

Peacehold Inc. takes care to safeguard all personal information in its possession against loss, theft and unauthorized use or disclosure. Peacehold Inc. uses reasonable efforts to ensure that such information is accurate and up to date. We provide our customers and employees with a procedure to access the information we obtain and to make corrections to this information where appropriate. Please review the Peacehold Inc.’s Privacy Code and Privacy Policy for more information on our commitment to privacy.

Peacehold Inc. Internet Privacy Policy

Peacehold Inc. respects your right to privacy and is committed to the protection of your personal information. This policy summarizes what personally identifiable information we may collect, how we might use it and to whom we may disclose it to. This policy also describes other important topics relating to your privacy.

Information Collection

Peacehold Inc. will only collect personally identifiable information (such as name, address, telephone number, or email address) that you voluntarily provide through our website or email correspondence. We will collect general information (such as the type of browser you use, the files you request, and the domain name and country from which you request information) to improve our website and better meet your needs.

Information Automatically Gathered from Your Device

Device and browser information. Peacehold Inc. may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. Peacehold Inc. collects this information automatically from your device and web browser through cookies and similar technologies.

Information About How You Interact With Us

Peacehold Inc. may collect technical data about your usage of Peacehold Inc. Internet Sites and Apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Peacehold Inc. promotional emails opened, and dates and times of interactions. Peacehold Inc. collects this information using cookies and similar technologies.

Location Information

Peacehold Inc. may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Peacehold Inc. Apps will NOT access precise real-time location information from your device unless you grant permission to do so.

Use and Disclosure of Information

Before we collect any personally identifiable information, we will identify the purpose for our collection, use and any possible disclosure of your personal information.

For instance, the information you supply will be used by Peacehold Inc. to respond to your inquiries, supply you with requested information on Peacehold Inc. products and services, or track orders you place with Peacehold Inc.

Peacehold Inc. will seek your consent to use your personal information at the time of collection or in advance. Consent may be expressed in writing, or implied, and in some cases may be provided verbally or electronically. With your consent, authorized third parties may be utilized by Peacehold Inc. to collect, track and process such information. It may also be necessary, if required by law or if pertinent to judicial or governmental investigations, to release your personally identifiable information.

Please note that should you choose not to provide Peacehold Inc. with the necessary personal information, Peacehold Inc. may be unable to service your request for Peacehold Inc. products or information. We will use all reasonable efforts to comply with your request.

Peacehold Inc. Privacy Code

The Peacehold Inc. Privacy Code is a formal statement of the principles and guidelines concerning the requirements for the protection of personal information provided to Peacehold Inc. by its customers and employees. Peacehold Inc. strives to provide its customers with the best service possible. This means handling your personal information fairly and honestly.

The purpose of the Peacehold Inc. Code is to provide responsible and transparent practices in its management of personal information in keeping with applicable legislation. It tells you how we protect your privacy and the confidentiality of your personal information.

The 10 Principles of Privacy

The following principles developed by PIPEDA form the basis of Peacehold Inc.’s fair information practices and outline Peacehold Inc.’s commitment to protecting your privacy.

Accountability

Every Peacehold Inc. employee is responsible for maintaining the confidentiality of all information to which they have access. Peacehold Inc. employees are informed about the importance of privacy and receive ongoing updates on privacy related policies.

In addition to establishing the Privacy Code, we have appointed a Chief Privacy Officer who is responsible for overseeing the personal information handling practices at Peacehold Inc. and ensuring we are in compliance with our Privacy Code and related policies.

Identifying Purposes: Why We Collect Information

Should Peacehold Inc. need to collect personal information from you, Peacehold Inc. will identify the purpose for the collection at or before the time Peacehold Inc. collects it. Peacehold Inc. will only collect the information needed to fulfill the purpose we have identified and for no other purpose. If Peacehold Inc. wishes to use your information for any other purpose, we will obtain your consent.

Peacehold Inc. asks for your personal information in order to meet your service needs.

The information Peacehold Inc. asks for depends on which services you require from Peacehold Inc.

Consent

Peacehold Inc. seeks your consent to collect, use or disclose your personal information at the time of collection or in advance. Peacehold Inc. has taken steps to ensure that our language is clear and understandable so that you know why we are collecting your information and how we will use it. Please note that under certain legal and medical circumstances, it may be impossible or impractical to obtain an individual’s consent.

Consent may be expressed in writing, or it may be implied in the circumstances. In addition to writing, your consent may also be expressed verbally or electronically.

In deciding what form of consent is appropriate, Peacehold Inc. will consider the type of personal information Peacehold Inc. needs, its use, any necessary disclosures, the type of customer contact that is involved and applicable legislation.

In general, you can choose not to provide Peacehold Inc. with some or all of your personal information at any time. However, should you make this choice, Peacehold Inc. may not be able to provide you with the service or information that you requested or that could be offered to you. Upon request, Peacehold Inc. will explain your options of refusing or withdrawing consent to the collection, use, and disclosure of your personal information.

Limiting Collection

Peacehold Inc. does not collect personal information indiscriminately. Rather, we limit our collection of personal information to only what is necessary for the purpose we have identified. We employ fair and lawful means in the collection of personal information.

Limiting use, Disclosure and Retention Accuracy

Peacehold Inc. will use or disclose your personal information for the purpose for which it was collected, except with the consent of the individual or as required by law.

There are some instances in which Peacehold Inc. may be required to disclose your personal information as part of Peacehold Inc. conducting its business in the ordinary course. Peacehold Inc. hires other organizations to provide support services and will require them to conform to our privacy standards.

Peacehold Inc. will retain personal information only for as long as required to fulfil the identified purpose. Once your personal information is no longer required, it will be destroyed.

Accuracy

Peacehold Inc. endeavours to keep Peacehold Inc.’s personal information holdings complete, up-to-date and accurate. While Peacehold Inc. does their best to ensure our information is accurate, Peacehold Inc. does rely on individuals to inform Peacehold Inc. of any relevant changes in their personal information.

Should you discover, upon review of your personal information, that amendments are required, please advise Peacehold Inc. If the requested change is accepted, the personal information will be modified in accordance with your request as soon as possible and you will receive a copy of the amended portion of the record.

When a correction or amendment has been made to a personal record, Peacehold Inc. will, where appropriate, send a copy of the correction to any persons or organizations that have access to the information in question.

If the requested change is not accepted, you will be notified in writing that the change will not be made. You will be given an opportunity to submit a statement concerning the dispute which will be maintained along with the disputed information for as long as Peacehold Inc. retains that information.

Safeguards: Protecting your Information

Peacehold Inc. employs appropriate safeguards to make certain that your personal information is protected from loss or theft as well as from unauthorized access or disclosure.

Peacehold Inc. may employ other companies to provide services to you on Peacehold Inc.’s behalf, such as data processing or records retention. When this occurs, Peacehold Inc. has contracts in place to ensure your personal information is protected by the same high standards that govern Peacehold Inc.’s information handling practices.

The nature of the safeguards and level of protection will depend on the sensitivity of the information in question and incorporates physical security measures (locked doors and file cabinets), organizational controls (visitor sign in and employee identification cards), and technological tools (computer passwords and encryption).

Peacehold Inc. audits its security measures to ensure our practices conform with Peacehold Inc.’s Code and related privacy policies.

Openness: Keeping you Informed

We have prepared this Privacy Code to keep you informed of our commitment to protecting your personal information. It is available to the public in paper form at the address set out below and in electronic form by emailing info@peacehold.com. If you have any privacy related questions or concerns not addressed in the Privacy Code, please contact our Chief Privacy Officer, by phone, by email or through the Callback form below. We will respond to all inquiries within 3 business days.

Providing Access

Peacehold Inc. will provide you with access to the information it retains about you upon receipt of a written request and satisfactory identification. We may charge you a small fee and if so, we will give you notice in advance of costs for processing your request.

Upon written request and satisfactory identification, we will also correct or amend any personal information if its accuracy and completeness is found to be deficient.

There are some instances where Peacehold Inc. will not be able to provide an individual with the requested information. Some of these instances include where the information:

• consists of references to other persons that cannot be otherwise severed
• is subject to solicitor–client privilege
• contains confidential Peacehold Inc. proprietary information
• has already been destroyed due to legal requirements or because it was no longer needed for the identified purpose

If Peacehold Inc. is unable to provide you with the information you have requested, the reason for the refusal will be explained in writing.

Providing Recourse

You may at any time initiate a formal privacy inquiry by contacting any of the above personnel and providing the necessary information to complete Peacehold Inc.’s Request for Information Form. The information you provide to Peacehold Inc. on this form will be collected, used or disclosed solely for the purpose of resolving your question or concern. Once your request is received, Peacehold Inc.’s Chief Privacy Officer will promptly initiate an investigation and respond to your concern in writing. If the issue is still not satisfactorily resolved, Peacehold Inc. will provide information on other complaint procedures that may be available to you.