The EuroTEL respects the privacy of its Internet users and will protect that privacy as vigorously as possible and will only collect and store specific information required to deliver services to customers.

There may be occasions where specific personal information is requested before an individual can enter certain sections of a EuroTEL site. For example, registration is needed to enter online payment control panels or to participate in any EuroTEL online forums, contests or related online initiatives. This kind of registration helps us to ensure that content standards on these sections of the site are rigorously upheld or that contact can be made with users to inform them of new updates. Information requested in order to personalize the EuroTEL.ca homepage or any other EuroTEL site section would be a similar example.

In all such cases, EuroTEL will collect only information that is voluntarily provided by the user and undertakes that such information will be kept strictly confidential. Individual information provided to EuroTEL to gain access to any EuroTEL site will not be sold or made available to a third party.

EuroTEL does reserve the right, however, to perform statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of its sites so as to improve design and navigation and to gather marketing information. Only aggregated data from these analyses, not individual data, will be used for this purpose.

As well, users should be aware that certain non-personal information and data may be automatically collected by the EuroTEL through the operation of what are called "cookies". "Cookies" are small text files that identify an individual computer's browser entering a web site. They allow the site to track that browser's movement through the site over several sessions. Through cookies, a web site can recognize repeat users, facilitate the user's access to and use of the site and allow a site to track usage behaviour that will allow content improvements. The EuroTEL uses cookies only for the above-mentioned purposes and will not use them to identify users or to track non-EuroTEL usage.

If you do not want a cookie placed on your computer by the EuroTEL, you may disable cookies altogether by modifying the Preferences section of your Netscape or Internet Explorer browser (under Edit/Preferences/Advanced). Note that it is possible that some aspects of EuroTEL sites may be unavailable to you if you choose this option.

If you have no problem accepting cookies, but wish to be informed of their appearance, you may turn on a warning prompt by modifying the cookie warning section in Edit/Preferences/Advanced.

Statement of Policy

It is the policy of the EuroTEL to control the collection, use, and disclosure of personal information in accordance with all requirements set out in the Personal Information Protection and Electronic Documents Act. In certain circumstances personal information may be collected, used, or disclosed without the knowledge and consent of the individual. Exemptions include, but are not limited to personal information gathered for:

• Legal, medical, or security reasons.
• Detection and prevention of fraud or for law enforcement.
• Journalistic, artistic or literary purposes if its use is confined to those purposes.

Requirements

The following requirements shall be met by EuroTEL unless exempted by the Personal Information Protection and Electronic Documents Act.

1. Accountability
The EuroTEL is responsible for personal information under its control and shall designate a Privacy Coordinator to be accountable for the EuroTEL's compliance with the Act.

2. Identifying Purposes
The purposes for which personal information is collected shall be identified by the EuroTEL at or before the time the information is collected.

3. Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information.

4. Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by the EuroTEL.

5. Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

6. Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

7. Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

8. Openness
The EuroTEL shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

9. Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the EuroTEL's compliance.

Responsibility

• All EuroTEL employees, who collect, maintain and/or use personal information, are responsible for insuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.
• The Privacy Secretariat is the department responsible for supervising compliance with the legislation and for initiating procedures, guidelines and schedules that will be developed to effect this policy.
• The Privacy Coordinator is accountable for the EuroTEL's policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.

Operating Principles

All questions related to the interpretation and application of this policy should be directed to the Privacy Coordinator.