Privacy Policy

JTI-Macdonald Corp. (“JTI”, “we” or “us”), the operator of the publications and other information available at facetheconsequences.ca and faceauxconsequences.ca (the “Website”) on behalf of itself and of JTI Canada Tech Inc. (each a “Company” and collectively the “Companies”), is committed to protecting any personal information which you may provide while using, or that we may obtain from your use of, the Website. This Privacy Policy (the “Policy”) describes the types of information we may collect from or about you when using the Website or otherwise when communicating with us, and our practices regarding the collection, use and disclosure of that information.

THE WEBSITE IS NOT INTENDED FOR INDIVIDUALS UNDER 18 YEARS OF AGE. NO ONE UNDER AGE 18 MAY PROVIDE ANY PERSONAL INFORMATION TO OR ON THE WEBSITE. BY USING THE WEBSITE, YOU CONSENT TO THE COLLECTION, STORAGE, USE, DISCLOSURE AND RETENTION OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS POLICY. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITE.

OVERVIEW OF OUR PRIVACY PRACTICES

The purpose of this Policy is to inform you of our privacy practices and policies, including:

• the personal information collected by us;
• the purpose of collection and use of your personal information;
• the disclosure of your personal information;
• how we protect your privacy;
• your options to withdraw your consent;
• how you can request to access, amend, update or the deletion of your personal information; and
• our contact information should you have questions or concerns about our practices.

This Privacy Policy is designed to comply with applicable privacy legislation in Canada, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”). This Privacy Policy is incorporated into, forms part of and is subject to our Terms of Use. Further information with respect to our privacy practices is set out below.

PERSONAL INFORMATION COLLECTED

We collect the personal information you provide to us, and may also collect Website usage data, internet protocol (IP) address, and other similar information that you provide to us via the Website, including information collected through the use of cookies on your browser.

You should exercise discretion when disclosing your personal information to us, and should not disclose sensitive or confidential information that you wish to remain private.

NON-IDENTIFIABLE INFORMATION AUTOMATICALLY COLLECTED

The Website may automatically collect certain non-identifiable information regarding Website users, such as the date and time you access the Website, the Internet address of the website from which you linked directly to the Website, the operating system you are using, the sections of the Website you visit, the Website pages read and images viewed, and the materials you post to or download from the Website. We may collect, use, transfer and disclose aggregated and/or non- personal information.

COOKIES

The Website uses "cookies", a technology that installs information on a website user's computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to track your activity on the Website in order to respond to your needs, to offer personalized web page content and information for your use, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website.

PURPOSE OF COLLECTION AND USE OF YOUR PERSONAL INFORMATION

The Companies collect and use personal information that is collected through your use of the Website for the following purposes:

• To provide, maintain, administer and improve our Website or services (including but not limited to protecting the Companies and Website users from fraud);
• To analyze usage patterns and trends to enhance user experience;
• To provide you with information requested from us, including customer service and support to you;
• As permitted by, and to comply with, applicable laws and regulations;
• To notify you in connection with any changes to our services or this Policy;
• For any other purpose with your consent.

DISCLOSURE OF PERSONAL INFORMATION

We will keep personal information that you provide to us private, and will disclose such personal information only in accordance with this Policy.

The Companies do not sell, rent, or lease to third parties any personal information they collect from you. The Companies may disclose or share personal information with its authorized employees, agents, service providers and legal representatives for the purposes described in this Policy. We may also share your personal information with third parties that we engage to provide products and services on our behalf. The Companies will not otherwise share your personal information with third parties without your consent, unless authorized or required by law or as disclosed to you when the information is collected. The Companies may disclose your personal information to a government institution or agency that has asserted its lawful authority to obtain the information, or in order to comply with laws and regulations, or where the Companies have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to protect the Companies' rights and property. If the Companies are involved in the sale or transfer of some or all of their businesses, the Companies may disclose your personal information in connection with the transfer or sale.

HOW THE COMPANIES PROTECT YOUR PRIVACY

The Companies keep the personal information they collect about you confidential and have adopted reasonable physical, electronic and managerial procedures appropriate to the sensitivity of the data in an effort to safeguard the personal information you provide to the Companies. However, no collection, storage or transmission of information over the Internet on websites or otherwise can be guaranteed to be 100% secure, and therefore we cannot ensure, warrant or guarantee the security of any such information.

WITHDRAWAL OF CONSENT

You may withdraw your consent to the collection, use and disclosure of personal information about you at any time. To do this, please contact our Privacy Officer at the e-mail address listed in this Policy below, under the section “Resolving Your Concerns”. Withdrawal of your consent to the collection, use and disclosure of personal information may result in you being unable to continue use of our Website or services.

ACCESSING YOUR PERSONAL INFORMATION

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information held by the Companies and you may request that your personal information be corrected or updated or deleted in accordance with applicable laws. Please e-mail our Privacy Officer (under the section “Resolving Your Concerns”) and we will assist you.

You may be required to put your request in writing to confirm your request and identity. It is your responsibility to notify us of any changes to your personal information, including contact information, so we can contact you and inform you about updates to this Policy and any other relevant information with respect to your use of the Website.

RETENTION AND STORAGE OF PERSONAL INFORMATION

We retain personal information in compliance with our legal obligations, and only as long as necessary for the purposes for which it was collected. We securely destroy, erase or make anonymous personal information that is no longer required, in accordance with our guidelines and procedures.

We may store and process your personal information collected through the Website on our servers located in Canada. In some instances, your personal information may be stored, processed, shared or otherwise used on the servers of our third- party service providers (such as Microsoft Corporation and its affiliates), located in other countries. As such, foreign governments, courts, law enforcement or regulatory agencies may be able to access your personal information under foreign laws. Our third-party service providers are only permitted to collect, use, store, process and disclose your personal information in accordance with the purposes set out in this Policy or as required by applicable law.

PRIVACY POLICY CHANGES AND UPDATES

We may revise this Policy at any time, without notice to you. Your continued use of the Website constitutes your consent to the contents of any updated policy. Where we make significant changes to this Policy, we will notify you by sending you an email to the email address you provided informing you of the changes, or through an announcement or notice on the Website. You are responsible for periodically visiting our Website and this Policy to check for any changes.

RESOLVING YOUR CONCERNS

If you would like more information about this Policy or our privacy practices, have questions or concerns, or would like to make a request regarding your personal information in our possession as provided for under Canadian law, please contact our Privacy Officer by e-mail at: privacy.canada@jti.com.