Privacy

Privacy Policy

Sutton Fair

1. Introduction

The Sutton Agricultural Society (“Sutton Fair”) is committed to maintaining the accuracy, security and privacy of personal information. This Privacy Policy is a statement of principles and guidelines for the protection of personal information of our exhibitors, customers, personnel, service providers and other individuals. The objective of the Sutton Fair Privacy Policy is to ensure responsible and transparent practices in the management of personal information, in accordance with applicable legislation.

This Privacy Policy applies to Sutton Fair and its personnel and agents. Sutton Fair does not include exhibitors, resellers or distributors of Sutton Fair products and services. Any time you do business with Sutton Fair, or with an agent authorized to act on our behalf, you are protected by the rights and safeguards contained in this Privacy Policy. For the purposes of this Privacy Policy, “affiliates” means the parent company, subsidiaries and affiliated companies of Sutton Fair, as they may exist from time to time, and the Sutton Agricultural Society and its parent company, subsidiaries and affiliated companies as they may exist from time to time.

In addition to this Privacy Policy, Sutton Fair may also be subject to the requirements of applicable legislation and regulations and the orders of any court, regulatory body or other lawful authority.

2. Personal Information

Personal information is information about an identifiable individual. Personal information does not include aggregated information that does not allow an individual to be identified. An individual’s business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information.

3. Privacy Principles

The following are the ten privacy principles forming this Privacy Policy.

Principle 1 – Accountability

Sutton Fair is responsible for personal information under its control and shall designate one or more persons who are accountable for Sutton Fair’s compliance with the following principles. Sutton Fair has established a Chief Privacy Officer to oversee compliance with this Privacy Policy. Contact information for the Sutton Fair Chief Privacy Officer is provided below.

Principle 2 – Identifying Purposes for Collection of Personal Information

Sutton Fair shall identify the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Sutton Fair collects, uses or discloses of personal information are described in section 4 below.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of his or her personal information, except where inappropriate or as permitted by law. In obtaining consent, Sutton Fair shall use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Sutton Fair shall take into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. Consent shall not be obtained through deception. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Sutton Fair will advise the individual of the implications of such withdrawal.

Principle 4 – Limiting Collection of Personal Information

Sutton Fair shall limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Sutton Fair. Personal information shall be collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose or which information is being collected.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information

Sutton Fair shall not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Sutton Fair shall retain personal information only as long as necessary to fulfill the identified purposes.

Principle 6 – Accuracy of Personal Information

Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Sutton Fair shall update personal information about individuals as and when necessary to fulfill the identified purposes or upon notification by the subject individual. Sutton Fair will not routinely update personal information, unless such process is necessary to fulfill the identified purposes.

Principle 7 – Security Safeguards

Sutton Fair shall protect personal information by security safeguards appropriate to the sensitivity of the information. Sutton Fair shall use reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Sutton Fair shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the limited purposes for which it is to be used.

Principle 8 – Openness Concerning Policies and Practices

Sutton Fair shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Sutton Fair shall make information about its personal information policies and practices available on the Sutton Fair website at www.Suttonfair.com and upon request to the Chief Privacy Officer via the contact information provided below.

Principle 9 – Individual Access to Personal Information

Upon written request from an individual pursuant to Principle 8, Sutton Fair shall inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions, shall give the individual access to that information. If access is denied, Sutton Fair shall notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her. If access is granted, Sutton Fair shall afford the requesting individual a reasonable opportunity to review the personal information collected by Sutton Fair. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Sutton Fair may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Sutton Fair or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance

An individual shall be able to address a challenge concerning compliance with this Privacy Policy to the Sutton Fair Chief Privacy Officer.

4. Identified Purposes for the Collection, Use and Disclosure of Personal Information

Sutton Fair and its agents, affiliates and service providers may collect, use and/or disclose your Personal Information for the following purposes:

(a) to consider whether Sutton Fair or any of its affiliates should establish or continue a commercial or franchise relationship with existing or potential exhibitors, including without limitation, to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and confer with banking institutions;

(b) to establish and maintain commercial or franchise relations with exhibitors, customers, suppliers, financial institutions, and affiliates, and to provide ongoing products and services, administer accounts, make and receive payments, engage in leasing arrangements (including without limitation, with M.T. Leasing Inc.), and fulfill contractual obligations;

(c) to understand and respond to franchisee and customer needs and preferences, including to communicate with exhibitors and customers and to conduct surveys and promotions;

(d) to develop, publish and distribute our franchise newsletters, press releases, marketing and advertising media, and other Sutton Fair branded products and services, in any format or media;

(e) to develop, enhance, market, sell, provide and inform you of Sutton Fair’s products and services;

(f) to develop, enhance, market, sell, provide and inform you of products and services of third parties, including our affiliates and franchise suppliers, with whom Sutton Fair and/or its exhibitors have a commercial relationship;

(g) to manage and develop Sutton Fair’s and its affiliates’ businesses and operations;

(h) in the course of conducting regular human resources operations, compensation, tax and benefits administration, including for the purposes of establishing, managing or terminating an employment or consulting relationship, to administer corporate travel, and to obtain and provide references regarding prospective, current or former personnel and exhibitors;

(i) to update and verify our databases and information provided by third parties;

(j) to monitor communications to ensure the consistency and quality of the products and services of Sutton Fair, its affiliates, exhibitors, suppliers, and other third parties with whom Sutton Fair has a commercial relationship;

(k) to detect and protect Sutton Fair, its affiliates, exhibitors and other third parties against error and fraud and other illegal activity, and to audit compliance with Sutton Fair’s corporate policies and contractual obligations;

(l) to engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Sutton Fair or its affiliates or exhibitors;

(m) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and

(n) for any other purpose to which you consent.

In addition to the purposes identified above, Sutton Fair may collect, use or disclose personal information from or to an organization or individual (including an affiliate):

(1) who, in the reasonable judgment of Sutton Fair, is providing or seeking the information as an agent of the subject individual;

(2) retained by Sutton Fair to perform functions on its behalf or to provide services to Sutton Fair, provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Sutton Fair;

(3) where the subject individual consents to such collection, use or disclosure, or as required or permitted by law.

Consent

BY SUBMITTING PERSONAL INFORMATION TO SUTTON FAIR OR ITS AFFILIATES, SERVICE PROVIDERS AND AGENTS, YOU AGREE TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION FOR THE IDENTIFIED PURPOSES DESCRIBED IN THIS PRIVACY POLICY, PROVIDED THAT SUCH COLLECTION, USE AND DISCLOSURE IS IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to any one or all of the purposes described in Sections 4(a), (b), (c), (d), (e), (f), (g), (i), (j), (l) and (n) at any time with reasonable notice by contacting the Sutton Fair Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to establish or maintain a franchise or commercial relationship or provide you or continue to provide you with some products, services or information which may be of value to you. To the extent that you provide Sutton Fair with personal information of another person, you represent that you have the power and/or have obtained all necessary consents from such person to enable Sutton Fair to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

5. Privacy and our Websites

Cookies – When you access the Sutton Fair websites, we may use a browser feature called a ‘cookie’ to collect information that is not personally identifiable (such as the type of Internet browser and operating system you use, the domain name of the website from which you came, number of visits, average time spent on our website, and pages viewed). A cookie is a small text file containing a unique identification number that identifies your browser, but not you, to our computers each time you visit one of our websites that uses cookies. Unless you specifically inform us, we will not know who you are. In addition to the identified purposes described in our Privacy Policy, Sutton Fair may use this cookie information and share it with our affiliates and other organizations with whom we have a commercial relationship to measure the use of our websites and to improve the functionality and content of the websites. If you wish, you can reset your browser either to notify you when you have received a cookie or refuse to accept cookies. However, if you refuse to accept cookies, you may not be able to use certain features on our websites.

Online Communications – In order to provide you with a product, service or information, you may voluntarily submit personal information to us for purposes such as submitting a franchise application, obtaining information, corresponding with us, and participating in contests and surveys. We may combine and store personal information about your use of our websites and the online information you have provided with certain other online and offline information we may have collected.

E-Mail Communications – Occasionally, Sutton Fair may send you e-mail communications with information that may be useful to you, including information about the products and services of Sutton Fair, its affiliates and other third parties with whom we have a commercial relationship. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from Sutton Fair. However, if you are a franchisee, customer, supplier or otherwise have a commercial relationship with Sutton Fair, to ensure that you receive important information, you agree that we may send you non-marketing related information when necessary.

Links – Our websites may contain links to other websites which are provided to you as a convenience only. You are advised that other third party websites may have different privacy practices than Sutton Fair, and Sutton Fair has no responsibility for such third party websites.

6. Changes to this Privacy Policy

Sutton Fair reserves the right to modify or supplement this Privacy Policy at any time. If we make any change to this Privacy Policy, we will post such changes on our website and will be available upon request to the Sutton Fair Chief Privacy Officer. However, Sutton Fair will seek an individual’s consent if it seeks to collect, use or disclose his or her personal information for purposes other than those to which the individual has consented unless otherwise required or permitted by law.

Changes to our Privacy Policy will be noted here so that you can be fully informed about our privacy policies and practices.

Date last revised: March, 2012

Description of Revision: New draft

7. Further Information

For more information on Sutton Fair’s privacy practices or if you have questions or concerns about your privacy, you can contact us through the Sutton Fair website at www.Suttonfair.com or by phoning the office at (905) 722-3165. Our office representatives will assist you in resolving the situation. If you still have unsolved concerns with respect to the treatment of your personal information by Sutton Fair, you may address these concerns to the Chief Privacy Officer at:

Sutton Fair Chief Privacy Officer

P.O. Box 460, Sutton, ON, L0E 1R0 Canada

info@Suttonfair.com