eCASA VITTORIA LIMITED ("eCasa") - Privacy Policy

In recognition of the sensitivity of personal information, eCasa has developed this privacy policy with respect to the collection, use, and/or disclosure of personal information. eCasa recognizes that it is necessary to develop a set of policies together with procedures for implementing eCasa's obligations with respect to the management of personal information, including those regarding the use of personal information by a third party engaged by eCasa in the execution of their obligations on behalf of eCasa.

eCasa takes reasonable steps to protect information from client, including personal information from unauthorized use, and recognizes that it is not possible to ensure that an internet transactions security may not be comprised.

The objective of the policies and procedures set out herein are to give effect to the principles, including:

1. implementing procedures to protect personal information;
2. establishing procedures to receive and respond to complaints and inquiries;
3. training staff and communicating to staff information about eCasa's policies and practices; and
4. developing information to explain eCasa's policies and procedures.

Accordingly, eCasa implements the following policies and related procedures:

1. Policy 1 - Accountability

We together with our employees, agents and representatives, are responsible for personal information under our control, and hereby designate our Privacy Officer as being accountable for eCasa's compliance with the following policies:

1. Accountability for eCasa's compliance with the policies rests with the Privacy Officer, while the responsibility for the day-to-day collection and processing of personal information in accordance with these policies and procedures shall be that of the "Office Manager".
2. Upon request, the Privacy Officer shall be identified as the individual within eCasa that is responsible for overseeing eCasa's compliance with the policies and procedures set out herein, which the policies shall be available upon request.
3. The Privacy Officer recognizes and acknowledges that they are responsible on an on-going basis for personal information in our possession or custody, including information that has been transferred to a third party for processing. The Privacy Officer shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

2. Policy 2 ? Identifying Purposes

1. Personal Information shall only be used, collected and disclosed by eCasa, including its agents, employees and third parties, with prior consent of the individual in question and shall be only used, collected, retained and disclosed for the purpose of (collectively the "Purposes"):
1. providing services specifically to process orders for the purchase of products;
2. complying with applicable laws;
3. providing affiliates, employees, agents, third parties and representatives with information, in the course of those parties conducting or performing services or functions for us in conjunction with our services to clients, where such affiliates, employees, agents, third parties and representatives are contractually bound to maintain the standards mandated under applicable laws;
4. participating in legal proceedings against any party, including any alternative dispute resolution process, on the understanding that personal information to the extent it can be maintained confidentially will be so maintained;
5. complying with statutory and common law disclosure requirements, including those outlined in Canadian law;
6. potentially or actually selling, merging or amalgamating eCasa, provided that reasonable precautions are taken to ensure the confidentiality of personal information, so that such information cannot be revealed by a prospective purchaser or merger / amalgamation partner;
7. to monitor the use of the services provided by eCasa;
8. providing our clients with information regarding services products, sales, coupons, offers and updates which may be of interest to our clients; and/or
9. fulfilling orders from repeat clients.
2. The Privacy Officer shall provide, upon request, a copy of "eCasa's Privacy Policy" to any client or prospective client.

3. The Privacy Officer shall only collect, use, retain and disclose personal information that is required for the Purposes.

4. The Privacy Officer upon being requested or retained shall identify the Purposes for which eCasa uses, collects, retains and discloses personal information either in writing and/or orally to the person from whom the personal information is collected.
5. The Privacy Officer acknowledges that when personal information that has been collected are to be used for a purpose not previously identified, the new purpose shall be identified prior to implementation. Unless the new purpose is required by law, the appropriate form of consent of the individual are required before information can be used for the new purpose.
6. eCasa will use "Cookies" (small text files sent by her website to the user's address that are stored on the users hard drive) for the purpose of tracking information to improving performance and support services.

3) Policy 3 - Consent

1. The Privacy Officer and client, both recognize that the knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where deemed inappropriate by reason of the circumstances of the collection, use or disclosure.
2. In certain circumstances, personal information may be collected, used, or disclosed without the knowledge and consent of the individual where seeking consent may be inappropriate, impracticable or impossible.
3. Consent to use, collect, retain and disclose personal information will be sought in writing where practical and where implied consent may not be adequate. However, all clients will be made aware of the Purposes upon request.
4. eCasa affirms that it shall not, as a condition of supplying a product or service, require an individual to consent to the collection, use, retention and/or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.
5. Client consent is received on the reasonable expectation of the individual in question, that the personal information will be used for the purposes.
6. All client information, including personal information, is considered confidential and shall be treated with a view to maintaining confidentiality. In furthering this objective:
1. No employee, lawyer, agent or representative of eCasa shall discuss personal information outside of the office in such a manner that the identity of the client or parties in question will be revealed or are readily identifiable.
2. All documentation pertaining to client matters shall be maintained in secured areas, including, safes, filing cabinets, desks and offices, which shall all be locked outside of business hours. Only designated employees shall have access to such documentation on a need-to-know basis.
3. All documentation pertaining to client matters shall be kept confidential and not readily accessible to third parties not having business with eCasa.
4. All electronically sent documentation shall be sent undercover of the following notifications:
1. For e-mail or other electronic transmissions:

"This email together with any attachments is for the sole use of the intended recipient(s) and may contain confidential, personal and/or privileged information which may be protected by law. If you are not an intended recipient, please contact the sender by reply e-mail or telephone (collect) and delete this e-mail and destroy any information relating to the same including attachments in hard or soft copy. Thank you."

2. For Facsimile transmissions:

CONFIDENTIALITY NOTE

The information contained in this facsimile message is legally privileged and confidential and is intended only for the use of the individual or entity named above. Any other use, dissemination, distribution, disclosure or copy of this facsimile is strictly prohibited. If you have received this facsimile in error, please immediately notify us by telephone (collect if necessary) so that we may arrange the return of the original transmission. Thank you

5. Client information, including client images, trademarks, or personal information, shall not be used in any promotion or websites, unless written authorization of the relevant client is obtained previously.

6. eCasa may seek consent in writing, orally or by way of implied consent depending on the circumstances and the type of information collected. eCasa will try to obtain at all times, express consent to use, collect, retain and disclose personal information, especially where the personal information may be of a very sensitive nature. Consent can also be given by an authorized representative (such as a legal guardian or a person having power of attorney).

7. An individual may withdraw his/her consent at any time, subject to legal or contractual restrictions and reasonable notice. Upon withdrawing his/her consent, eCasa shall inform the individual of the implications of such withdrawal.

4) Policy 4 - Limiting Collection

1. eCasa acknowledges that the collection of personal information shall be limited to that information which is necessary for the purposes identified by eCasa. Information shall be collected by fair and lawful means.

5) Policy 5 - Limiting Use, Disclosure, and Retention

1. Personal information shall not be collected, used, retained or disclosed by eCasa for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
2. If eCasa develops a new reason for collecting, retaining or using personal information it shall inform its clients as necessary unless such requirement are mandated by law.

3. eCasa shall store personal information for a minimum of six (6) years or such other time frames as prescribed by law.

4. Where eCasa has determined that personal information are no longer required to fulfill the identified purposes it will be destroyed, erased, or made anonymous.

6) Policy 6 - Accuracy

1. eCasa shall use reasonable efforts to ensure that personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. The extent to which personal information shall be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.
2. eCasa shall only update personal information where the individual in question consents to or provides such updated information and/or are necessary to fulfill the purposes for which the information was collected.
3. Personal information that are used on an ongoing basis, including information that are disclosed to third parties, will be accurate and up-to-date, to the extent that the individual keeps eCasa up-to-date with his/her personal information.

7) Policy 7 - Safeguards

Personal information shall be reasonably protected by security safeguards appropriate to the sensitivity of the information although eCasa does not guarantee that information will remain confidential.

eCasa shall, in a manner consistent with the degree of sensitivity regarding the information in question, take reasonable steps to protect information against loss, theft, unauthorized access, disclosure, use, copying or modification.

1. All staff members of eCasa have been given a copy of this policy and procedures and have been instructed on the importance of safeguarding personal information.

8) Policy 8 - Openness

1. At eCasa:

(i) The Privacy Officer is accountable for the organization's policies and practices and all complaints or inquiries can be forwarded to her attention at info@ecasavittoria.com.

(ii) Requests for personal information held by eCasa shall be forwarded to the Privacy Officer.

2. eCasa?s policies and practices regarding information are available in hard copy and on our website.

9) Policy 9 - Individual Access

1. Upon request, an individual shall within thirty (30) days of his/her written request, but subject to legal parameters shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information at eCasa's office. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
2. Upon request, eCasa shall inform an individual whether or not the organization holds personal information about the individual within thirty (30) days of receipt of a written request. eCasa shall allow the individual access to this information.

3. eCasa shall respond to an individual's request within thirty (30) days, a reasonable time, and at minimal or no cost to the individual in accordance with our procedures hereto. The requested information shall be provided or made available in a form that is generally understandable.

4. Where an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we shall amend the information as required. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
5. When a challenge is not resolved to the satisfaction of the individual, the substance of the unresolved challenge shall be recorded by eCasa. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question.

10) Policy 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the attention of eCasa.

1. eCasa shall upon receipt of a written complaint or inquiry about policies and practices relating to the handling of personal information:
   
1. Acknowledge the request either by:
   
1. providing a hard copy of the information or policies requested within 30 days of receipt of the request; or
   
2. acknowledge the request by written letter and indicate that a response will be forwarded within thirty (30) days of eCasa's response letter.

2. A copy of all requests, concerns or inquiries regarding information management, policies and procedures or individual information shall be logged in the Information Request Log by the Privacy Officer and a copy shall be provided to eCasa for her review.
3. The Privacy Officer shall review the inquiry, collate materials relevant to the complaint, and prepare a draft response to the Privacy Officer within fourteen (14) days of receiving request.
4. Upon review, the Privacy Officer shall revise and finalize the response and send it to party requesting response.
5. If the ability to answer an inquiry by eCasa are anticipated to be delayed beyond twenty-one 21) days from the receipt of the request, eCasa shall advise the requestor in writing (the "Extension Letter"), of the delay and that the requestor shall receive a further response in thirty (30) days from the date of the Extension Letter.