Accountability

Vincent Associates Inc. has designated Joan Wilson as Chief Privacy Officer, accountable for compliance with applicable privacy laws.

Identifying Purposes

Vincent Associates is aware of the necessity of informing customers regarding the purposes for which their information will be collected, used and disclosed. Any such information received by Vincent Associates Inc. and maintained on behalf of specific clients is used for those clients' specific purposes only.

Consent

Vincent Associates is aware of the necessity of obtaining consent from their customers for the collection of personal information. Such consent is recorded in the customers' record within the specific client's database.

Limiting Collection

The collection of personal information by Vincent Associate on behalf of our clients is limited to that which is appropriate and reasonably necessary for the identified purpose.

Limiting Use, Disclosure and Retention

Vincent Associates does not disclose personal information for purposes other than for our clients' intended use. Such information is maintained only as long as is necessary for the individual client's purposes.

Accuracy

Vincent Associates ensures that information collected and maintained on behalf of its clients is accurate, complete and up-to-date.

Safeguards

Vincent Associates has implemented physical, organizational and technological measures to protect the personal information in its custody.

Openness

Vincent Associates is committed to making specific information about its privacy policies, practices and procedures readily available to individuals upon request.

Individual Access

Vincent Associates will provide an individual, upon request and with permission from the associated client, with access to his or her personal information in Vincent Associates' custody or control, subject to the removal of personal information about other individuals and subject to legal or contractual constraints.

Challenging Compliance

Vincent Associates is set up to respond to and investigate any complaints received.