Environmental Systems Corporation (“ESC”) designs, builds, services and maintains commercial industrial HVAC systems, Cleanrooms and close tolerance environments. We are sensitive to the nature of the information that you provide to us and the information that we may be exposed to in the course of providing those services. We are diligent with respect to the protection of that information. ESC is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services that we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. It includes information that relates to personal characteristics, health, history, activities and views. Personal information does not include business information, which is not protected by current privacy legislation.

PRIMARY PURPOSES
Generally, the type of information that we collect from our customers is more businessrelated. Any personal information that you do give us, however, is kept strictly confidential and is protected in accordance with the standards set out in the Personal Information Protection and Electronic Documents Act (PIPEDA). Information about customers is collected, used and disclosed for the primary purposes of providing our services to that customer, contacting the customer and invoicing and collecting from the customer for services rendered. Upon default in payment, we may utilize the personal information provided in order to exercise our legal rights as creditors. Contract staff that we hire may also provide us with personal information which is collected primarily in order to communicate on
work-related issues and in order to contact them when they are not in the office.

SECONDARY PURPOSES
Like many organizations, we may also collect, use and disclose personal information for purposes related to or secondary to our primary purposes. Some examples might be to comply with regulatory requirements or if required, to disclose information by law or in an emergency situation. We may also access information in order to ensure high quality services (i.e.) assessing the performance of our employees or to market our services to potential customers. Customers may have questions about the services that we have provided after their file has been closed. We may from time to time retain the services of consultants or contractors who may have limited access to personal information that we hold. These consultants or contractors may include computer consultants, office security and maintenance advisors, bookkeepers, accountants, temporary workers, cleaners, etc. We restrict their access to any personal information that we hold as much as is reasonably possible. We also have their assurance that they will follow appropriate privacy principles. We do not sell information to other organizations.

PROTECTION OF PERSONAL INFORMATION
Our relationship with our customers is based upon trust and confidence. We endeavour at all times to protect the personal information that we collect by, first of all, collecting only relevant and necessary information. We then store that information in secure offices that are alarmed, restricting access to the information to only those individuals who require it using security clearances. We destroy unnecessary documentation and documentation that becomes obsolete (usually five to seven years after a customer has had no further contact with us) by shredding it. We delete unneeded computer files and our computers are password protected and have up-to-date anti-virus software. Our staff is made aware of our commitment to your privacy and our policies in this regard.

CONFIDENTIALITY
In the course of providing the above services, we will not generally be required to access personal and/or confidential information that our customers hold about others, however, our employees may be exposed to such information during the installation process, for example. In this case, we undertake to use our best efforts to safeguard the personal and/or confidential information held in all mediums by our customers.
AUTHORITY
When you retain our services and provide us with personal information, your consent to the use of that information in order to supply those services will be implied. If you disclose personal information to us about others, it is your responsibility to ensure that you have consent to do so. When you provide your consent to the collection, use and disclosure of your personal information, it is subject to the provisions of this Privacy Policy.
ACCESS TO YOUR PERSONAL INFORMATION
Our customers have the right to review their file in the presence of our Privacy Officer and request that any incorrect information be corrected. The Privacy Officer should be contacted to obtain further particulars on the process, including the costs involved.
STILL HAVE QUESTIONS?
Please feel free to email our Privacy Officer or send correspondence to:
Vernon Solomon
Environmental Systems Corporation
PO Box 160, Oro, Ontario, L0L 2X0
vern@e-s-c.ca
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of Ontario privacy legislation. The Commissioner also acts as an ombudsman for privacy disputes.