Michael Gibson Gallery Commitment to Privacy
Protecting your privacy and the confidentiality of your personal information has always been an important aspect of Michael Gibson Gallery's operations. As a gallery, the collection and use of customers' personal information is fundamental to our day-to-day business operations.

We strive to provide you with the best customer service. To us, that includes treating your personal information fairly and with respect. Each Michael Gibson Gallery employee and representative must abide by our commitment to privacy in the handling of personal information. Michael Gibson Gallery is also concerned about the personal information of its employees and representatives.

Applicability of Michael Gibson Gallery's Privacy Code
Michael Gibson Gallery's Privacy Code informs you of our commitment to, and policy on, privacy. It tells you the ways we ensure that your privacy and the confidentiality of your personal information are protected.

In this Code, "we", "us" and "our" means Michael Gibson Gallery. "You" and "your" means the individual who is a customer or potential customer of Michael Gibson Gallery. In other words, our Privacy Code applies to protect the personal information, in our possession and control.

Our Web sites may contain links to other Web sites that are provided and maintained exclusively by third parties. Web sites provided and maintained by third parties are not subject to this Privacy Code. Please review the privacy policies on those Web sites to determine their information handling practices.

What is Personal Information?
Personal information is any piece of information, either factual or subjective, about an identifiable individual. Personal information does not include the name, title, business address, or telephone number of an employee of an organization.

The 10 Principles of Privacy
Our Privacy Code consists of the following ten key principles:
Accountability
At Michael Gibson Gallery, we take our commitment to securing your privacy very seriously. Each employee and representative of Michael Gibson Gallery is responsible for the personal information under his or her control. Our employees are informed about the importance of privacy and receive information periodically to update them about our Privacy Code and related policies.

In addition to establishing this Privacy Code, we have appointed Michael Gibson - as Michael Gibson Gallery's Chief Privacy Officer. Mr. Gibson is responsible for analyzing all personal information handling practices at Michael Gibson Gallery, and ensuring that our privacy policy is up-to-date and in force at all times.

Identifying Purposes: Why We Collect Information
Whenever we collect information about you, we will explain how we intend to use it, either at that time or earlier. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose.

The information we ask for depends on which services you require from Michael Gibson Gallery. For example, personal information is required to subscribe to Michael Gibson Gallery Newsletter.

Consent
We seek and confirm your consent to use your personal information at the time of collection or in advance. We will endeavour to employ clear, understandable language when we obtain your consent.

Consent may be expressed in writing or implied, and in some cases, you may provide it verbally, electronically or through your authorized representative, such as your lawyer. Implied consent may be found where you choose to use a Michael Gibson Gallery product or service, such as our Web site.

All electronic communication ("e-mail") with you that is not essential to participation in a Michael Gibson Gallery program includes a straightforward "opt-out" feature that allows you to request that we cease e-mail communication with you. Not responding to our offer to have your name removed from the e-mail list is another form of implied consent.

Before deciding what form of consent is appropriate, Michael Gibson Gallery will consider the type of personal information it needs, the reason for its use and the type of customer contact that is involved.

The choice to provide us with personal information is always yours. Upon request, we will explain your options of refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your written choices. However, your decision to withhold particular details may limit the services we are able to offer.

Limiting Collection
Information is not collected by Michael Gibson Gallery without a specific, limited requirement. We collect information by fair and lawful means.

When you visit our Web sites, information is not collected that could identify you personally unless you choose to provide it. You are welcome to browse these sites at any time anonymously and privately, without revealing any personal information about yourself.

Limiting Use, Disclosure and Retention
The information we request from you is used for the purposes defined. We will seek your consent before using the information for purposes beyond the scope of your original consent.

Under no circumstances do we sell customer lists or other personal information to third parties. Michael Gibson Gallery's policy is to use personal information only to forward communications necessary or appropriate to the fulfillment of our obligations as a publisher, which may include subscription information.

There are some unavoidable types of disclosure of your personal information which may occur occasionally as part of Michael Gibson Gallery fulfilling its routine obligations and/or conducting its business in the ordinary course. This includes, for example, partners, consultants and suppliers to Michael Gibson Gallery (also known collectively as "service providers"), assuming that they are abiding by Michael Gibson Gallery's Privacy Code and only to the extent necessary to allow them to provide business services or support to Michael Gibson Gallery, including technology, banking, financial, auditing, accounting, legal and insurance services.

We will retain your information only for the time it is required for the purposes we describe. Once your personal information is no longer required, it will be destroyed or made anonymous.

Accuracy
All decisions involving personal information should be based on accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on individuals to disclose all material information and to inform us of any relevant changes.

We will make reasonable efforts to keep your information accurate and up-to-date, based upon satisfactory evidence provided by you and to the extent updated information is relevant to the purpose for which it was originally collected.

We encourage our customers to review and confirm the accuracy of information provided. If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or Internet), and we will make the appropriate corrections immediately, upon receipt of appropriate evidence.

Safeguards: Protecting Your Information
We will protect your information with appropriate safeguards and security measures, such as Michael Gibson Gallery's computer usage and security policies. We audit our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate.

Michael Gibson Gallery maintains personal information in a combination of paper and electronic files. Recent paper records concerning individuals' personal information are stored in files kept onsite at our Brantford head office. Older records containing individuals' personal information may be stored at an offsite storage facility.

Access to personal information will be authorized only for Michael Gibson Gallery's employees, representatives and service providers who require access in the performance of their duties, to any person granted access by the individual through the consent process and to those otherwise authorized by law.

When providing information to service providers acting on our behalf, we will require such organizations or individuals to abide by our Privacy Code. We will give them only the information necessary to perform the services for which they are engaged, and will require that they not store, analyze or use that information for purposes other than to carry out those services.

Michael Gibson Gallery's computer systems, including portions of our Web sites, are password-secured and constructed in such a way that only authorized individuals can access secure systems and databases.

If you send us an e-mail message that includes personal information (such as your name included in the "address"), we will use that information to respond to your inquiry. Please remember that e-mail is not necessarily secure against interception. If your communication is very sensitive, or includes information such as your bank account or credit card number, you should not send it electronically unless the e-mail is encrypted or your browser indicates that the access to our Web site is secure.


Openness: Keeping You Informed
Michael Gibson Gallery has prepared this plain-language Privacy Code to keep you informed.

If you have any additional questions or concerns about privacy, we invite you to contact us by phone, fax, mail, e-mail, or our Web sites, and we will address your concerns to the best of our ability.

Providing Individual Access
We will give you access to the information we retain about you within a reasonable time, with a written request, satisfactory identification and proof of entitlement. You also have the right to know:
- how we collected your personal information;
- how we are using it; and
- to whom it may have been disclosed, except where such disclosure was to a governmental body or service provider to Michael Gibson Gallery for routine purposes. This would include, for example, designers, technicians, acting for Michael Gibson Gallery.

If you find any errors in this information, we urge you to contact us as soon as possible (by phone, fax, mail, e-mail, or our Web sites), and we will make the appropriate corrections immediately, based on the receipt of satisfactory evidence.

In some cases we may not provide access to personal information within our possession or control. This may occur when:
- providing access would be likely to reveal personal information about a third party or could pose a threat to the security of the third party, and the information cannot be segregated;
- disclosure would reveal confidential commercial information of Michael Gibson Gallery;
- it would be too costly, in our determination, to retrieve it;
- the personal information is protected by solicitor-client privilege; or
- the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons, such as a non-disclosure agreement.

If we deny your individual request for access to your personal information, we will advise you in writing of the reason for the refusal and you may then challenge our decision.

Providing Recourse: Respecting and Responding to Your Privacy Concerns
Michael Gibson Gallery encourages you to contact us with any questions or concerns you might have about your privacy or our Privacy Code. We will investigate and respond to your concerns about any aspect of our handling of your information.

In most cases, an issue is resolved simply by telling us about it and discussing it.
You can reach
Michael Gibson Gallery, 157 Carling St. London, Ontario N6A 1H5 Tel. (519) 439-0451 , Fax (519) 439-2842
Owner: Michael Gibson
E-mail: michael@gibsongallery.com

Conclusions
Any changes to our Privacy Code and information handling practices shall be acknowledged in this Privacy Code in a timely manner. We may add, modify or remove portions of this Code when we feel it is appropriate to do so. You may determine when this Code was last updated by referring to the modification date found at the bottom of the page.

2003-7-14