3.         Accountability

We are responsible for all personal information under our control. Accountability for our compliance with this privacy policy rests with our Chief Privacy Officer; however, other individuals within FHHi may have responsibility for the day to day collection and processing of personal information. Our Chief Privacy Officer may be reached at info@fhhi.org or 1-888-403-9040.

We are responsible for personal information in our possession or custody, including information that has been transferred to third parties for processing. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their possession or control.

4.         Identifying Purposes

We will clearly identify and document the purposes for which we collect, use or disclose personal information at or before the time of collection. As part of the Site’s service, we collect, use and disclose certain personal information strictly for the following purposes:

If you do not wish FHHi to use your personal information to send such additional information, please advise us during the registration process or by sending an unsubscribe e-mail to info@fhhi.org.

The specific uses of personal information in connection with the foregoing purposes will be limited to what a reasonable person would consider appropriate in the circumstances. As we continue to develop our business, we might sell or buy business assets. In such transactions, user information generally is one of the transferred business assets. Also, in the event that we sell all or substantially all of our assets, information regarding the Site’s users will of course be one of the transferred assets.

If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document the purpose before such additional use. We will state the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.

5.         Obtaining Consent

We will collect, use and disclose personal information only with the knowledge and consent of the individual, except where inappropriate.

We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection. In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may have to seek your consent after your personal information has been collected but before our use for that purpose.

We will not, as a condition of providing you access to the Site, require you to consent to the collection, use or disclosure of personal information beyond that which is absolutely necessary.

In certain limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without your knowledge or consent. Although the following list is not exhaustive, these circumstance include: (i) personal information which is publicly available as defined by regulation; (ii) circumstances where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely fashion; (iii) to investigate a breach of an agreement or a contravention of a law; (iv) to act in respect of an emergency that threatens the life, health or security of an individual; and (v) to comply with a subpoena, warrant or court order.

You may withdraw your consent with respect to a particular use or disclosure of your personal information at any time by sending an e-mail with written instructions to our Chief Privacy Officer at the e-mail the address set out above.

6.         Limiting Collection

We will limit the amount and type of personal information collected to that which is necessary for our identified purposes and we will only collect personal information by fair and lawful means.

The Site collects the following types of personal information from our users:

If you are a Consumer, the Site collects the following additional information:

·     Details regarding the types of services you may require (i.e. the information you post with respect to your Sales Leads)

Similarly, if you are a Service Provider, the Site collects the following additional information:

·      Details regarding the services you provide and your qualifications and experience

If you are a Consumer, the Site collects personal information described above in connection with your posting of Sales Leads.  We provide that information along with your contact information to the Service Providers who purchase your Sales Leads.  By registering and posting Sales Leads on the Site, you expressly consent to being contacted by the Service Providers via telephone, e-mail or other methods specified by you during your registration so that such Service Providers may discuss your needs outlined in your Sales Leads and provide you with quotations.

In addition, the Site collects ratings, comments, feedback and testimonials from Consumers about the performance of Service Providers and rebuttals and testimonials from Service Providers. By providing such information to us, you consent to our use, publication and/or distribution of such information with no compensation to you.

The Site also collects demographic information which is not unique to you, such as your postal code or zip code, age range and gender. Responses to surveys are grouped and aggregated so users will not be personally identifiable. The aggregated information may be shared with or sold to third-party companies. By clicking the "Submit" button at the end of a survey, you authorize FHHi to include your responses in the aggregated data (such responses will not include any personally identifiable information).

7.         Limiting Use, Disclosure and Retention

We do not and will not use or disclose personal information for purposes other than those for which it is collected, except with your express consent or as required by law.  We will retain personal information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements. Our current policy is to delete or destroy all collected personal information if it is not used for a period of 3 years from the date it is first collected. For example, if you register as a Consumer and do not post a Sales Lead for a period of 3 years from the date you register, we will limit the retention of your personal information by deleting it after 3 years.

8.         Accuracy

We will use our best efforts to ensure that personal information under our control that is used on an ongoing basis, including information that we disclose to third parties in accordance with this privacy policy, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. In order to assist us in that regard, we urge you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold.

9.         Safeguards

We will protect personal information with safeguards appropriate to the sensitivity of the information. We employ appropriate safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We make our staff members and business partners aware of the importance of maintaining the confidentiality of personal information, and we will exercise appropriate care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Our methods of protection include physical measures, organization measures (for example, limiting access on a “need to know” basis), technological measures (for example, the use of passwords and encryption) and contractual measures (for example, we ensure that any third parties that store our records for us are contractually bound to adhere to our privacy policy).

10.       Openness

We will make specific information about our policies readily available, except to the extent that it is confidential commercial information.

The information we will make available will include: (i) how to gain access to your personal information; (ii) the type of personal information held by us, including a general account of its use; (iii) general information concerning our privacy policy; (iv) what personal information is made available to third parties; and (v) how to contact our Chief Privacy Officer.

11.       Access

Upon written request addressed to our Chief Privacy Officer, we will inform you of the existence, use and disclosure of your personal information and we will give you access to that personal information. You can challenge the accuracy and completeness of your personal information under our control and have it amended as appropriate.

We will respond to an individual’s written request within a reasonable time (generally within 30 days) and we will assist any individual who informs us that he or she needs assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and proceed upon payment by the individual of the cost. Requested information will be provided or made available in a form that is understandable. Where possible, we will indicate the source of the information.

If you feel that your personal information we hold is inaccurate or incomplete you are invited to advise our Chief Privacy Officer of such inaccuracies and ask that we amend the personal information. Any such request must be in writing.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.

If an individual successfully demonstrates an inaccuracy or incompleteness of his or her personal information under our control, we will amend the personal information as appropriate. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Although the following list is not exhaustive, exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.

If you visit the Site from an online banner ad, an anonymous identification number may be passed to the Site. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising campaigns.