Providing peace of mind

PRIVACY POLICY

Locksmith Gals

Introduction

1. This Privacy Policy Statement (the “Privacy Policy”)      contains the policies, procedures and practices to be followed by Locksmith Gals and any of its present or future subsidiaries (the “Company”)      pertaining to the collection, use and disclosure of personal information      (the “Personal Information”) of an identifiable person (the “Individual”)      that has a present, future or former relationship with the Company.
2. The Company recognizes the confidential nature of the      Personal Information in its care and is accountable for the compliance of      itself and its directors, officers, management, customers, clients,      employees, representatives and agents including consultants and      independent contractors (the “Staff”) in protecting this Personal      Information.
3. For the purpose of this Privacy Policy, the term      “Personal Information” has the meaning of any information or collection of      information in any form, whether oral, electronic or written that pertains      to the Individual excluding information that is publicly available in its      entirety. Personal Information will also include any publicly available      information that is combined with non-publicly available information.
4. Personal Information includes but is not limited to      name, home address, home phone number, home email address, identity      verification information, Social Security Number, physical description,      age, gender, salary, education, professional designation, personal hobbies      and activities, notarized documents, assessments, audits, project or      program material, medical history, employment history, credit history,      contents of resume, references, interview notes, performance review notes      and emergency contact information.
5. Personal Information will not include the Individual's      business title, and business address and contact information when used or      disclosed for the purposes of reasonable business communication.
6. The Company will implement policies and procedures that      give effect to this Privacy Policy including procedures to protect and      secure Personal Information, procedures to receive, investigate and      resolve complaints, procedures to ensure adequate training of the Staff      concerning the Company's privacy policies, and procedures to distribute      new and current information pertaining to the Company's Privacy Policy.
7. Corporate Privacy Policy
8. The Company and the Staff will at all times respect the      confidentiality of the Personal Information placed in its care. The Company      will endeavor to ensure that the policies affecting the collection,      storage and disclosure of Personal Information reflect the confidential      nature of the information.
9. The Company will comply with all applicable privacy      legislation and regulations in force now and in the future related to      protecting the confidentiality of Personal Information.
10. Purposes for which Personal Information is Collected
11. Personal Information will be collected, used and      disclosed for purposes pertaining to the entity's relationship with the      Company, including but not limited to the administration, reviews, the      administration of payroll, processing of claims, and for the purpose of      complying with all applicable regulations, laws, and legislation.
12. The purposes for collecting Personal Information will      be documented by the Company. Personal Information will only be used for      the stated purpose or purposes for which it was originally collected. The      purposes for which Personal Information is being collected will be      identified orally or in writing to the Individual before it is collected.      The person collecting the information will be able to explain the purpose      at the time that the information is collected.
13. The Company may use Personal Information for a purpose      other than the originally stated purpose where the new purpose is required      by law or where the Company has obtained consent in writing from the      affected Individual for each new purpose.
14. Knowledge and Consent
15. Knowledge and consent is required from the affected      Individual for the collection, use and disclosure of all Personal      Information subject to exceptions noted elsewhere in the Privacy Policy      statement.
16. Consent will not be obtained through deception or      misrepresentation.
17. Any use or disclosure of Personal Information will be within      the reasonable expectations of the Individual or Entity.
18. Subject to legal and contractual obligations, an      Individual may withdraw their consent on reasonable notice.
19. Legislation and Regulation
20. Where the Company has Individuals living and working in      different jurisdictions the specific rights and obligations of Individuals      or Entities may vary between jurisdictions.
21. The Company is subject to the privacy legislation in      all jurisdictions in which the Company operates. If any term, covenant,      condition or provision of this Privacy Policy is held by a court of      competent jurisdiction to be invalid, void or unenforceable, it is the      intent of this Privacy Policy that the scope of the rights and obligations      of the Privacy Policy be reduced only for the affected jurisdiction and      only to the extent deemed necessary under the laws of the local      jurisdiction to render the provision reasonable and enforceable and the      remainder of the provisions of the Privacy Policy statement will in no way      be affected, impaired or invalidated as a result.
22. Where this Privacy Policy provides greater rights and      protections to the Individual or entity than the available governing law,      the terms of this Privacy Policy will prevail wherever allowed by law.
23. Scope and Application
24. The rights and obligations described in this Privacy      Policy will apply to all Individuals. The Company and the Staff must      comply with the policies, procedures and practices described in the      Privacy Policy.
25. Collection of Personal Information
26. The type and amount of Personal Information collected      by the Company will be limited to the minimum necessary to accomplish      reasonable business purposes. Personal Information will not be collected      maliciously, indiscriminately or without a reasonable business purpose.
27. Personal Information will be collected using fair and      lawful means.
28. Access by Authorized Company Representatives
29. All Personal Information will be released internally      only on a need-to-know basis. In the course of normal and reasonable      business practices it is the policy of the Company to grant designated      Company representatives’ access to Personal Information files. This access      will not exceed that necessary to accomplish the specific business      function of the Company representative nor the purpose for which the      information was originally collected.
30. Accuracy of Personal Information
31. The Company will endeavor to ensure that all Personal      Information collected is accurate and validated using reasonable business      practices and procedures. The Company is also committed to ensuring that      the Personal Information remains accurate for the purpose for which it was      collected.
32. Rights of Access and Correction
33. The Company will make reasonable efforts to ensure that      Personal Information is at all times complete and accurate for its stated      purpose.
34. An Individual may apply for access to their Personal      Information by submitting a request in writing along with adequate proof      of identity to an authorized personnel officer. Where the application is      made in person the requirement for proof of identity will be at the      discretion of the personnel officer. The Individual will be provided with      a copy of all available information that is not subject to restriction as      described in this Privacy Policy. All Personal Information and Medical      Information will be provided at no cost or at a minimal cost that is not      prohibitive.
35. The Company will also provide a specific summary of how      the Personal Information has been used and to whom it has been disclosed.      Where a detailed account of disclosure is not available, the Company will      provide a list of organizations to which the Personal Information may have      been disclosed.
36. The Personal Information disclosed to an Individual or      entity must be in a form that is reasonable and understandable. Where the      meaning of information is not clear then translations and explanations      will be provided without additional cost.
37. Where an Individual suspects that an error exists in      their Personal Information, the Individual or Entity may submit a request      in writing for correction. This request should include any relevant      information substantiating the error and should describe the correction to      be made. The Company will make all reasonable efforts to address any      request for correction.
38. Where the Individual or Entity successfully demonstrates      an error in their Personal Information the Company will make appropriate      corrections. Any modifications, additions or deletions to the Individual's      Personal Information will be made only by an authorized personnel officer.
39. Where a request for correction is not successful, the      details and substantiating evidence of the request will be recorded and      retained by the Company.
40. The Company will endeavor to respond promptly to any      reasonable request for disclosure and correction made by an Individual or      entity to ensure the continued accuracy of Personal Information.
41. In some instances the Company may be required to limit      access to Personal Information because of statutory or regulatory      requirements. In all instances however the Company will make all reasonable      efforts to comply with the Individual's or Entity's request for access and      correction to the extent of what is allowed by statute or regulation.
42. The Company may refuse access to portions of the      Personal Information of an Individual or Entity where it is found to      contain Personal Information pertaining to another Individual or Entity.
43. Use and Disclosure of Personal Information
44. The Company and the Staff will keep confidential all      Personal Information in its control except where one or more of the following      conditions apply:
    
     
    1. where the Individual or Entity who is the subject of       disclosure has provided written consent;
    2. where the disclosure is in accord with the purposes       for which the Personal Information was originally collected;
    3. where the disclosure is for the purpose of providing       details to third parties and where the Personal Information disclosed is       limited to information considered reasonably necessary for the purpose of       providing a service;
    4. where the Company is permitted or required to do so by       applicable legislation or regulation;
    5. where the disclosure is directed to health benefit       providers and where the purpose of the disclosure is in accord with the       purposes for which the Personal Information was originally collected;
    6. where the disclosure is required by authorized       government representatives who are acting to enforce any federal or state       law or carrying out an investigation relating to the enforcement of any       federal or state law or gathering information for the purpose of       enforcing any federal or state law;
    7. where the Company is required to comply with valid       court orders, warrants or subpoenas or other valid legal processes and
    8. in an emergency to protect the physical safety of any       person or group of persons.
45. Ownership of Personal Information
46. All Personal Information collected by the Company in      compliance with this Privacy Policy are business records of the 

Retention and Disposal of Personal Information

Any Personal Information collected by the Company will be retained by the Company during the period of contract duration only as long as the Personal Information is required to serve its original purpose or as directed by applicable legislation or regulation.

Personal Information that is no longer needed for its stated purpose will be destroyed, erased or made anonymous.

The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, will ensure the complete destruction of Personal Information so that there will be no risk of subsequent unauthorized disclosure of Personal Information.

Deceased Individuals

The rights and protections of the Company's Privacy Policies will extend to deceased Individuals or dissolved entities.

Security

The Company will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information for every Individual and entity is protected against any form of unauthorized use including but not limited to accidental or malicious disclosure, unauthorized access, unauthorized modification, unauthorized duplication or theft.

Methods of security will include but not be limited to the following:

1. physical security including locked filing cabinets and       secure-access offices;
2. organizational security including security clearances       and access limited on a “need-to-know” basis and
3. technological security including passwords and       encryption.
4. The Company will educate and inform all Staff regarding      the Privacy Policy and related procedures and on the importance of      confidentiality of Personal Information and will monitor compliance with      the Privacy Policy and may observe and investigate the information      management practices of all Staff having care of Personal Information.

Knowledge of Unauthorized Disclosure

Responsibility for the security of Personal Information is a responsibility that the Company holds in very serious regard. Any Staff having knowledge of an impending unauthorized disclosure, whether intentional or unintentional, and who fail to act to prevent the unauthorized breach will be subject to sanction as described in the Enforcement section of this document including the immediate dismissal of the offending Staff.

Enforcement

All Staff having care over Personal Information must comply with the policies, procedures and practices described in the Privacy Policy. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, including but not limited to the unauthorized disclosure of Personal Information is grounds for disciplinary action up to and including the immediate dismissal of any and all responsible Staff. Any breach of any term or condition of this Privacy Policy, whether intentional or unintentional, is grounds for dismissal with cause.

Compliance with Privacy Policy

The Company will have a procedure that will allow Individuals or Entities to challenge the Company's compliance with this Privacy Policy. The Company will also have procedures to promptly respond to Privacy Policy compliance challenges.

The Company will make all reasonable efforts to investigate and respond to compliance challenges relating to this Privacy Policy. Where a challenge is well founded the Company will take action to correct any outstanding problems up to and including amending the Privacy Policy and related procedures.

Arbitration

In the event a dispute arises out of or in connection with this Privacy Policy, the parties will first attempt to resolve the dispute through friendly consultation.

If the dispute is not resolved within a reasonable period then any or all outstanding issues may be submitted to final and binding arbitration in accordance with the laws of the State of Ohio. The arbitrator's award will be final, and judgment may be entered upon it by any court having jurisdiction within the State of Ohio