BLU’S WOMEN’S WEAR PRIVACY POLICY

BLU’S WOMEN’S WEAR is committed to protecting your privacy and maintaining the integrity of any identifiable information we collect about you (“Personal Information”). Keeping our customers’ Personal Information and affairs in strict confidence is a cornerstone of BLU’S WOMEN’S WEAR’S business practices.

The purpose of this Privacy Policy is to outline the steps we take to keep your Personal Information confidential, to inform you about how and why we collect Personal Information and to provide you with Blu’s Women’s Wear contact information should you have questions or concerns about our online Personal Information protection practices.

Our policies and procedures, which we practise in order to protect your privacy, are in place across BLU’S WOMEN’S WEAR. In the following pages we describe these policies and procedures and how we put them into practice so that you have control over how we collect, use and disclose your information.

Protecting your Privacy Means:

• We keep your information and the business you do with us in strict confidence
• your information is not sold
• you have control over how we obtain, use, and give out information about you
• you have access to the information we have about you
• we respect your privacy when we market our products and services.

A. The Collection of Personal Information

1. Why does Blu’s Women’s Wear collect your Personal Information?

Blu’s Women’s Wear collects Personal Information and uses it in order to:

• Understand your needs and eligibility for products and services;
• Recommend particular products and services to meet your needs;
• Provide ongoing service;
• Improve service delivery;
• Answer your questions, queries or complaints;
• Review and evaluate job applications filed online through www.blus.com;
• Provide you with information (e.g. through direct mail and/ or e-newsletters);
• Verify some of the information you give us;
• Establish your identification;
• Protect you and us from error and fraud;
• Where required, co-operate with law enforcement authorities, to comply with a court order or to prevent a breach of any applicable law.

Certain information, such as a driver’s licence, although convenient for identification, is voluntary. It is up to you whether you want to provide this or other suitable identification, subject to any legal requirements.

We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

We may review and analyze your use of products and services, to help us serve you better, and to bring other products and services to your attention, which we feel, will be of benefit to you. We also collect and analyze information from other sources for the same purposes.

Please note that aggregated information, where the identity of a specific individual cannot be determined, is not Personal Information. Blu’s Women’s Wear reserves the right to use aggregated information in any manner it thinks appropriate. For example, Blu’s Women’s Wear may also prepare aggregated user statistics or information summaries to describe our services and their popularity to our suppliers and prospective advertisers and for other lawful purposes. Any aggregated user statistics and information will not contain any Personal Information.

2. What type of Personal Information does Blu’s Women’s Wear collect?

Blu’s Women’s Wear collects various types of Personal Information. For example, during the registration process with us, you will be asked to provide certain contact information (such as your name and e-mail address) and may be asked, depending upon which services you subscribe to or features you make use of, to provide additional contact information and general information about yourself (such as address, postal code, telephone numbers, age group, personal interests, personal preferences, product preferences and, with respect to the online job application feature specifically, work experience, formal education, training, certifications, skill set, abilities and other work related information).

3. How Does Blu’s Women’s Wear Collect Personal Information?

Blu’s Women’s Wear will only collect Personal Information that you have voluntarily provided to us. Blu’s Women’s Wear will not collect any Personal Information about you without telling you ahead of time (either through this Privacy Policy or at the time we are requesting Personal Information from you) why and how Personal Information is being collected and how such Personal Information will be used or disclosed (if applicable).

Blu’s Women’s Wear may obtain and collect your Personal Information through a variety of means (e.g. you provide it verbally or in writing (including via electronic media)). The following are examples of how we may do so:

• The completion of manual or electronic forms. Forms you may be asked to complete include:
  • Blu’s Personal Account Applications: As a service to eligible customers, Blu’s Women’s Wear may extend personal account services to eligible applicants.
  • Online Job Applications: Users of our website may submit job applications online. Users who use such a service will be asked to provide a cover letter, a resume and provide particulars as to their work experience, proficiencies and work preferences.
• Contests and Promotional Events: From time-to-time Blu’s Women’s Wear offers various promotions and contests. When participating in these promotions and contests, you may be asked to provide us with certain Personal Information. You are free at any time to have your Personal Information removed from our database or to have your name removed from our marketing distribution list on a go-forward basis.
• Web site traffic information, which is monitored and analyzed in order to determine which features and services are popular and useful to visitors, so that we can improve our services.

Blu’s Women’s Wear may also prepare aggregated user statistics or information summaries to describe our services and their popularity to our suppliers and prospective advertisers and for other lawful purposes. Any aggregated user statistics and information will not contain any Personal Information.

4. How Blu’s Women’s Wear May Disclose Personal Information

Blu’s Women’s Wear does not sell to third parties any Personal Information we collect. Blu’s Women’s Wear may transfer some information we collect to preferred service providers and suppliers who help us provide personalized services and advertising to you.

B. Your Consent

1. Your Information is Obtained or Used Only With Your Consent

We obtain your consent before we:

• offer you other products and services
• send you information about products and services by means of direct marketing
• provided it is legally permitted, share your information in confidence within BLU’S WOMEN’S WEAR
• obtain, use or disclose to other persons, information about you unless we are obliged to do so by law or to protect our interests
• use your information in any way we did not tell you about previously.

2. Your Consent Can Be Express Or Implied

Express consent can be verbal or written.

Your implied consent when we can reasonably conclude that you’ve given consent by some action you have taken, or when you decide not to take action. By choosing to provide us with your Personal Information you are consenting to its use in accordance with the principles outlined in this Privacy Policy and as may be further outlined at the time of collection. For example, if we give you an opportunity to tell us you don’t want direct marketing material and you don’t tell us that you don’t want us to send it, we can conclude that you have no objection. We will rely on your implied consent to use and disclose identifying information about you, such as your name and address.

3. You May Withdraw Your Consent After You Have Given It

The protection of your Personal Information is of the utmost importance to us. If you don’t want Blu’s Women’s Wear to use Personal Information collected about you for marketing or publicity purposes, please tell us at the time the information is collected.

You can withdraw your consent any time after you have given it to us, provided there are no legal requirements to prevent this, by calling (780) 425-4544 or by sending an e-mail at edm@blus.com.

Please note, if you don’t consent to certain uses of information, or if you withdraw your consent, we may not be able to provide you with a particular product or service. If so, we will explain the situation to you to help you with your decision.

4. We Ask for Your Consent Before Sharing Information With Other People

We may share information about you within BLU’S WOMEN’S WEAR and with our leased partners, however we do not release it to anyone outside of BLU’S WOMEN’S WEAR without your consent.

There are some exceptions to the above rule. For example, we may collect, use or disclose information without your consent if we:

a) use an outside company to process information

At times we may use the expertise of an outside company to do work for us involving some of your information. When we do, we choose the company carefully and confirm that it uses security and privacy standards comparable to those of BLU’S WOMEN’S WEAR.

b) must disclose information for legal reasons

We may be compelled to release information by a court of law, or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to.

c) have to protect the interests of BLU’S WOMEN’S WEAR

In certain circumstances, BLU’S WOMEN’S WEAR may have to collect, use or release information for its protection. For example, we may do so to detect or prevent fraud.

d) use an outside company to provide you with a specific service

For example, to deliver a purchase to your home.

e) Sale or Transfer all or Part of Blu’s Women’s Wear

In some scenarios, Personal Information may be subject to transfer to another organization. This might occur, for example, in contemplation of a merger or a change of ownership of all or part of Blu’s Women’s Wear. We will do this only if the parties have entered into an agreement under which the disclosure of the information (including any Personal Information) is restricted to those purposes that relate to the business transaction and is to be used by the parties to carry out and complete the business transaction.

C. Verifying and Amending your Personal Information

1. You Can See and Verify the Accuracy of Your Information

You can check your information to verify and correct it, and to have any obsolete information removed. We will ask you to put your request in writing.

There is no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records, which we have already given you.

We will let you know in advance if there is a charge.

If you have a sensory disability, we will do our best to give you access to your personal information in any alternative format you request if we already have it in that format or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.

It may not be appropriate for us to release certain information to you. Where information will not or cannot be disclosed, we will provide you with the reasons for non-disclosure.

If we have obtained information about you from other people, upon your request, we will let you know the person we got it from.

2. You Can Find Out to Whom We Have Given Information About You

If you ask, we will let you know the names of outside companies or organizations we have given information to. This may include information given to outside companies we have used to do work for us, such as mailing houses.

3. We Respond to Your Request Promptly

We will deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we’ll tell you why, subject to any legal restrictions and we will notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.

4. We Revise Your Information From Other Sources

Whenever possible, we will revise your information with any information obtained from any source.
If a third party has given us information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information.

5. We Protect Other People’s Privacy When We Make Information Available to You

There may be files that include information about you and other customers, or that have information confidential to BLU’S WOMEN’S WEAR or are the property of BLU’S WOMEN’S WEAR. Because we must protect everyone’s confidentiality and legal rights, we cannot make these files available to persons outside of BLU’S WOMEN’S WEAR. However, we will make available to you any factual information about you contained in such files.

D. Security

Blu’s Women’s Wear endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.

Blu’s Women’s Wear keeps the Personal Information we collect about you strictly confidential. Only authorized personnel have access to this Personal Information. Blu’s Women’s Wear and leased partners personnel who have access to Personal Information receive special training regarding privacy protection.

If any employee of Blu’s Women’s Wear or its leased partners misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information - provided for the purpose of providing services to or for Blu’s Women’s Wear - this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Blu’s Women’s Wear and that individual or organization.

Our computer security specialists build security into all our computer systems. This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitted, for example, between our data processing centers, our stores and corporate offices.

Blu’s Women’s Wear has taken steps to protect the confidentiality of your on-line viewing. When you visit www.blus.com, our website is able to recognize your Internet service provider, but does not identify you as an individual.

Blu’s Women’s Wear has also taken steps to ensure that any service providers and suppliers with whom we share any information are committed to maintaining the privacy of your Personal Information, as outlined in this Privacy Policy, and refraining from making any independent or unauthorized use of such Personal Information.

We note that Blu’s Women’s Wear enables its customers in certain stores to connect to www.blus.com through our Internet service provider. We cannot guarantee that any information that you may choose to disclose via the Internet will not be intercepted by third parties. We assume no responsibility for Personal Information disclosed through the Internet, which is intercepted, diverted or otherwise accessed.

E. Retention and Disposal

We keep your information only as long as we need it for the products and services you’re using, to offer you products and services when you are a customer and for a reasonable time thereafter, or to meet any legal requirements. We have retention standards, which meet these requirements. We destroy your information when it is no longer needed, or we remove your name from the information.

F. How We Ensure Compliance With our Privacy Policy

1. We Are Committed to Upholding the BLU’S WOMEN’S WEAR Privacy Policies

If you have any questions or complaints about our privacy policies, or about how we are living up to them, let us know right away. Our privacy policies can be found on the Blu’s Women’s Wear website at www. blus.com, by writing the Office of the Chief Privacy Officer and requesting a copy or by visiting any store.

2. We Monitor Our Compliance With the BLU’S WOMEN’S WEAR Privacy Policies

We have procedures in place to assist our employees and leased employees in the practice of the BLU’S WOMEN’S WEAR privacy policies. Our practices will be reviewed on a regular basis and their findings will be reported to the Privacy Committee.

G. Resolving Your Concerns

1. Resolving Your Concerns Is Important to Us

BLU’S WOMEN’S WEAR is committed to treating you with the greatest respect and consideration, and providing the highest level of service. Please let us know about your questions or concerns and we will do our best to help you. Whatever the circumstances, resolving the problem for you is our primary concern.

2. How to Resolve Concerns and Complaints at BLU’S WOMEN’S WEAR

a) Talk to Us

In most cases speaking with a Service Representative in any of our stores will lead to resolution of your concern.

b) The BLU’S WOMEN’S WEAR Chief Privacy Officer Acts On Your Behalf

If your concerns have not been resolved to your satisfaction, feel free to write to The Chief Privacy Officer for Blu’s Women’s Wear as follows:

BLU’S WOMEN’S WEAR Chief Privacy Officer
Second Floor Manulife Place
10180 101 Street
Edmonton Alberta T5J 3S4

The BLU’S WOMEN’S WEAR Chief Privacy Officer’s office will acknowledge your complaint. Then, providing legal action has not been taken on the matter, the BLU’S WOMEN’S WEAR Chief Privacy Officer immediately goes to work. You will receive a response within thirty (30) working days.

c) If You Are Not Satisfied With the Decision of BLU’S WOMEN’S WEAR’S Chief Privacy Officer Regarding Your Complaint

Should you not be able to accept the conclusion of BLU’S WOMEN’S WEAR’S Chief Privacy Officer, you can ask how your complaint can be further escalated.