When you sign up for the membership. [ GALLERIASM PRIVACY POLICY ] GalleriaSM and its subsidiaries and divisions (referred to collectively in this Privacy Policy as "GalleriaSM") are committed to protecting your privacy. This Privacy Policy identifies the ways we ensure that your privacy and the confidentiality of your personal information are protected within our businesses whether provided at our stores, over the Internet or on the telephone. It also outlines what personal information that GalleriaSM may collect and how we use, or restrict the use of, your personal information. [ GALLERIASM COMMITMENT TO PRIVACY ] The privacy of our customers and visitors is of great importance to the GalleriaSM. Keeping our customers' and visitors' personal information in strict confidence is a cornerstone of our business. Regardless of how the range of products and services we offer our customers expands, and the technology we use changes, we will always strive to protect your privacy. [ YOUR INFORMATION ] * What is personal information Personal information is anything that is personal about you including your name, address, telephone number, birth date and social insurance number. It could also include financial information such as your credit history. * What personal information we collect We obtain most of our information about you directly from you. The information we ask for depends on which product or service you request, and it is obtained from you in order to fulfill this request. For example, if you order something over the Internet to be delivered to your home then we will at a minimum require your name and address. If you would like financial services, you may be required to provide credit information and/or your social insurance number. Here is why we need some of the information we may ask you to provide with respect to the provision of financial services: - Birth date This helps us to identify you and to ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products and services that may be of benefit to a particular age group. - Social Insurance Number (SIN) Your SIN is required under Canadian legislation for products which earn investment income, in order to comply with Canada Customs and Revenue Agency's income reporting requirements. Providing your SIN for other financial products or any other product is optional. By providing your SIN, you are consenting to our use of your SIN to keep your information with respect to financial products separate from that of other customers with a similar name, including information we obtain with your consent through the credit approval process. - Financial information Your financial information is used to assess your eligibility for any credit product, for example, a President's Choice Financial MasterCard. * Why we collect your personal information We collect your personal information in order to serve you better and to meet your customer service expectations. Collecting your personal information assists us to recognize your relationship with the GalleriaSM, no matter when or where you contact us, or which one of our various businesses you contact. * Why we collect personal information about you from others Obtaining additional information about you from parties outside the GalleriaSM helps us assess your eligibility for certain products. For credit products, for example, we need to know your creditworthiness. For this reason, we may contact other lenders or credit bureaus to give us information on your credit history. We may also contact employers or other personal references to verify information that you have given us, as is customary when confirming creditworthiness. * Protecting your information We will protect your information with appropriate safeguards and security measures. We have thorough security standards to protect our systems against unauthorized access and use. We use the same standards to protect your personal information as we use to protect our own confidential information. We do our best to ensure that our business providers, suppliers and sponsors maintain your confidentiality and do not use your personal information for any unauthorized purpose. If we are required to provide information in response to a legal enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required to be disclosed. The GalleriaSM audits its procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate. The length of time we retain your personal information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your information is no longer needed for the purposes explained to you, we have procedures to destroy, delete or erase it, or convert it to an anonymous form. [ USE OF YOUR INFORMATION ] * Your consent We will not disclose your personal information without your consent. Your consent to disclosure can be either express or implied. - Express consent You can signify your express consent to us face-to-face, over the telephone, by e-mail, fax or other written form. In obtaining your express consent, we will identify the purpose for which your personal information is being collected and used, and under what circumstances it may be disclosed to others. - Implied consent You signify your implied consent to us by some action or inaction on your part. One action that signifies your implied consent is when you provide your personal information (except for health information) to us. By doing this you are consenting to the uses of your information as outlined in this Privacy Policy and you are consenting to the uses outlined at the time you are requested to provide the information (for example, you may be consenting to a credit check when applying for a President's Choice Bank credit card). You are also consenting to the GalleriaSM sharing your personal information (except for health information and financial information) within its group and sharing your personal information (except for health information) among its business providers, suppliers, sponsors and franchisees as necessary to provide our services to you (for example, financial information may need to be shared with cheque printers and credit card manufacturers who provide goods and services to you through us). * Disclosure of your information Whether we obtain your express or implied consent, when sharing your personal information, the GalleriaSM endeavours to ensure that all its business providers, suppliers, sponsors and franchisees adhere to a comparable privacy standard. Details of shared use of your information by our business providers, suppliers, sponsors and franchisees may also be found in specific terms of service, use agreements, and sweepstakes or promotions rules, depending on the service you are enjoying. If you provide information for a promotion, some or all data collected during the promotion may be shared with the sponsor. Many promotions offer opportunities for you to request additional information from sponsors. By requesting more information, you give the GalleriaSM permission to transfer your personal information to the sponsor so they can fulfill your request. However, only the minimum of personal information required will be shared. Whether your consent is express or implied, you are not consenting to the GalleriaSM sharing or selling your personal information beyond its group and its business providers, suppliers, sponsors and franchisees. Under no circumstances will we sell customer lists or information to others. * Non-disclosure of certain information We will never disclose certain personal information and other personal information will only be shared with your express consent. To be specific: - Health Information Any personal information that you provide to any pharmacy in the GalleriaSM is held in strict confidence by the pharmacy and will not be shared under any circumstance within the GalleriaSM, among its business providers, suppliers, sponsors or franchisees, or to any other person. - Financial Information With your express consent, we may, in certain circumstances, disclose your credit history with us to other lenders or credit bureaus in order to support the credit approval process. We will only disclose the information required to identify you, as well as facts from our credit records about your repayment history. We may disclose further personal information in other circumstances but only if we have first obtained your express consent. Your financial information, such as your creditworthiness or the balance on your President's Choice credit card, will not be shared by President's Choice Bank with other members of the GalleriaSM, but may be shared with other business providers of President's Choice Financial products or services. * When required or permitted by law Even without your consent, we must provide your information in response to a court order, search warrant or other legally valid enquiry or order. We may also disclose information to the authorities to serve a clear public interest and fulfill our public duty - such as to protect against fraud, money laundering or other criminal activity. * Withdrawal of your consent You are free to refuse or withdraw your consent at any time. You may do so by contacting the Loblaw Privacy Officer in writing as indicated at the end of this Privacy Policy. TheGalleriaSM Privacy Officer will be pleased to explain your options and any consequences of refusing or withdrawing your consent. You can change your level of consent at any time. However, changing or withdrawing your consent may affect the products or services we are able to provide or make available to you. For example, you may refuse consent for us to do a credit check, but we would then be unable to extend credit services to you. * Access to your information You can also access the information we retain about you. Upon receipt of your written request, we will provide you with a copy of your information. We will make every reasonable effort to keep your information accurate and up-to-date, and we will enable you to revise the information as appropriate. Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes such as a change of address or telephone number. If you find any errors in our information about you, let the appropriate member of the GalleriaSM know and the corrections will be made. [ OUR INTERNET BUSINESSES ] * Visiting Our Internet Sites When you go directly to our Web sites and move from page to page, read pages or download content onto your computer, we learn which pages are visited, what content is downloaded, and the address of Web sites that you visited immediately before coming to our Web sites. However, none of this is collected in a way which would identify you as an individual. It is measured only in aggregate and will not be used to identify you. We use this information to find out how many people visit our Web sites and the frequency with which certain pages of the sites are visited. This helps us to know what type of information is most useful to you so that we can improve our Web sites to make it easier for you to access information. We record the statistical information on the number of visitors to our Web sites and their activities, but no specific information about your particular actions on our Web sites will be kept or used. * Using our Internet Transaction Services When you register for one of our Internet transaction services, such as egrocer, we compile a profile of you for that service (e.g. name, address, account numbers, logon id etc.). Each time you use our Internet services, we collect your logon id, information about the transactions that you complete and the informational pages of the GalleriaSM Web sites that you visit while using the service. We use your profile in responding to your inquiries on the service. We use your logon id to identify you as a user of the service. We use the transaction information in the aggregate to assess and improve the service. We use specific transaction information for servicing purposes (e.g. billing). We use both your transaction information and the pages of the GalleriaSM Web sites that you have visited to determine whether we can offer other products and services that may interest you. When you are transacting through our Internet services, we will use appropriate safeguards and security measures to protect your information against unauthorized access and use. * Cookies A "cookie" is a small file containing certain pieces of information that a Web site creates when you visit the site. Cookies can track how and when you use a site, and which site you visited immediately before. We may use cookies to temporarily store some personal information, such as to save your password, so you don't have to re-enter it each time you visit our site. Cookies, by themselves, cannot be used to disclose your individual identity. This personal information identifies your browser, but not you, to our servers when you visit our site. Most browsers are initially set up to accept cookies, but you can set your browsers to refuse cookies. However, if you do not accept cookies, you may be limited in some areas of the GalleriaSM Web sites. For example, you would not be able to use the egrocer Web site. * E-mail Comments, Questions or Responses When you send an e-mail to a GalleriaSM Web site service or when you ask for a response by e-mail, we learn your exact e-mail address and any information you have included in the e-mail. Your e-mail address will be used to acknowledge your comments and/or reply to your questions and your communication and our reply will be stored in case we correspond further. The GalleriaSM will not sell your e-mail address to anyone. Your e-mail address may be used to send you information about products or services of the GalleriaSM that we believe may be of interest to you. If you do not want to be contacted with product information by e-mail, you may tell us so at any time. If you have asked to be put on an e-mail mailing list to provide you with certain information on a regular basis, you may ask to be removed from the list at any time. Please remember: E-mail over the Internet is generally unencrypted. We recommend that you use caution when forwarding free-format e-mail messages to us and that you do not include confidential information (such as account numbers, etc). [ YOUR CONCERNS MATTER TO US ] If you have any questions about the GalleriaSM Privacy Policy, or your dealings with us, you can contact the GalleriaSM Privacy Officer at: GalleriaSM Privacy Officer 7171 Yonge Street Thornhill, ON L3T 2A9 The content of this Web site is protected by copyright. ?2005 GalleriaSM Inc. Certain trademarks, tradenames and logos used at this Web site are the exclusive property of GalleriaSM Inc. or other affiliates. All rights reserved. The GalleriaSM reserves the right to amend this Privacy Policy from time to time without prior notice.