This Policy outlines the continued commitment of ICI Canada Inc. to safeguarding the privacy of personal information supplied to us by our clients, prospective clients, suppliers, the employees of clients and suppliers and the general public. It also sets out the rights of these groups regarding the personal information supplied to us. This Policy covers personal information supplied to us directly by the groups mentioned above, and personal information supplied by clients using our services concerning their employees. It governs all branches of ICI Canada Inc., and applies to all our employees who deal with the personal information of clients, prospective clients, suppliers and the general public.

The contents of this policy also fully comply with the Federal Personal Information Protection and Electronic Documents Act, which applies to the personal information collected, used or disclosed in connection with commercial activities as of January 1, 2004, and all applicable provincial privacy legislation.

Accountability

To the extent required by law and as governed by this Policy, ICI Canada Inc. is responsible for personal information under its control, and we have designated a Privacy Officer who is responsible for ensuring the company's compliance with applicable legislation and this Policy. Information regarding how to contact ICI Canada Inc.'s Privacy Officer can be found under "Openness Concerning Policies and Practices" below.

Identifying Purposes and Limiting Collection of Personal Information

ICI Canada Inc. will only use personal information collected from clients, prospective clients, suppliers, the employees of clients and suppliers and the general public to process orders and credit applications, for marketing campaigns and promotions and to respond to requests and inquiries about our products and services, unless we obtain specific permission to use that personal information for other purposes.

The personal information collected by ICI Canada Inc. will be limited to that which is necessary to process orders and credit applications, for marketing campaigns and promotions and to respond to requests and inquiries about our products and services. All personal information collected for these purposes directly by us shall be collected by fair and lawful means. It is the responsibility of clients and suppliers utilizing our services to follow fair and lawful means in collecting the personal information that they provide to us.

Obtaining Consent for the Collection, Use and Disclosure of Personal Information

Except where inappropriate, ICI Canada Inc. requires the knowledge and consent (whether express or implied) of clients, suppliers, prospects and the general public to the collection, use and disclosure of personal information provided to us.

ICI Canada Inc. does not use "cookies" to save the personal information of general users to its various web sites, although cookies are used during a user session (i.e., to maintain a shopping cart). Cookies are used to identify users who take advantage of any customization features available on the sites and to save this information between visits. Additional information about web site privacy can be obtained by viewing each site's Privacy Policy.

ICI Canada Inc. may disclose personal information to third parties without consent as required by law or court order, to cooperate in a criminal investigation, or to enforce or protect our property or contractual rights.

Limiting Use, Disclosure and Retention of Personal Information

ICI Canada Inc. will retain personal information we receive only for as long as is required to fulfill the purposes for which it was collected or as required by law. We do not sell or share personal information with parties outside of ICI , with the following exceptions: to conduct credit checks; for customer surveys; and for market research.

Any data collected by ICI Canada Inc. may be transferred internationally throughout ICI, but only for internal purposes. By submitting personal information to ICI electronically, ICI Canada Inc. assumes that explicit consent is provided to the trans-border transmission of data for these purposes.

Accuracy of Personal Information

ICI Canada Inc. assumes that the personal information provided by clients, prospective clients, suppliers, the employees of clients and suppliers and the general public for the purposes identified in this Policy is accurate. However, we will endeavour to ensure that the personal information we receive is as complete and up-to-date as necessary for the purposes for which it is to be used. We will permit clients, prospective clients, suppliers and the general public to review, correct or update their personal information.

If ICI Canada Inc. has inaccurate personal information about a client, prospective client, supplier or employee thereof, the individual to whom the personal information relates can update and correct any errors by contacting the Privacy Officer. If ICI Canada Inc. concludes that a correction is not warranted, the affected individual will be permitted to attach a notation to their file. However, in the case of personal information that has been transferred to us by another organization, our Privacy Officer will direct the individual to the appropriate contact within the transferring organization.

Access to Personal Information

Following the receipt of a written request from a member of the general public for access, our Privacy Officer will, within a reasonable time, respond to the request advising what personal information ICI Canada Inc. has, the purposes for which it is being used, and to whom it has been disclosed. In the case of an access request from an individual relating to personal information that has been transferred to us by another organization, our Privacy Officer will direct the individual to the appropriate contact within the transferring organization.

In certain situations, access may not be provided to all the personal information ICI Canada Inc. possesses about an individual. If this is the case, our Privacy Officer will advise the individual of the reasons for this lack of access and any recourse the individual may have, except where prohibited by law.

Information regarding how to contact ICI Canada Inc.'s Privacy Officer can be found under "Openness Concerning Policies and Practices" below.

Security Safeguards

To prevent unauthorized access, to maintain data accuracy, and to ensure the correct use of personal information, ICI Canada Inc. has implemented appropriate physical, electronic and managerial procedures. These procedures are designed to safeguard and secure the information we collect on-line from loss, misuse, unauthorized alteration or unintentional destruction.

Openness Concerning Policies and Practices

Additional information about ICI's privacy policies and practices can be obtained by contacting our Privacy Officer at the address below, or by e-mail at privacy_officer@ici.com

Privacy Officer
ICI Canada Inc.
2600 Steeles Avenue West
Concord, Ontario
L4K 3C8

Our Privacy Officer has ultimate responsibility for ICI Canada Inc.'s compliance with this policy and with applicable privacy legislation.

Challenging Compliance

Any complaints or concerns about the treatment of personal information by ICI Canada Inc. should be addressed, in writing, to our Privacy Officer.

Privacy Officer
ICI Canada Inc.
2600 Steeles Avenue West
Concord, Ontario
L4K 3C8

A response will be provided within 30 days of our receipt of written notification of the complaint or concern. If matters are not satisfactorily resolved, a complaint may be filed with the appropriate privacy commissioner, whether federal or provincial, at the addresses below.

Federal:
Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario
K1A 1H3

Alberta:
Information and Privacy Commissioner of Alberta
410, 9925 - 109 Street
Edmonton, Alberta
T5K 2J8

British Columbia:
Information and Privacy Commissioner for British Columbia
4-1675 Douglas Street
Victoria, British Columbia
V8V 1X4

Quebec:
La Commission d'accés á l'information du Québec
575, rue St. Amable
Bureau 1.10
Québec, Québec
G1R 2G4