Totes ISOTONER Canada PRIVACY POLICY

Last updated: October 4, 2012

Welcome to totes-ISOTONER.ca (the "Website"), an interactive online service operated by totes ISOTONER Canada, Limited and its subsidiaries ("totes Isotoner Canada", "us", "we", or "our"). It is the policy of totes Isotoner Canada to protect and respect the privacy of its customers' personal information. totes Isotoner Canada maintains the privacy of your personal information in accordance with the law as detailed in this Privacy and Security Policy.

This Privacy Policy applies only to information that totes Isotoner Canada collects through the Website and does not apply to the collection of information by totes Isotoner Canada from other sources. Further, this Privacy Policy only applies to personal information that is subject to the privacy laws of Canada or any of its Provinces (as applicable). In view of totes Isotoner Canada's international operations, it is important to note that privacy laws may vary by jurisdiction and the rights and obligations described in this Privacy Policy may not be applicable to all persons or in all jurisdictions.

This Privacy Policy, together with the Terms of Use posted on our Website, sets forth the general rules and policies governing your use of our Website.

Since privacy and security concerns and legal and business requirements are constantly changing, we reserve the right to change this Privacy Policy by providing notice on our Website. Any changes will be effective immediately upon the posting of the revised Privacy Policy and accordingly, we encourage you to review this Privacy Policy often.

A. YOUR CONSENT

We only collect, use and disclose personal information with the consent of the individual to whom it relates. The consent may be express or implied. If you choose to voluntarily submit personal information to us, we will consider that you have consented to our collection, use and disclosure of this personal information for purposes reasonably related to our provision of products and services through our Website.

There may also be situations where our collection, use or disclosure of personal information without consent is authorized or required by law. You can withhold your consent to our collection, use and disclosure of your personal information, or withdraw your consent at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is withheld or withdrawn, the products and services we provide may be impacted, such that we may not be able to fulfill the purpose(s) for which the information was originally collected.

B. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect information, as necessary, in connection with the provision of our products and services through our Website.

(1) Personally Identifiable Information: We collect the following information that may personally identify you:

• Name, address, telephone number, email address or other contact information;
• Information about the goods or services provided or purchased;
• Customer financial information; and/or
• Information about customer transactions, including bills, credit history and method of payment preferences.

As a general policy, we do not automatically collect your personally identifiable information when you visit our Website. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Website. Such circumstances include, without limitation:

• providing your name, mail/shipping address, email address, credit card number and/or phone number when registering with our Website, using our online store, or in connection with a contest entry;
• providing certain demographic information about yourself (for example, age, gender, purchase preference and usage frequency) when participating in a survey, poll or joining a club; and/or
• posting a general comment and/or recommendation on our Website.

Whether or not you provide this information is your choice; however, in many instances this type of information is required to participate in the particular activity, realize a benefit we may offer, or gain access to certain content on our Website.

(2) Non-Personally Identifiable Information: We also collect information that does not personally identify you, such as information that we automatically collect when you visit our Website or information that you provide us that is de-identified.

We automatically collect certain non-personally identifiable information from you when you access our Website. This information may include, among other things, IP addresses, the type of browser you are using, the third party website from which your visit originated, the operating system you are using, the domain name of your Internet service provider, the search terms you use on our Website, the specific web pages you visit, and the duration of your visits.

We will not attempt to link or match such non-personally identifiable information with any personally-identifiable information unless:

• We have your consent;
• We (or our service providers) have detected or reasonably suspect any unlawful use of our services or security breach; or
• We have a legal right or duty to do so.

As part of the collection of technical information, we may use "cookies" on our Website. "Cookies" are small files placed on your computer that can collect and store a variety of information, including customer preferences and activities on the Website. Permanent cookies are stored indefinitely on a customer's hard drive unless manually deleted, while temporary cookies are automatically deleted from the user's browser upon logging out of a website.

If you are concerned about the storage and use of cookies, you may be able to direct your internet browser to notify you and seek approval whenever a cookie is being sent to your Web browser or hard drive. You may also delete a cookie manually from your hard drive through your internet browser or other programs. Please note, however, that some parts of our Website will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.

C. HOW WE USE & SHARE THE INFORMATION COLLECTED

(1) Personally Identifiable Information: The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to contact you for a variety of reasons, such as customer service, providing you promotional information for our products or those of our affiliated companies, or to communicate with you about content or other information you have posted or shared with us via our Website. We may also use personally identifiable information for other purposes to the extent authorized or required by law.

In certain instances we may also share your personally identifiable information with third party service providers performing functions on our behalf (or on behalf of our affiliated companies), including, without limitation, vendors that process credit card orders, deliver our merchandise, administer our promotions, provide us marketing or promotional assistance, analyze our data, and assist us with customer service. We require our service providers to keep your information secure; our service providers may not use or disclose personal information for any purpose other than providing the services on our behalf.

In addition, we may share your personally identifiable information with participating sponsors to a program or promotion (for example, a sweepstakes or contest) you enter via our Website. Further, we may share your personally identifiable information with third parties such as our co-promotional partners and others with whom we have marketing or other relationships. Except as provided in this Privacy Policy, our Terms of Use, or as set forth when you submit the information, your personally identifiable information will not be shared or sold to any third parties without your prior approval.

(2) Non-Personally Identifiable Information: We use non-personally identifiable information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities, and to improve our services. We may use your non-personally identifiable information by itself or aggregate it with information we have obtained from others. We may share your non-personally identifiable information with our affiliated companies and third parties to achieve these objectives and others.

(3) Marketing Purposes: We may use personal information to inform you of new products or other developments that we believe will be of interest to you. Such communications may be made by way of telephone, e-mail, fax or regular mail. In addition, personal information may be used to customize the advertisements displayed to you on our Website based on your interests and preferences, as determined through your use of the Website. You may opt-out of receiving such marketing communications or customized advertising by contacting us at the address below.

Please be aware that even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes (for example, contact to provide customer service, product information, service or reminder notices, or recalls). We may also need to contact you with questions or information regarding your order, such as regarding order status, shipment or refunds.

D. PUBLIC FORUMS

We may offer blogs, message boards, bulletin boards, or similar public forums where you and other users of our Website can communicate. The protections described in this Privacy Policy do not apply when you provide information (including personal information) in connection with your use of these public forums. We may use personally identifiable and non-personally identifiable information about you to identify you with a posting in a public forum. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Website.

E. ACCESS TO AND AMENDMENT OF PERSONAL INFORMATION

We will provide you with access to your personal information in accordance with applicable laws. We may require that any request for access to your personal information be made in writing. Generally, there is no cost for a request for access to your personal information. However, we reserve the right to charge reasonable costs in some circumstances in accordance with applicable laws. You will be notified in advance if such charges apply.

We will correct or amend the personal information in our files where it can be shown that the information is incorrect or incomplete. To ensure that your information is accurate, please notify us in writing when there are changes to your personal information.

F. PROCESSING, RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

Personal information about our customers may be processed and stored in Canada or any other country in which we or our service providers maintain facilities. Your personal information may be subject to the laws of the countries in which it is stored or used, and those countries may have different privacy laws. By providing us with your personal information, you consent to the transfer of your personal information to other countries.

We will retain personal information only as long as it is needed to provide our products and services through the Website and to meet legal or regulatory requirements. When the personal information is no longer required, we will destroy the information in a secure and confidential manner or ensure that such information is de-identified.

G. KEEPING YOUR INFORMATION SECURE

We have in place reasonable policies, procedures and safeguards (including physical, technological and organizational measures) designed to protect the security of personal information under our control.

Information collected on this site is transmitted using Secure Sockets Layer (SSL) Technology. This technology encrypts the other information before sending it to our secure server. This industry standard is in place to prevent someone other than the operators of our Website from viewing your personal information.

From time to time we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems. Further, we will continue to monitor security issues and will update and improve security when it is reasonable and practical to do so.

Please be advised, however, that while we strive to protect your personally identifiable information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your personally identifiable information. The internet is not a secure method of communications and we cannot guarantee the privacy or security of customer information submitted through the Website or by email over the internet. No security or encryption provided by us can protect you against every circumstance.

Your Responsibilities

Just as you play a vital role in ensuring the security of your home and your possessions, you too share in the responsibility for ensuring that your personal information is adequately protected. While totes Isotoner Canada takes strong measures to protect the security and privacy of your information, there are important steps that you should take to help protect your information when accessing the Website.

To protect your information, you should consider and adopt the following 'best practices':

• Never leave your computer unattended while using the Website.
• Always exit your account by using the “log out” button and close your browser if you step away from your computer. Your browser may retain information you entered in the login screen and elsewhere until you exit the browser.
• Secure or erase files stored on your computer by your browser so others cannot read them. Most browsers store information in non-protected (unencrypted) files in the browser's cache to improve performance. These files remain there until erased. They can be erased using standard computer utilities or by using your browser feature to "empty" the cache.
• Disable automatic password-save features in the browser and software you use to access the internet.
• Install and use an anti-virus program. Ensure your anti-virus software is enabled and configured to run daily updates and regular virus scans.
• Install and use a personal firewall on your computer to ensure others cannot access your computer through the internet.
• Install new security patches as soon as your operating system and internet browser manufacturers make them available.
• Install an anti-spyware program. Ensure your anti-spyware is enabled and configured to run daily updates and regular spam scans.

Password Rules

In order for totes Isotoner Canada to ensure that only you are accessing your account(s), we need a unique way of knowing that it's you. Just as the key to your home protects unwanted entry, the totes Isotoner Canada Website "key" - your password - ensures that only you can access your accounts.

It is your responsibility to ensure that your "key" to the Website is protected. Please observe the following security practices:

• Select a password of at least seven characters that is easy for you to remember but difficult for others to guess.
• Keep your password confidential and do not share it with anyone.
• Do not write down your password or store it in a file in your computer.
• Ensure that no one observes you typing your password.
• Change your password frequently (every 90-120 days).

Internet and E-mail Transmission/Viruses

Further, internet software or electronic transmission errors may produce inaccurate or incomplete copies of the content of our Website when downloaded and displayed on any computer. We do not assume any liability or responsibility whatsoever for computer viruses or other destructive software on programs received during the electronic transmission of such content of our Website or any websites accessed through links provided therein.

H. OTHER SITES/LINKS

Our Website may link to or contain links to other third party websites that we do not control or maintain, such as in connection with purchasing products referenced on our Website and banner advertisements. We are not responsible for the privacy practices employed by any third party website. We encourage you to note when you leave our Website and to read the privacy statements of all third party websites before submitting any personally identifiable information.

I. CONTACT & OPT-OUT INFORMATION

For further information about our privacy practices, to opt-out of future commercial correspondence, or to make a request for personal information, please contact customer service.