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Privacy Policy

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Privacy is an important part of our commitment to our customers and employees. We are committed to protecting the personal information we collect.

The North West Company Inc.’s privacy policy (“Privacy Policy”) is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information by The North West Company Inc.’s family of operations (collectively, “North West”), which includes Northern, NorthMart, Quickstop, Crescent Multi Foods, Valu Lots, Solo Market, Inuit Art Marketing Service, Fur Marketing Branch, AMDOCS, Sealift Express, North West Telepharmacy Solutions, Northern NorthMart Pharmacy, Alaska Commercial Company, Cost-U-Less, Giant Tiger, North Star Quality Meats, Pacific Alaska Wholesale, Span Alaska Sales, North Star Air Ltd., Link Tax Services, AC Financial, We Financial, and those banners’ websites and mobile applications.

The practices that we have adopted reflect requirements set out in the various applicable laws (federal, state and/or provincial).

Alaska Commercial Company

· Is accountable for the personal information that we collect and have in our custody and/or have entrusted to our authorized agents or third-party service providers.

· Will inform employees and customers, where practical and/or required by law, as to why we must collect any of their personal information before the information is collected.

· Will obtain consent (implied or informed) before or when we collect, use, or disclose personal information about individuals. When allowed by law or contract, individuals may withdraw their consent at any time.

· Limits the amount and type of personal information we collect. We will collect personal information only for the purposes that we have identified or as otherwise permitted by law.

· Will use or disclose personal information only for the reasons that such information was provided to us. We will keep personal information only as long as is necessary to accomplish these purposes.

· Will endeavor to maintain the accuracy of the personal information in our possession or control.

· Protects personal information with safeguards deemed appropriate to the sensitivity of the information.

· Will be open about the policies and practices used to manage personal information.

· Will, at an individual’s request, advise that individual of what personal information we have in our possession or control, what it is being used for, and to whom and for what reason it has been disclosed.

Consent

By submitting personal information to Alaska Commercial Company or our respective service providers or agents via our websites, mobile applications, and/or in our retail stores, you consent to the collection, use and disclosure of such personal information for the purposes described in this Privacy Policy, and/or for purposes stipulated at the time of collection as as permitted or required by law.

Subject to legal and contractual requirements, you may opt out of receiving communications from our email list by setting your email preferences to opt-out or by clicking on the unsubscribe link in our emails. Your personal information may be retained in the database to ensure that we honor your privacy requests to opt-out of certain communications, for record keeping purposes, for internal research and analysis, and for the other purposes described in this Privacy Policy. If you provide us with personal information concerning another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such individual to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

Personal Information and Communication

Personal information may include, but not be limited to, your name, address, telephone number, or email address. You may happen to provide us with such information through resources such as regular mail, our on-line application form or via our email addresses. In all cases, we will take steps to ensure that the information is handled securely. These steps are taken in order to comply with legislative requirements of applicable privacy laws. Personal information does not include aggregated information that does not allow an individual to be identified.

Collecting, Using and Protecting your Information

We collect, use and disclose personal information in accordance with applicable privacy and data protection laws and regulations. Alaska Commercial Company collects personal information (including, without limitation, names, addresses, telephone numbers and email addresses) that you provide when you (a) order a product from us; (b) sign up to join our newsletter/email club; (c) create a www.shopalaskacommercial.com account (d) create an account in the Alaska Commercial Company mobile application (e) participate in a contest or sweepstakes promotion; (f) sign up for and/or fill out a survey or questionnaire; (g) apply for an employment opportunity; (h) contact Alaska Commercial Company by email or otherwise, including requests for customer service.

Information is only collected with your consent and will be used for the sole purpose that is stipulated at the time the information is gathered. Your consent is deemed to be given when you send information to us through the internet. Alaska Commercial Company does not sell or share customer information with any other organization or person for any reason, except for any information entrusted to authorized agents or third-party service providers in compliance with applicable standards and laws.

Any information sent to Alaska Commercial Company is kept confidential and secure. We make every reasonable effort to protect against the loss, misuse, and alteration of personal information under our

control. We operate secure data networks protected by industry standard firewall and password protection systems. Our security policies are reviewed and enhanced as necessary.

Only authorized employees and providers have access to your personal information. Where information is processed by a third-party provider, we make sure, through our contracts with them, that all your information is kept secure. Our service providers may be located outside of the United States or Canada and may be required to disclose personal information under the laws of their jurisdiction. Information is only kept for the duration we are providing you with a product or service and for a reasonable time thereafter in the event that you wish to resume service.

Examples of how we use your personal information include:

· Product and Service Fulfillment: fulfill and manage purchases, orders, payments, returns/exchanges, or requests for information, or to otherwise serve you.

· Marketing Purposes: (i) deliver coupons, promotions, sweepstakes, contests, newsletters, regular flyers, emails, as well as mobile coupons and messages you have chosen to receive, (ii) send marketing communications and other information you have chosen to receive regarding products, services and promotions.

· Administer Promotions: administer sweepstakes and contests.

· Internal Operations: (i) improve the effectiveness of our website, stores, mobile experience and marketing efforts, (ii) conduct research and analysis, including focus groups and surveys, (iii) perform other internal business activities as needed, or as described elsewhere in this policy.

· Fraud Prevention: to prevent fraudulent transactions, monitor against theft and otherwise protect our guests and our business.

· Legal Compliance: to assist law enforcement and respond to subpoenas, search warrants, or other legal/regulatory orders or inquiries.

Accuracy of Personal Information

For the most part, we collect personal information that is directly supplied by you. We will therefore assume the information you have provided us with is accurate. We will not make additional efforts to verify its accuracy or to update the information unless requested by you. Customers and/or applicants may request in writing access to their personal information; to do so please write to PrivacyOffice@northwest.ca. Any information we have on record will be provided to you. You may put in a request at that time for your information to be updated to ensure its accuracy.

Non-Personal Information Collected Automatically

We do not require your personal information for you to access this website/mobile application. We may collect information about you that is not personally identifiable such as the type of internet browser or computer/mobile operating system you are using and the domain name of the website/mobile application from which you linked to our site. In addition, when you view our websites/mobile applications, we may store some information on your computer or mobile device in the form of a “cookie” or similar file. Cookies allow us to tailor a website/mobile application or promotion to better match your interests and preferences. Most internet browsers enable you to erase cookies from your computer or mobile device hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.

Alaska Commercial Company does not collect your personal information automatically, but we may tie the information that we do collect automatically (such as the type of internet browser that you use) to your previously submitted personal information. Alaska Commercial Company allows service providers and third-party companies to collect certain non-personally identifiable information when you visit our websites/mobile applications and to use that information to surface ads for Alaska Commercial Company products or services or other companies’ products or services when you visit our websites/mobile applications or other websites. This information (e.g., clickstream information, browser type, time and date, subject of advertisements clicked or scrolled over) is used during your visits to our websites/mobile applications to provide advertisements about products and services that also may be of interest to you. These parties typically use a cookie or a web beacon to collect this information. If you would like to opt out of Google collecting your browsing history, please download their browser add-on here: https://tools.google.com/dlpage/gaoptout/

Information from Other Sources

We may also obtain information from other sources that help us analyze, update, expand our records and identify new guests (e.g., updating contact information or adding demographic information). Alaska Commercial Company uses the information to improve our ability to contact you and increase the relevance of our marketing to you. These companies must follow privacy laws when collecting and sharing the information with Alaska Commercial Company.

Links to Other Websites

Our websites/mobile applications may contain links to other websites, including content from other websites that is occasionally framed within Alaska Commercial Company websites/mobile applications. Please note that the privacy policies applicable to the collection of personal information on those other websites may be different from this one and we have no control or responsibility for the privacy practices of third-party websites. You are advised to review the privacy policy of any website linked to or framed within Alaska Commercial Company websites/mobile applications prior to providing any personal information.

Customer Privacy Statement

Respecting your personal information is an important part of our commitment to you. Our Customer Privacy Statement lists the practices that we follow so that you can see when and how we use your personal information, and to show you that we only use that information responsibly.

  1. When you buy or order a product from us, you give us permission to collect, use, keep and disclose personal information that we have already collected about you as well as any additional personal information that you may provide to us, but only for the following reasons:
    • To carry out our normal business activities, like answering your questions, processing your order, arranging for payment, maintaining tax records, etc.
    • To send you catalogues, flyers and offers about our products or services.
    • To carry out any other legitimate business activity, as long as you know about it and have given us permission to collect, use, keep or disclose your personal information in carrying on that activity.
    • To satisfy legal or regulatory requirements.
  2. We will not give your personal information to any other business, except under the following conditions:
    • If another business is performing a service for us or for you, we may tell them that portion of your personal information that they need to know to perform that service.
    • If we sell, lease, reorganize or dispose of any of our businesses, we will ask the new owner/operator to agree to treat your personal information in the same way that we do.
    • We might compile data and provide it to another business. For example, a manufacturer might ask for the number of warranty claims filed against a certain product. If we do this, we will make sure that you cannot be individually identified.
    • Sometimes, other businesses ask us if our customers would like to know about their products or services. If we think that you might be interested and you give us permission, we would give your information to that business, but only so that they could offer you their products or services.
  3. If you ask us in writing, we will remove some or all of your personal information from our records, unless there is a reason why we have to keep it. If we have to keep it, we will remove it as soon as we can.

Privacy Policy Revisions

We may change or add to this Privacy Policy from time to time, so we encourage you to review it periodically. Revisions may reflect changes in how we collect, use, share and protect your personal information, as well as changes in our legal or regulatory obligations. The Privacy Policy posted on our website is the one currently in effect. To help you keep track, we include the date of our most recent updates.

For more information about our personal information practices, please visit our website at www.northwest.ca, call 1-800-563-0002 (ext. 3), or e-mail us at PrivacyOffice@northwest.ca.