APPLICATION OF POLICY

White Spot Limited (“White Spot”) recognizes the importance of privacy and the sensitivity of your Personal Information (as defined below). White Spot believes in protecting your privacy. This policy outlines how we manage your Personal Information and safeguard your privacy. By providing Personal Information to us, you agree to the terms of this policy. However, we are committed to continuous improvement and value your input. We welcome your comments and/or suggestions for improving this policy. If you have any concerns, please contact us at the address at the end of this policy. This policy covers our treatment of Personal Information that we collect, both through our website and through communications or interaction we may have with you (such as e-mails, telephone conversations, face-to-face or correspondence). This policy also covers our treatment of any information shared with us by third parties. Since White Spot regularly reviews all of its policies and procedures, we may change this policy from time to time and such changes will be effective from the date of revision.

MEANING OF “PERSONAL INFORMATION”

“Personal Information” means personally identifiable information, including without limitation names, addresses, financial and credit information (such as provided by franchise applicants), health information and consumer preference information.

COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

If you provide comments to White Spot regarding your experience at our restaurants and franchises, use credit cards or travellers cheques to pay for meals, order White Spot gift certificates, enter a White Spot contest or promotion, apply for a White Spot franchise, seek employment opportunities at White Spot, or have other interactions with White Spot, you may provide us with certain Personal Information related to those interactions. White Spot does not and will not give, sell, rent, share or loan your Personal Information to others except with your prior permission, as disclosed in this policy, as may be permitted or required by law, or in certain cases if we engage a third party to provide services to us and the third party is bound by confidentiality obligations. White Spot takes reasonable steps to ensure that your Personal Information is kept safe from loss, unauthorized access, modification or disclosure. Personal Information will be retained in accordance with this policy only for as long as may be necessary or relevant for the purpose of collection or as may be required or permitted by law, after which time it will be destroyed or made anonymous unless you further consent to its continued retention. We will generally notify you of the purposes of the collection, use and disclosure of the Personal Information at the time of collection, unless the purpose is obvious and you voluntarily provide the information (as in the case of providing your credit card to pay for a meal) or we are required or authorized by law to do so. Without limiting the foregoing, White Spot may collect, use and disclose particular types of Personal Information as follows: