Twin Rivers Paper Company Inc. (“Twin Rivers”) respects the privacy of all stakeholders. Twin Rivers is committed to keeping personal information accurate, confidential, secure and private in accordance with applicable laws. The Twin Rivers Privacy Policy is a formal statement of principles and guidelines concerning the protection of personal information collected, used and disclosed by Twin Rivers.

Introduction

Twin Rivers is a North American forest products company that manufactures and markets a range of paper products in North America.

In the course of its business activities, Twin Rivers may collect certain personal information about its individual customers, suppliers and other stakeholders, in accordance with applicable laws.

“Personal information” means information about an identifiable, individual person. This may include, without limitation, the individual’s address, age, gender, income, employment status, credit history, debts and liabilities, personal preferences and other information. Personal information does not include the name, title, business address or telephone number of an employee of an organization.

The Twin Rivers Privacy Policy is based on and will be applied to comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable privacy and data protection laws. For more information about Privacy in Canada, visit the official web site of the Privacy Commission of Canada at www.privcom.gc.ca. The Twin Rivers Privacy Policy describes the ten principles Twin Rivers follows to ensure protection of personal information when the company collects, uses or discloses it in the course of carrying on commercial activities. Twin Rivers’ corporate headquarters are in Canada, but as a North American company, Twin Rivers may collect and transfer personal information across borders and between legal entities within Twin Rivers. Accordingly, to the extent applicable, Twin Rivers must comply with PIPEDA, provincial privacy legislation as it is enacted, and privacy legislation in jurisdictions where Twin Rivers carries on business. Twin Rivers believes that this Privacy Policy, as supplemented by additional requirements of other jurisdictions where Twin Rivers conducts business and additional requirements that apply to certain types and sources of personal information, meets the requirements set out in PIPEDA and other applicable privacy laws. Twin Rivers businesses in the United States with different privacy laws are expected to make all reasonable efforts to meet the requirements of this Privacy Policy. Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against Twin Rivers or any third party or any of their respective directors, officers, employees, agents or representatives (collectively, the “Twin Rivers Group”); nor will the existence of this Privacy Policy or its application impose any obligations or liability upon the Twin Rivers Group, or add to any such obligation or liability, that the Twin Rivers Group does not already otherwise have to any individual or person at law or otherwise.

All Twin Rivers employees with access to personal information must adhere to the Twin Rivers Privacy Policy and its application. To this end, Twin Rivers’ Chief Financial Officer is designated as Twin Rivers’ Privacy Officer to ensure compliance by all Twin Rivers employees.

The Ten Principles Of Privacy

Principle 1 –  Accountability
Twin Rivers is accountable for all personal information in its possession, including personal information disclosed to third parties for purposes of providing products and services requested by customers, employees, suppliers and other stakeholders.

Principle 2 —  Identifying Purposes for Collection of Personal Information
Twin Rivers will identify the purpose for which it is collecting personal information, before or at the time the information is collected. Some of the purposes for which Twin Rivers collects, uses or discloses personal information are described in section 3 below.

Principle 3 —  Consent for Collection, Use or Disclosure of Personal Information
An individual’s knowledge and consent is required for the collection, use or disclosure of his or her personal information, unless otherwise permitted by law. Consent can be express or implied and may be given through an authorized representative. Consent can be withdrawn at any time upon written request to the Twin Rivers Privacy Officer, subject to legal or contractual restrictions and reasonable notice. Twin Rivers may collect, use or disclose personal information without knowledge or consent in exceptional circumstances, such as where permitted or required by law.

Principle 4 —  Limiting Collection of Personal Information
The information collected from an individual will be limited to those details necessary for the purposes identified by Twin Rivers. Information will be collected by fair and lawful means.

Principle 5 —  Limiting Use, Disclosure and Retention of Personal Information
Personal information will only be used or disclosed for the purposes for which it was collected, unless the individual has otherwise consented, or when it is required or permitted by law. Personal information will be retained by Twin Rivers only as long as necessary to fulfill the purposes for which it was collected.

Principle 6 —  Accuracy of Personal Information
Twin Rivers will keep personal information as accurate, complete and current as necessary for the purposes for which it is to be used. An individual may have his or her information amended as appropriate where it is found to be inaccurate or incomplete.

Principle 7 —  Safeguarding Personal Information
Personal information is safeguarded using measures appropriate to the sensitivity of the information.

Principle 8 —  Openness Concerning Policies and Practices
Twin Rivers will make information available to individuals about its policies and practices related to the management of personal information. This information is available on the Twin Rivers web site, www.twinriverspaper.com, or through alternate means upon request to the Twin Rivers Privacy Officer.

Principle 9 —  Access to Personal Information
As required by applicable laws, Twin Rivers will inform an individual of the existence, use and disclosure of his or her personal information upon request, and subject to certain exceptions, will give the individual access to that information. If Twin Rivers declines to provide such access for lawful reasons, Twin Rivers will explain the reasons, except where prohibited by law.

Principle 10 —  Addressing Complaints and Suggestions
Individuals may challenge Twin Rivers’ compliance with this Privacy Policy. Twin Rivers has policies and procedures to receive, investigate and respond to complaints and questions. Please contact the Twin Rivers Privacy Officer to express concerns or request access to personal information. Contact information is provided in section 4 below.

Application of The Ten Principles Of Privacy

What kind of information does Twin Rivers collect?

Twin Rivers gathers and uses personal information in order to provide customers, suppliers and other stakeholders with the products and services requested or to offer additional products or services these stakeholders may be interested in. Providing Twin Rivers with personal information is the choice of each individual. However, Twin Rivers may not be able to provide certain products or services if certain information is not provided.

The nature of each request will determine the kind of personal information Twin Rivers might request.

Twin Rivers may keep a file with contact history to be used for inquiry purposes so that it may ensure that individuals are satisfied with Twin Rivers’ products and services.

How does Twin Rivers use personal information?

Twin Rivers and its agents, affiliates and service providers may collect, use and/or disclose personal information for the following purposes:

  1. To communicate with stakeholders and maintain commercial relations in order to provide products and services, to administer accounts, make and receive payments, and fulfill contractual obligations;
     
  2. To monitor its products and service and report back to individuals to ensure their satisfaction with the provision of such products and services;
     
  3. To consider whether Twin Rivers or any of its affiliates should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau or credit reporting agency information, to check references and to confer with banking institutions;
     
  4. To distribute our promotional information and other material to individuals on our mail and e-mail lists;
     
  5. To develop, enhance, market, sell, provide and inform individuals of Twin Rivers’ products and services;
     
  6. To manage and develop Twin Rivers’ and its affiliates’ businesses and operations;
     
  7. As permitted by, and to comply with, any legal or regulatory requirements or provisions; and
     
  8. For any other purpose to which an individual consents.

When May Twin Rivers Disclose Personal Information?

Twin Rivers is obliged to keep personal information confidential except as described in this Privacy Policy, including under the following circumstances:

  1. When authorized by the individual
    Certain of the products and services offered by Twin Rivers may require it to obtain personal information in order to perform the services it has been engaged to provide. Twin Rivers will use this information to tailor programs to meet the needs and objectives of the person requesting the services.
     
  2. When required by law
    The type of information Twin Rivers is legally required to disclose usually relates to government taxation and employment reporting requirements. In some cases, such as under a court order, Twin Rivers may be required to disclose certain information to persons specified in the court order.
     
  3. When permitted by law
    Privacy legislation provides for certain situations where Twin Rivers is legally permitted to disclose personal information without consent. Examples include without limitation situations involving the collection of debt in arrears, medical emergencies, or suspicion of illegal activities.

With Whom May Twin Rivers Share Information?

Twin Rivers cannot share information without consent unless otherwise permitted by law. However, from time to time Twin Rivers may need to provide information to the following persons for the purposes set out above.

  1. Twin Rivers Employees
    In the course of daily business, access to personal information is limited to those employees with a legitimate reason for accessing it. As a condition of their employment, Twin Rivers employees are required to follow all applicable laws and regulations, including this Privacy Policy and Twin Rivers’ Code of Business Conduct. Unauthorized use or disclosure of confidential client information by a Twin Rivers employee is prohibited and may result in disciplinary measures including dismissal.
     
  2. Twin Rivers Affiliates
    Twin Rivers may share personal information with its affiliates for the purposes described in this Privacy Policy.
     
  3. Twin Rivers Third Party Suppliers
    Twin Rivers may engage and coordinate third party suppliers to provide certain services on Twin Rivers’ behalf or otherwise for the purposes described in this Privacy Policy. Such suppliers are only given the information required to provide the specific service for which Twin Rivers contracts them to provide. Suppliers are required to protect the confidentiality of personal information, and are prohibited from doing anything with this information that Twin Rivers has not authorized them to do. They are required to treat all personal information in a manner consistent with the Twin Rivers Privacy Policy.
     
  4. Financial Institutions
    Twin Rivers may disclose personal information to a financial institution, or other organization or individual retained by Twin Rivers for the purposes described in this Privacy Policy, including without limitation, to evaluate creditworthiness, to collect debts outstanding on an account, or in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements.
     
  5. Agents of the Individual
    Twin Rivers may collect or disclose personal information for the purposes described in this Privacy Policy from or to a person who, in the reasonable judgment of Twin Rivers, is providing or seeking the information as the agent of the subject individual.
     
  6. Other Third Parties
    Twin Rivers may disclose personal information to third parties with the consent of the subject individual or where disclosure is required or permitted by law.

How Does Twin Rivers Safeguard Information?

Twin Rivers has controls in place to maintain the security of its information and information systems. Appropriate controls are placed on Twin Rivers’ computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.

Is Twin Rivers‘ Web Site Secure?

Twin Rivers offers customers access to certain information through its web site. www.twinriverspaper.com provides general information about Twin Rivers and the products and services it offers.

Twin Rivers will ensure that any information accessed or provided through these sites remains secure.

In order to facilitate navigation on the Twin Rivers web site and those of its subsidiaries and preserve settings between visits, Twin Rivers may use “cookie” technology. Twin Rivers does not use cookies to store information about its visitors. Cookies are small pieces of data stored by Internet browser on a computer’s hard drive, which makes browsing easier when pages are revisited. Web browsers may be set to notify the user when a cookie is received or to prevent cookies from being sent. Please note, however, that by not accepting cookies, the functionality provided to visitors to these sites may be limited.

Twin Rivers’ subsidiaries may collect information that identifies users who require secure access to Twin Rivers sites or who send Twin Rivers correspondence via the internet. Twin Rivers’ various systems log information about which users access the system and what options are used. In the case of correspondence to Twin Rivers, Twin Rivers only uses information contained within such communications to respond to the user or to identify how to best resolve the situation outlined in the message. Twin Rivers may collect such correspondence, but no further information (other than what is needed to resolve the matter) will be collected.

The Twin Rivers’ Privacy Policy does not apply to external web sites to which its site links. Twin Rivers makes no representation about the privacy policies on external web sites, and is not responsible for the privacy practices employed by other web sites.

How do I access and amend my information?

To access personal information in accordance with Principle 9, individuals should make a written request to the Twin Rivers Privacy Officer.

How do I opt out or withdraw my consent?

Should an individual not want to share their personal information with Twin Rivers’ employees, affiliates or third party suppliers, subject to legal restrictions, consent can be withdrawn for certain of the purposes described in this Privacy Policy by contacting the Twin Rivers Privacy Officer.

Questions, Concerns and Complaints

Questions, concerns or complaints about personal information, or about the Twin Rivers Privacy Policy, should be directed to the Twin Rivers Privacy Officer at the following address:

Twin Rivers Paper Company Inc.
Chief Financial Officer
707 Sable Oaks Drive, Suite #010
South Portland, Maine 04106
Tel: 207-523-2350