Introduction

Hamilton Works recognizes the importance of maintaining the privacy, security and accuracy of your personal information when conducting business with our company. Our privacy policy ensures that your personal information is protected and that all our practices and procedures comply with all applicable privacy legislation.

1. Personal Information

When referred to in our privacy policy, the term "personal information" means information about an identifiable individual, but does not apply to the name, title or business address or telephone number of an employee of an organization.

2. Accountability

Hamilton Works is responsible and accountable for personal information in our custody or control, including information that has been transferred to our authorized service providers for processing. We use contractual and other means to ensure that third parties to whom we disclose personal information for processing provide a comparable level of protection with respect to personal information in their custody or control.

3. Purpose

Hamilton Works clearly identifies and documents the purposes for which we may collect, use or disclose personal information at or before the time of collection. In the normal course of business, we may collect and use certain personal information for the following purposes: · to answer requests for information we receive through our website or by other means · to inform you of our new developments and our business · to facilitate recruitment and selection of new employees

Where appropriate we will identify the purposes for which your information will be used on the data collection form. If, from time to time, potential other uses are identified we will document the purpose before such additional use. We will communicate the identified purposes in such a manner that you can reasonably understand how your personal information will be used or disclosed.

4. Consent

We will use reasonable efforts to seek your express consent for the collection, use or disclosure of your personal information at the time of collection.

In some circumstances, such as where we want to use personal information for a purpose that was not previously identified, we may seek your consent after your personal information has been collected but before our use for that purpose.

If you wish to "opt-out" of receiving certain informational and promotional materials from us or you wish to withdraw your consent with respect to a particular use or disclosure of your personal information, you may do so at any time by sending your written requests to our Chief Privacy Officer at the address at the bottom of this policy. In limited circumstances, as permitted or required by law, we may collect, use or disclose personal information without the knowledge or consent of the individual.

5. Collection

We only collect personal information necessary for our identified purposes.

6. Use, Disclosure and Retention

Hamilton Works does not use or disclose personal information for purposes other than those for which it is collected, except with the express consent of the individual or as required or authorized by law. We retain personal information only for as long as is necessary for the fulfillment of those purposes, subject to legal requirements.

7. Security

Your information is maintained in a secure manner appropriate to its sensitivity in order to protect against loss, theft or unauthorized access, disclosure, copying, use or modification from the time of its collection to its final disposal. We ensure that our employees and authorized service providers are aware of the importance keeping personal information appropriately safeguarded through the use of locked premises, electronic security measures and access protocols among others.

8. Accuracy

In order to ensure our best possible service to you, we take steps to ensure that personal information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. We encourage you to provide us with updates regarding such information and to inform us of any errors affecting your personal information that we hold to assist with our efforts.

9. Openness

Should you have any further questions regarding Hamilton Works' privacy policies including:(i) how to gain access to your personal information; (ii) the type of personal information held by us, including a general account of its use; (iii) what personal information is made available to authorized service providers; please contact our Chief Privacy Officer at the address at the bottom of this policy.

10. Access and Correction

Requests for access to your personal information should be directed in writing to our Chief Privacy Officer at the address at the bottom of this policy. You may request information regarding the existence, use and disclosure of your personal information and access to that personal information.

You may also challenge the accuracy and completeness of your personal information under our control and have it amended as appropriate. We will respond to an individual's written request within a reasonable time (generally within 30 days).

We may require you to provide sufficient information to permit us to provide an account of the existence, use and disclosure of your personal information. While our response will typically be provided at no cost to the individual, depending on the nature of the request and the amount of information involved, we reserve the right to impose a reasonable cost. If a fee is to be charged, we will inform you of the approximate cost and proceed upon payment.

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which we have actually disclosed personal information, we will provide a list of organizations to which we may have disclosed the personal information.

If a challenge to the accuracy of our records is not resolved to your satisfaction, we will record the substance of the unresolved challenge. Where appropriate, the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.

In limited instances, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to access will be as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: (i) information that contains references to other individuals or contains confidential commercial information where such information cannot be severed from the record; (ii) information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and (iii) information that is subject to solicitor-client privilege.

11. Compliance

We invite you to share any comments or concerns you have with our privacy policy by contacting our Chief Privacy Officer in writing. We review and investigate all written complaints. If justified, we may amend our policies and practices to satisfy your concerns.

If not completely satisfied with the results of our investigation of and responses to your complaint, you may file a complaint with the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, KIA 1H3, Telephone: 1-800-282-1376.

12. Policy Changes

Hamilton Works reserves the right to amend this policy from time to time, so we encourage you to periodically check our web site http://www.hamiltonsteel.ca/ for the current version. You may also obtain a copy of our current privacy policy by contacting our Chief Privacy Officer.

13. Chief Privacy Officer
You can contact our Chief Privacy Officer at the following address:

Fred Rauscher

U. S. Steel Canada
386 Wilcox Street
P.O. Box 2030
Hamilton, Ontario
L8N 3T1
Canada

Tel: (905) 527-8335 ext. 2783
Fax: (905) 308-7013
Email: fred.rauscher@stelco.ca