CPNI Privacy Policy

Last Updated: October 29, 2007

Introduction

At CPNI Inc. ("CPNI"), we respect your privacy and are committed to protecting the personal information you share with us. CPNI has established this Privacy Policy so that you can understand the care with which we intend to treat such information. CPNI carries on business in Canada in compliance with the Personal Information Protection and Electronic Documents Act governing the collection, use and disclosure of personal information.

The term "personal information" means information about an identifiable individual. Personal information does not include the name, title or business address or telephone number of an employee of an organization or any publicly available information such as a directory listing of names, addresses, telephone numbers and electronic addresses.

Purposes of Collecting Information

CPNI's goal in collecting, using, and disclosing personal information is to enhance your product and service experience with us such as for the following purposes:

• providing you with general marketing, product, service and business partner information and offers;
• establishing and maintaining commercial relationships with partners, customers, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
• conducting market analysis and research;
• meeting safety, security, legal and regulatory requirements;
• detecting and protecting CPNI and other parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with CPNI policies and contractual obligations;
• maintaining the accuracy of our records to respond to your inquiries and provide you with customer service communications and otherwise manage our relationship with you;
• satisfying other reasonable, legitimate business interests (such as collecting outstanding debts); and
• for any other purpose to which you consent.

Consent

BY USING THIS SITE OR SUBMITTING PERSONAL INFORMATION TO CPNI OR ITS SERVICE PROVIDERS OR AGENTS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, CPNI'S TERMS OF SERVICE AND AS PERMITTED OR REQUIRED BY LAW. You also consent to CPNI having the right to collect, use and disclose any information acquired, whether through this Web site or use of CPNI services, which is not in a personally identifiable form, including aggregated information.

Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting CPNI. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide CPNI or our service providers or agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

Disclosure of Personal Information

If you provide us with personal information, we may from time to time disclose or transfer that information across borders and from your country or jurisdiction either within CPNI (including its subsidiaries and related companies) or to others including the following:

• service providers, including an organization or individual retained by CPNI to perform functions on its behalf, such as marketing, research, data processing, technical support, fulfillment and delivery services;
• an organization or individual retained by CPNI to evaluate your creditworthiness or to collect debts outstanding on an account;
• a person who, in the reasonable judgment of CPNI, is providing or seeking the information as your agent;
• third parties in connection with the sale, assignment, or other transfer of CPNI's business to which the information relates;
• any third party if, in CPNI's judgment, the rights or property of CPNI, its affiliates, third party service providers, or the users of CPNI's Web sites are in jeopardy;
• any third party if, in CPNI's judgment, the personal safety of users of CPNI's Web sites or other members of the public are in jeopardy; and
• any third party, where you consent to such disclosure or where disclosure is required or permitted by law or court order.

CPNI may also disclose aggregated information that does not allow you to be personally identified to third parties.

You agree that in certain circumstances personal information may be collected, used, or disclosed without your knowledge and/or consent. Examples of such circumstances include: a) legal, medical, or security reasons; b) detection and prevention of fraud or for law enforcement; and c) journalistic, artistic or literary purposes if its use is confined to those purposes.

You also agree that if the ownership of all or substantially all of CPNI's business or individual business units owned by CPNI were to change, your user information may be transferred to the new owner so our service can continue operations. In any such transfer of information, your user information would remain subject to the promises made in any pre-existing Privacy Policy.

Links

The CPNI Web sites contain links to other sites. You should be aware that operators of those linked sites may also collect your personal information and other information generated through the use of cookies or other tracking mechanism when you link to or use their sites. CPNI is not responsible for the privacy practices or content of other Web sites, including how such third parties collect, use or disclose your personal information. You are urged to check the privacy policies of linked sites before providing the operators of those sites with your personal information.

Security

CPNI is committed to protecting your personal information in compliance with this Privacy Policy and applicable laws. Your personal information may be stored and/or processed or otherwise used by or on behalf of CPNI both inside and outside of Canada (e.g., at secured locations with our service providers). To help protect the confidentiality of your personal information, CPNI employs administrative and technical security measures appropriate to the sensitivity of your personal information. For example, we operate secure data networks protected by industry standard firewall and encryption systems.

In terms of communicating personal information, you should note that there is no method of transmitting or storing data that is completely secure. While the physical characteristics of each are different, mail, telephone calls, faxes and transmissions over the Internet are all susceptible to possible loss, misrouting, interception and misuse of the information being communicated or transmitted. Moreover, where you use passwords, ID numbers or other special access features on our Web sites or in connection with CPNI services, it is your responsibility to safeguard them.

Contacting Us

CPNI is committed to continuous improvement and values your input. If you have any questions, comments or concerns about this Privacy Policy, or wish to update or correct or limit the use of any of your personal information that we may have, you may contact CPNI at:

CPNI Inc.
The Privacy Officer
401 The West Mall, Suite 415
Toronto, ON
Canada, M9C 5J5
Tel: +1.647.439.5341
Fax: +1.647.439.5373
Email: privacy@cpni-inc.com

Privacy Policy Updates

CPNI reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our Web site. Such changes will apply to personal information collected from the date of posting of the revised Privacy Policy as well as to existing information held by CPNI.

We encourage you to the review the Privacy Policy each time you visit our site.