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Privacy Policy

Effective January 1, 2004, the Government of Canada will implement the last phase of the Personal Information Protection and Electronic Documents Act (PIPEDA). This federal statute applies to telecommunications providers and many other industry sectors.

This legislation establishes rules and principles for the use and disclosure of personal information based on the ten privacy principles developed by the Canadian Standards Association. These principles recognize that we live in an era when commercial information is exchanged and circulated by electronic means. It balances the individual's right to privacy in their personal information with the reasonable need of organizations to collect, use or disclose personal information.

Under the new legislation, an organization may collect, use or disclose personal information only for limited purposes that a reasonable person would consider appropriate in the circumstances.

The Personal Information Protection and Electronic Documents Act requires us to provide the same safeguards for your privacy that we have always provided on a voluntary basis. Our Privacy Policy sets out these principles in simple terms. It explains how we ensure that your privacy and the confidentiality of your personal information are protected.

"Personal Information" is personally identifiable information, such as your name, address, birth date and gender. Personal Information may be collected when you choose to provide it to us when registering for a HuronTel Service, such as when you choose to subscribe to a HuronTel Service, enter a HuronTel promotion or choose to receive a HuronTel newsletter. In addition, if you choose to contact any of our customer service representatives, we may keep a record of that correspondence so that we may fully address the subject matter. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information.

Business contact information such as the name, title, business address, email address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.

We have created this document to inform you about our privacy practices. We want you to understand the purposes for which we collect personal information about our customers. And we want to be sure that we have your consent to continue to collect, use and disclose your personal information for those purposes.

The HuronTel Privacy Policy is based on the following ten principles of privacy accountability:

• Principle 1: Accountability for the Collection, Use or Disclosure of Personal Information
As a customer of HuronTel, you have a right to expect that we are accountable for the personal information we collect and use. “Customers" mean our current and former customers and applicants for service.

We are responsible for maintaining and protecting your personal information while it is under our control. This includes any personal information that may need to be disclosed to third parties for processing or other administrative functions.

To help ensure the confidentiality of your personal information, we have established policies and procedures to ensure that we comply with the Personal Information Protection and Electronic Documents Act. We have designed a privacy officer who is responsible for our company's compliance with the ten privacy principles of the Canadian Standards Association.

If you have any questions or inquiries about how your personal information is stored, or when it may need to be disclosed to others, our privacy officer is there to assist and explain our policies to you.

• Principle 2: Identifying the Purpose for the Collection, Use or Disclosure of Personal Information
HuronTel collects personal information only for the following purposes:

1. To establish and maintain a responsible commercial relationship with you and to provide ongoing service. For example, when you apply for service, we collect information that allows us to confirm your identity and credit history so that we can accurately bill and collect for the products and services that you receive from us. We may collect credit card or bank account information, if you prefer the convenience of pre-authorized payment for services.
2. To understand your needs and preferences. We maintain a record of the products and services you receive from us, and we may ask for additional information so that we can serve you better. For example, we will ask for your e-mail address, if you wish to pay your bills electronically.
3. To develop, enhance, market or provide products and services. For example, we look at how our customers use our products and services, so that we can understand how to improve them. From time to time, we may review and analyze your use of our products and services to help us provide better product recommendations and special offers that we think will interest you.
4. To manage and develop our business and operations. For example, we analyze customer usage of our networks and facilities to help us manage them efficiently and plan for future growth.
5. To meet legal and regulatory requirements. For example, we may collect information in response to a court order, or to satisfy a request by the Canadian Radio-television and Telecommunications Commission (the "CRTC") for information about a customer complaint and how it was resolved.

Unless required by law, HuronTel will not use or disclose any personal information that has been collected without documenting the new purpose and obtaining your consent. If you have any questions about these purposes, our privacy officer will be pleased to explain them to you.

• Principle 3: Obtaining Consent for the Collection, Use or Disclosure of Personal Information
HuronTel will make a reasonable effort to make sure that our customers understand and consent to how their personal information will be used by the Company.

We will obtain your consent if we need to use your information for any other purpose and before collecting information from third parties such as other service companies.

In certain circumstances, however, personal information may need to be collected, used or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent.

The Personal Information Protection and Electronic Act recognizes that when information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of an individual may defeat the purpose of collecting the information. Seeking consent may also be impossible or inappropriate when the individual is a minor, seriously ill, or mentally incapacitated.

In obtaining your consent, we will always use reasonable efforts to ensure that you are advised of the identified purposes for which any personal information collected will be used or disclosed.

• Principle 4: Limiting Collection of Personal Information
We will limit the collection of personal information to that which is necessary for the identified purposes. Typically, this is information that is required to enable us to provide you with service. We may need to collect personal information from other sources including credit bureaus.

We will always collect personal information by fair and lawful means.

• Principle 5: Limiting the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed for purposes other than for which it was collected, except with your consent or as permitted or required by law. Your personal information will be retained only as long as it is necessary to fulfill those purposes.

There are a variety of circumstances where we may need to disclose some personal information about our customers. Here are some examples:

1. We may disclose a customer's personal information to a person who, in the reasonable judgment of HuronTel, is seeking the information as an agent of the customer. For example, we may provide information about a customer's account to the customer's legal representative if we are satisfied that that individual is requesting the information on behalf of the customer.

2. Subject to applicable CRTC regulations, customer information may be shared among HuronTel business units to help us serve our customers better and to provide them with services, such as Combined Voice Mail and Internet Call Director, which combine services from different parts of our organization.

3. We may disclose a customer's personal information to:

a. another telecommunications company for the efficient and cost-effective provision of telecommunications services;
b. a company involved in supplying the customer with communications or communications directory related services
c. a company or individual employed by HuronTel to perform functions on its behalf, such as research or data processing; or
d. an agent used by HuronTel to evaluate the customer's credit worthiness or to collect the customer's account.
Any such disclosure of a customer's personal information outside of HURONTEL is made on a confidential basis with the information to be used only for the purpose for which it was disclosed.

Subject to applicable CRTC regulations, we may disclose a customer's personal information to a credit-reporting agency.
We may disclose a customer's personal information to a public authority or agent of a public authority, if in the reasonable judgment of HuronTel, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information. If a customer calls 911, we will provide the customer's name, address and telephone number to the emergency agency.
In conjunction with special offers or programs, we may disclose customers' personal information to our program partners, or to third-party agents responsible for administering such offers or programs. Any such disclosure is made on a confidential basis with the customer's express consent.
HuronTel does not provide or sell its customer lists to any outside company for use in marketing or solicitation. Only employees with a business "need to know", or those whose duties require it, are granted access to personal information about our customers.

We keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law is destroyed, erased or made anonymous.

• Principle 6: Keeping Personal Information Accurate
HuronTel makes every effort to ensure that personal information about its customers is as accurate, complete, and up-to-date as is necessary for the purposes for which it was collected.

The terms and conditions of your service may require you to notify us of material changes to your personal information.

If you have any questions about the accuracy and completeness of the personal information that we have collected or retained, please do not hesitate to contact our privacy officer. If you need to update some aspect of your personal information, please contact the business office directly.

• Principle 7: Safeguarding Your Personal Information
HuronTel takes steps to protect personal information with security safeguards appropriate to the sensitivity of the information.

Specifically, we have stringent security measures in place to protect personal information against such risks as loss or theft, computer hackers, unauthorized access, disclosure, copying, use, modification or destruction.

HuronTel protects your personal information regardless of the format in which it is held. We also protect personal information we disclose to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All our employees with access to personal information are required as a condition of their employment to respect the confidentiality of personal information.

• Principle 8: Openness Concerning our Privacy Practices
HuronTel pursues a policy of openness about the procedures it uses to manage personal information. We will make specific information about our policies and practices relating to the management of their personal information available to customers upon written request.

We ensure openness by providing you with the following information:

1. the title and address of the privacy officer accountable for our compliance with the policy;
2. the name of the individual to whom inquiries or complaints can be forwarded;
3. the means of gaining access to personal information held by our company; and
4. a description of the type of personal information held by HuronTel, including a general account of its use.
HuronTel makes information available to help our customers exercise informed choices regarding the use of their personal information.

• Principle 9: Customer Access to Personal Information
HuronTel informs its customers of the existence, use, and disclosure of their personal information upon request and provides access to that information. Our customers are able to challenge or correct the accuracy and completeness of their personal information and have it amended when appropriate.

When a request is made in writing, we will inform you in a timely fashion, of the existence, use, and disclosure of your personal information and you will be given access to that information. In order to safeguard your personal information, we may require you to provide sufficient identification information to permit us to authorize access to your file.

In certain exceptional situations, we may not be able to provide you with access to all of the personal information we hold. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege. If this is the case, HuronTel will provide the reasons for denying access upon request.

Customers can obtain information by contacting our designed privacy officer at the address listed below.

• Principle 10: Challenging Compliance
A customer has the right to challenge HuronTel's compliance with the above principles by contacting the privacy officer accountable for our compliance with the policy.

HuronTel maintains strict procedures for addressing and responding to all inquiries or complaints from its customers about its handling of personal information. We inform our customers about our privacy practices as well as availability of complaint procedures, if necessary.

Our privacy officer will investigate all complaints concerning compliance with the privacy policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including the amendment of our policies and procedures where necessary.

In exceptional circumstances, the privacy officer accountable for compliance with our privacy policy may seek external legal advice where appropriate before providing a final response to individual complaints.

• Questions, Comments or Suggestions?
If you have any questions or concerns about our privacy practices, please call us at 519-395-2625. Otherwise, we will assume that we have your consent to continue to collect, use and disclose your personal information for the purposes identified above.



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