Policy on the Collection, Use and Disclosure of Personal Information

1. Objective & Scope of Policy

RipNET Limited (RipNET) is committed to respecting your privacy and has prepared this Policy Statement to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.

This Policy Statement governs Personal Information collected from and about individuals who are or may become Customers of RipNET and those other individuals outside of RipNET with whom we work or who may provide Personal Information to RipNET.  This policy does not cover business contact information, corporate information or aggregated data from which the identity of an individual cannot be determined. RipNET retains the right to use aggregated data in any way that it determines appropriate.

In the event of questions about: (i) access to your Personal Information; (ii) RipNET's collection, use, management or disclosure of Personal Information; or (iii) this Policy Statement; please contact, Kingsley Grant, President, RipNET Limited, 101 Water Street West, Brockville, Ontario K6V 3M1 or by email at privacy@ripnet.com

2. The Collection, Use & Disclosure of Personal Information

For the purposes of this Policy:

"Customer" means a person or corporate entity that seeks to become a customer of RipNET or is a customer of RipNET or becomes a customer of RipNET.

"Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information but does not include business contact information.

RipNET requires your informed consent to the collection, use and disclosure of your Personal Information.  By entering into a customer contract with RipNET or otherwise voluntarily providing your Personal Information to RipNET, you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Privacy Policy.  If you do not agree with these terms, you are requested not to provide any Personal Information to RipNET. Unfortunately, certain services can only be offered if you provide Personal Information to RipNET. Consequently, if you choose not to provide us with any required Personal Information, RipNET may not be able to offer you those services .

RipNET uses the Personal Information you provided verbally or in writing in order to:

·         Process Customer contracts and accounts;

·         Manage our relationship with Customers;

·         Respond to requests for information;

·         Meet any legal or regulatory requirement;

·         For such purposes as are set forth and agreed to between the Customer and RipNET in any agreement entered into be the Customer and RipNET; and

• For such other purposes consistent with the foregoing and general purposes of RipNET.

RipNET's use of Personal Information is limited to these purposes. Unless permitted by law, no personal information is collected, without first obtaining the consent of the individual to the collection, use and dissemination of that information.

Personal information is collected, to the extent possible, directly from the individual concerned.

RipNET may disclose your Personal Information to organizations or individuals that perform services on behalf of RipNET. Using contractual or other arrangements, RipNET shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to RipNET, agree to use and hold such information solely for the purposes indicated by RipNET.

Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where RipNET is obliged to disclose information without consent. Such circumstances may include:

·         Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;

·         Where RipNET believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;

·         Where it is necessary to establish or collect fees or other monies owing to RipNET;

·         Where it is necessary to permit RipNET to pursue available remedies or limit any damages that RipNET may sustain; or

·         Where the information is public.

Where obliged or permitted to disclose information without consent, RipNET will not disclose more information than is required.

3. Accuracy

RipNET endeavours to ensure that any Personal Information provided by its Customers and in its possession is as accurate, current and complete as necessary for the purposes for which RipNET uses that data.

4. Retention

RipNET keeps Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When Personal Information is no longer required for RipNET's purposes, we will destroy, delete, erase or convert it into an anonymous form.

5. Security

RipNET endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.

RipNET further protects Personal Information by restricting access to it to those employees that the management of RipNET has determined need to know that information in order that RipNET may provide its services.

6. Access to Personal information

RipNET permits to individuals the reasonable right of access and review of Personal Information held by us about them.

If an individual believes any Personal Information concerning him or her is not correct, that person may request an update of that information by sending a request to the person indicated in Section 1 of this Policy. RipNET reserves the right not to change any Personal Information but will append any alternative reasonable text the individual concerned believes appropriate. An individual may also request that RipNET delete an individual's Personal Information from RipNET's system and records. However, due to technical constraints and the fact that RipNET backs up its systems, Personal Information may continue to reside in RipNET's systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from RipNET systems in response to an accepted request for deletion.

RipNET reserves the right to decline access to Personal Information where the information requested:

a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm RipNET or the competitive position of a third party or interfere with contractual or other negotiations of RipNET or a third party;

b) Is subject to solicitor-client or litigation privilege;

c) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;

d) Does not exist, is not held, or cannot be found by RipNET;

e) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual or another individual, or (iii) serious bodily harm to another individual;

f) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or

g) Any other grounds under applicable legislation.

Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.

Where information will be disclosed, RipNET will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.

RipNET will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.

To guard against fraudulent requests for access, RipNET will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.

7. Amendment of RipNET Practices and This Policy

This statement is in effect as of February 1, 2006. RipNET will from time to time review and revise its privacy practices and this Policy Statement. Policy changes will apply to the information collected from the date of the revised Policy Statement as well as to existing information held by the RipNET.

© 2006 RipNET Limited