MELOTEL PRIVACY POLICY

At MeloTel, we are committed to your privacy. This means we do not distribute, rent or sell any of your personal information to third parties except as provided for in this policy or as specifically consented to by you. For example, MeloTel may provide your personal information to third-party carriers for the provision of services, for billing and/or collection purposes, etc. All such provision of personal information to third-party providers shall only be done in accordance with the Personal Information Protection and Electronic Documents Act.

MeloTel’s privacy policy is segregated into ten principles.

• Accountability
• Identifying Purposes
• Consent
• Limiting Collection
• Limiting Use, Disclosure and Retention
• Accuracy
• Safeguards
• Openness
• Individual Access
• Challenging Compliance

Principle #1 Accountability

MeloTel is responsible for personal information under its control and has designated its Privacy Officer as accountable for the company’s compliance with the following principles. Accountability for MeloTel’s compliance with the provisions of MeloTel’s privacy policy rests with the Privacy Office within MeloTel, which shall designate one or more persons to be accountable for compliance with the MeloTel policy. Other individuals within MeloTel may be delegated to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of personal information. The Privacy Office has been created to ensure customers and employees have a designated avenue to answer their privacy-related inquiries.

• MeloTel shall make known, upon request, the title of the person or persons designated to oversee MeloTel’s compliance with this policy.
• MeloTel is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. MeloTel shall use contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
• MeloTel shall implement policies and practices to give effect to these principles, including:

1. Implementing procedures to protect personal information;
2. Establishing procedures to receive and respond to complaints and inquiries;
3. Training staff and communicating to staff information about the organization’s policies and practices; and
4. Developing information to explain the organization’s policies and procedures.

PRINCIPLE #2 IDENTIFYING PURPOSES

Where appropriate, MeloTel will identify the purposes for which personal information is collected at or before the time the information is collected.

MeloTel collects personal information only for the following purposes:

• To provide service(s) and/or products to its customers;
• To establish and maintain responsible commercial relations with customers and to communicate with its customers (which will include, but not be limited to: billing, collection, advertising, promotion and account verification);
• To understand customer needs and preferences;
• To afford promotional or other opportunities to our customers (e.g. contests);
• To meet legal and regulatory requirements; and

To administer and manage its business operations, including personnel and employment matters. Except where the collection of personal information is reasonably necessary in order to carry out the express wishes of the customer or employee, MeloTel shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected.

Persons collecting personal information will be able to explain to individuals the purposes for which the information is being collected, or will refer the individual to a designated person at MeloTel who will explain the purposes.

Unless required by law, MeloTel shall not use or disclose personal information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining the consent of the customer, where such consent may not reasonably be implied.

PRINCIPLE #3 CONSENT

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except in certain circumstances as described below:

In certain circumstances, personal information can 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. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate where there is an emergency threatening the individual’s life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. In addition, organizations that do not have a direct relationship with a customer may not always be able to seek consent. For example, seeking consent may be impractical for a charity or a direct-marketing firm that wishes to acquire a mailing list from another organization. In such cases, the organization providing the list would be expected to obtain consent before disclosing personal information.

Where appropriate, MeloTel will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when MeloTel wants to use information for a purpose other than those identified above).

In obtaining consent, MeloTel will use reasonable efforts to ensure that a customer is advised of the identified purposes for which personal information collected will be used or disclosed.

The form of consent sought by MeloTel may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, MeloTel shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.

MeloTel will seek consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. The use of services or products by a customer or the acceptance of employment by an employee will be considered implied consent to collect, use and disclose personal information for all identified purposes.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. MeloTel will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to MeloTel in writing.

With respect to personal information already collected by MeloTel prior to the publication of this policy, this policy will constitute reasonable notice to MeloTel’s current customers and employees of the purposes and uses for which such personal information has been collected. Should an individual object to these ongoing uses or disclosures, consent may be withdrawn upon providing notice to MeloTel in writing.

PRINCIPLE #4 LIMITING COLLECTION

The collection of personal information will be limited to that which is necessary for the purposes identified by MeloTel. Information will be collected by fair and lawful means.

MeloTel collects personal information from its customers and employees for the purposes described under Principle #2. MeloTel may also collect personal information from such third parties as credit bureaus, employers, personal references or other third parties that represent they have the right to disclose the information.

PRINCIPLE #5 USE, DISCLOSURE AND RETENTION

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual, or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

MeloTel may collect, use or disclose personal information without the individual’s knowledge or consent in certain circumstances as described in Principle #3.1. MeloTel may disclose a customer’s personal information to:

1. Another telecommunications company for the provision of telecommunications services to that customer;
2. A company involved in providing communications directory services;
3. A company involving in providing billing services;
4. A person involved in the development, promotion, marketing or enhancement of MeloTel’s services;
5. A credit collections agency;
6. Emergency services in an emergency situation;
7. MeloTel’s agents and affiliates;
8. A person who, in the reasonable estimation of MeloTel, is an agent of the customer; and
9. Any other third party, upon receiving the consent of the customer or as required by law.

MeloTel may disclose an employee’s personal information in the following circumstances:

• In the administration of that employee’s benefits;
• In providing references to prospective employers, upon receiving the consent of the employee; and
• As may be required by law.

Only MeloTel’s employees with a business need to know, or whose duties reasonably so require, are granted access to personal information about customers. MeloTel will retain personal information for only as long as required to fulfill the identified purposes or as required by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by MeloTel.

Principle #6 Accuracy

Principle #7 Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

MeloTel will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.

MeloTel protects all personal information regardless of the format in which it is held. Our methods of protection include:

• Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to MeloTel’s place of business in general and to internal offices as well;
• Organization measures, such as security clearances and limited access on a need to know basis; and
• Technological measures, such as the use of passwords, firewalls and encryption.

MeloTel makes its employees aware of the importance of maintaining the confidentiality of personal information. All of MeloTel’s employees with access to personal information will be required as a condition of employment to contractually respect the confidentiality of personal information.

MeloTel will protect personal information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

Principle #8 Openness

MeloTel shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

MeloTel will make information about its policies and practices easy to understand, including:

• The title and address of the person(s) accountable for MeloTel’s compliance with the policy and to whom inquiries or complaints can be forwarded;
• The means of gaining access to personal information held by MeloTel; and
• A description of the type of personal information held by MeloTel, including a general account of its use.

Principle #9 Individual Access

Principle #10 Challenging Compliance