At THE EASIER TO READ TELEPHONE DIRECTORY INC., an important part of our commitment to you is respect for your right to privacy.

THE EASIER TO READ TELEPHONE DIRECTORY INC. has policies and procedures to protect your privacy. Keeping your information in strict confidence is a cornerstone of our business and an integral part of our commitment to service excellence.

This policy statement will help you better understand how THE EASIER TO READ TELEPHONE DIRECTORY INC. protects your personal information and the rights you have in terms of our collection, use and disclosure of your information. Copies of this Privacy Policy are available at 993 Princess St., Suite 217, Box 6, Kingston, Ontario, K7L 1H3 and online at www.easiertoread.com.

THE EASIER TO READ TELEPHONE DIRECTORY INC. may amend this Privacy Policy statement from time to time. Please visit online at www.easiertoread.com for the most up-to-date version.

This policy governs THE EASIER TO READ TELEPHONE DIRECTORY INC. ”THE EASIER TO READ TELEPHONE DIRECTORY INC.” and "we" used throughout this policy statement refers to and means THE EASIER TO READ TELEPHONE DIRECTORY INC.

THE EASIER TO READ TELEPHONE DIRECTORY INC. follows nine principles when collecting, using, disclosing and protecting your personal information

1. We are accountable for personal information under our control. There are designated individuals within THE EASIER TO READ TELEPHONE DIRECTORY INC. who ensure our compliance with these principles.
2. We have or will collect details that might appear in an existing telephone directory, on a business card or information that is available in public records.
3. We limit the personal information we collect to what is necessary for us to conduct business and serve you to the best of our ability. We collect information only by fair and lawful means.
4. The personal information we collect is only used, disclosed or retained for its original intended purpose, unless we have your consent or the information is required to meet legal requirements. We retain it only as long as necessary for those purposes.
5. We take care to ensure the information we have is accurate and up-to-date.
6. We safeguard the privacy of your personal information through security measures.
7. We are open with you about our policies and practices related to managing your personal information.
8. Upon request, we provide you with access to your personal information. You can ask how your information is used, ensure your records are accurate and complete, and update information if necessary.
9. We address your concerns. If you have questions or concerns regarding your privacy, we have steps you can follow to make sure your questions are answered to your satisfaction.
   

Why we need your personal information

What is personal information?

"Personal information" is information about you and your residence or place of business. This does not include public details that might appear on a business card or information that is available in public records.

When you first become a THE EASIER TO READ TELEPHONE DIRECTORY INC. customer, we may ask for both public and personal information about you so we can:

• establish your identity and location
• publish your information in the form of a telephone directory
• protect you and us from error and fraud
• understand your needs and eligibility for products and services
• recommend particular products and services to meet your needs
• extend payment, terms & conditions required by contract
• provide ongoing service
• meet our standard accounting practices
• comply with legal and regulatory requirements

As you do business with THE EASIER TO READ TELEPHONE DIRECTORY INC., we continue to collect personal information for our mutual protection. For example, we may monitor or record your telephone conversations with our representatives to ensure service quality, security and to confirm our discussions with you. We may also review and analyze your personal information to ensure its accuracy, protect your information from unauthorized use and to offer solutions that help meet your needs.

We obtain most of your personal information directly from you or from public records such as an existing telephone directory. When we ask for information we will let you know how it will be used. We will also inform you of our Privacy Policy.

The information we ask for depends on the product or service. We may ask for your name, address, phone number, fax number, email address, website address and business or occupation information to ensure the accuracy of our product and business records.

Some information may be obtained from other sources with your consent (if required). For example, we may verify some of the information you give us with public records such as an existing telephone directory. When we obtain information from someone or some place other than you, such as a public record, we record the source of that information, unless otherwise permitted or required by law.

Your information is obtained, used or shared only with your consent

This allows us to:

• ensure your information is correct in our database and records
• offer you other products and services
• send you information about products and services by means of direct marketing
• share your information in confidence within THE EASIER TO READ TELEPHONE DIRECTORY INC. group (provided it is legally permitted)
• obtain, use or disclose your information to others that we tell you about

Except as explained in “We may collect, use or disclose information without consent”, we do not share information about you with anyone outside of THE EASIER TO READ TELEPHONE DIRECTORY INC. group without your consent. In addition, if we intend to use your information in any way we did not tell you about previously, we will obtain your consent at that time.

There are many ways you can give your consent

Your express consent may be given in writing, verbally or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you have taken or when you continue to use a product or service after we have notified you of a change.

Examples of express consent:

Written - Signing a contract.
Example: If you sign a contract that states "I agree to the Terms”.

Verbal - Responding to a direct question from a representative.
Example: A representative asks, "To process your contract, we need your credit card information. Do you agree?"

Electronic - Clicking on the "I AGREE" button online.
Example: You may be asked to electronically acknowledge that you will be bound by legal terms or agree to certain statements. Clicking "I AGREE" is your electronic consent.

Example of implied consent:

Action you've taken - Use of products or services.
Example: If we provide you with a contract with conditions and we inform you of those conditions, we can conclude that you agree to those conditions if you choose to sign the contract. In addition, if you receive The Easier To Read Telephone Directory into your home or place of business, we can conclude that you agree to the ongoing use of your information.

We may collect, use or disclose information without consent

1. If we use an outside supplier to do work for us.

At times we may use the expertise of outside suppliers to do work for us involving some of your information. For example, collect accounts. We select the company carefully and confirm that it uses privacy and security standards that meet THE EASIER TO READ TELEPHONE DIRECTORY INCs strict requirements. Similarly, your payment transactions will be processed through payment associations such as financial institutions, Visa, MasterCard, the Interac Association, or the Canadian Payments Association. We may need to disclose some of your information to them on a confidential basis to process payments, provide customer service, and promote the service and for other reasonable purposes.

2. If we are required or permitted by law.

We may be compelled to release information by a court of law or other legal or regulatory authority. If so, our policy is to release information only to the extent that we have to. We may also collect, use or disclose information without consent where permitted by law. For example, we may collect and use publicly available information like information in an existing telephone book for marketing or customer service purposes. Further, for other legal, medical or other security reasons, it may be impossible or impractical to seek or obtain your consent.

3. If we have to protect the interests of THE EASIER TO READ TELEPHONE DIRECTORY INC.

In certain circumstances, THE EASIER TO READ TELEPHONE DIRECTORY INC. may have to collect, use or release information without consent for its protection. For example, we may do so when a payment is rejected for the reason "Non Sufficient Funds," when collecting an overdue account, or to detect or prevent fraud.

We may exchange information with credit bureaus

When you apply for certain terms of payment, we obtain your consent to exchange information about you with credit bureaus. In order to maintain the integrity of the credit reporting system, we may have to periodically update your information with credit bureaus as long as you appear in our publication and for a period of time following repayment. Your consent to the exchange of information cannot be withdrawn during this time.

We protect your privacy when sharing information for business transactions

From time to time, we may sell parts of our business, sell or securitize assets, or merge or amalgamate part or all of our business with other entities. Since customer and account information will normally be a part of such transactions, we may use or disclose such information to other parties included in the transaction, as part of due diligence and/or on completion of the transaction.

You can withdraw your consent

Subject to legal and contractual requirements, you may change or withdraw your consent at any time.

To change or withdraw your consent:

• contact the office at 993 Princess St., Suite 217, Box 6, Kingston, Ontario, K7L 1H3
• call us at 1-888-228-7855

Withdrawing your consent will generally not affect your eligibility for inclusion in the telephone directory offered by THE EASIER TO READ TELEPHONE DIRECTORY INC. However, if you do not consent or if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact on you, to help you with your decision.

When you change or withdraw your consent, we will do our best to make sure that our files are updated as quickly as possible. It may take some time for our records to reflect your changes as many records can only be changed during regular file updates.

You can choose not to receive direct marketing

We may ask for your consent to tell you about products and services through direct mail, telephone or other means. If you withdraw your consent to be sent direct marketing, this will not limit product-related information that we may send to you.

We protect your information from loss and unauthorized access

We limit access to your personal information and store it securely in a variety of locations. Depending on the nature of the information, it may be stored in various secure computer systems, or in archives in various locations in Ontario.

Access to your personal information is only given to those who require it to provide THE EASIER TO READ TELEPHONE DIRECTORY INCs products or services.

Employees who have access to your information are made aware of how to keep it confidential. Each employee must sign an agreement stating that maintaining confidentiality is a condition of employment with THE EASIER TO READ TELEPHONE DIRECTORY INC.

Outside suppliers are required to sign contracts to maintain confidentiality and security of your personal information and not to use it for any unauthorized purpose.

We use a combination of security measures to protect your personal information

In addition to the physical and electronic security devices we use to protect your information, we have security standards to protect our computer systems and your information from unauthorized use or access.

This protects your information at all times, when it is stored in data files or handled by our employees. Our systems also protect your information when it is electronically transmitted, for example, between our offices.

We regularly audit our information security procedures and continually assess that they remain effective and appropriate.

Your information is destroyed when it is no longer needed

The length of time we keep your information varies depending on the product or service and the nature of the personal information.

We have retention standards that meet customer service, legal and regulatory needs. When your information is no longer required, we securely destroy it or convert it to an anonymous form. For legal reasons, we may keep information beyond the end of your relationship with us.

We monitor our compliance with THE EASIER TO READ TELEPHONE DIRECTORY INC. Privacy Policy

We have procedures in place to assist our employees in the application of THE EASIER TO READ TELEPHONE DIRECTORY INC. Privacy Policy. We monitor the practice of these policies and report our findings to our Vice President of Operations.

The offices at THE EASIER TO READ TELEPHONE DIRECTORY INC. and our Vice President of Operations are accountable for overseeing compliance.

We work with you to keep your information accurate

We make every effort to ensure the information in our records is correct and up-to-date. However, we also rely on you to tell us when your personal information changes.

It is important to ensure your personal information at THE EASIER TO READ TELEPHONE DIRECTORY INC. is accurate and complete. This allows us to continue to offer the highest quality service and to suggest products and services that best meet your needs.

To update your address and other personal information:

• contact us in writing at 993 Princess St., Suite 217, Box 6, Kingston, Ontario, K7L 1H3
• call us at 1-888-228-7855
• visit our website at www.easiertoread.com and email us at admin@easiertoread.com

By using one of the means of contact above, you can easily check and update your information.

You have the right to access, verify, rectify and update your personal information.

Much of your personal information is available to you through the Easier To Read Telephone Directory. An employee of THE EASIER TO READ TELEPHONE DIRECTORY INC. can help you check your information, update it and remove any unnecessary information.

Depending on the nature of the information you are requesting and complexity of your request, we may ask you to put your request in writing.

There's no charge for verifying or correcting your information. Depending on the circumstances, there may be a charge if you want a copy of records that we have already given you. We will let you know in advance if there is a charge.

You can find out the source of information we have collected

If we have obtained information about you from other people or sources, you can ask us for the source of that information. If we obtained a credit report on you, you may have access to that information; it would have come from Equifax Canada or Trans Union Canada. You may contact them directly for a current credit report; their contact information is available upon request.

You can find out to whom we have given information about you

On request, and where legally permitted, we will provide you with the names of outside companies or organizations to whom we have given your personal information.

We respond to your request promptly

Some of the information you request may not be immediately available. If this is the case, we will ask you to put your request in writing and will typically respond to you within 30 days.

If for some reason you are refused access to information held in your file, we will explain why, subject to any legal restrictions. If you wish to challenge our decision, we will tell you how to escalate your request.

We correct your information

If we discover we have information about you that is obsolete or incorrect, we will update our records accordingly. Whenever possible, we will correct any information which we may have given to an outside organization.

If a third party, such as a telephone directory or credit bureau, has given us information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information with them.

We protect other people's privacy when we make information available to you

It may not be appropriate for us to release certain information directly to you. There may be records that include information about you and other customers, or that have information confidential to THE EASIER TO READ TELEPHONE DIRECTORY INC. or are the property of THE EASIER TO READ TELEPHONE DIRECTORY INC. Because we must protect everyone's confidentiality and legal rights, we cannot make these records available to persons outside of THE EASIER TO READ TELEPHONE DIRECTORY INC. group. We will, however, make available to you any factual information about you contained in such records.

If we are unable to disclose information to you, we will explain to you why we cannot fulfill your request.

What you can do to safeguard your privacy

Notify THE EASIER TO READ TELEPHONE DIRECTORY INC. office immediately if:

• your credit card or debit card is lost, stolen or retained by a bank machine
• you believe someone has obtained your card number and PIN or password
• you believe someone is impersonating a THE EASIER TO READ TELEPHONE DIRECTORY INC. representative
• you believe your personal or financial information has been compromised
• you believe you have been the victim of identity theft, or that someone is using your personal information fraudulently

There are some simple yet very important steps you should take to protect your privacy.

Protect your debit card, credit card, PIN and passwords

You are the only person who should know your PIN (Personal Identification Number). Never disclose your PIN or passwords to anyone or you could be liable for losses. No THE EASIER TO READ TELEPHONE DIRECTORY INC. employee or agent will ever ask you verbally for your PIN or online banking password.

To protect your PIN, use your hand or body to shield your PIN from onlookers when you are conducting transactions at a bank machine or at a point-of-sale.

Regularly monitor your account activities

Promptly check your account statements to verify that all information has been properly recorded. If entries do not accurately reflect your contract or payment agreement, Contact THE EASIER TO READ TELEPHONE DIRECTORY INC. immediately.

Make sure your contact information is up-to-date

Making sure that THE EASIER TO READ TELEPHONE DIRECTORY INC. has your most up-to-date address or contact information will help protect your personal information from being misdirected. The “We work with you to keep your information accurate” portion of this policy statement explains how to check and update your personal information.

If you receive a suspicious phone call, email or letter, contact us

If you think someone is impersonating THE EASIER TO READ TELEPHONE DIRECTORY INC., or believe you have been the victim of fraud or attempted fraud through telephone, mail or email, call THE EASIER TO READ TELEPHONE DIRECTORY INC. office at 1-888-228-7855 or email admin@easiertoread.com.

Resolving your concerns is important to us

THE EASIER TO READ TELEPHONE DIRECTORY INC. is committed to treating you with the utmost respect and consideration while providing the highest level of product and service. Even so, from time to time something may go wrong. There may be a misunderstanding or you may feel you have been dealt with unjustly. Whatever the circumstances, our primary concern is ensuring your concerns are addressed and your problem is resolved.

How to resolve concerns and complaints at THE EASIER TO READ TELEPHONE DIRECTORY INC.

We are committed to upholding THE EASIER TO READ TELEPHONE DIRECTORY INC. Privacy Policy. If you have any questions or complaints about our Privacy Policy or about how we are living up to the Policy, let us know right away.

In most cases, a complaint or concern is resolved simply by talking to us about it. You should be able to get swift results by talking to our employees or the Vice President of Operations. You can speak with us at 1 888 228 7855 or write to us at:

The Easier To Read Telephone Directory Inc.
993 Princess St.
Suite 217
Box 6
Kingston, Ontario

Attention: Mr. Randy Bolton, Vice President of Operations

Be sure to include:

• your name
• your address/email address where you prefer to be reached
• if you prefer, fax number with area code
• the nature of your complaint
• details relevant to the matter and with whom you have already discussed the issue