TALK-OUT SYSTEMS INC.'s Online Privacy PolicyOverview “TALK-OUT SYSTEMS INC.” is committed to protect the privacy of our customer information. We fully support the spirit and intent of Canada's privacy legislation - The Personal Information Protection and Electronic Documents Act (PIPEDA). Although “TALK-OUT SYSTEMS INC.” has always had information protection policies and procedures in place, the purpose of this document is to provide our customers with information on our current policies and procedures. In particular, this document will provide information about “TALK-OUT SYSTEMS INC.”'s policy relating to the collection, use and disclosure of personal information and of our customer's right to limit such collection, use or disclosure. Personal information is any information that is identifiable about you, that may include information such as, but not limited to, your name, mailing or e-mail addresses, phone numbers, identification numbers, credit card numbers, and banking information. All personal information relating to our customers is maintained in strict confidence by “TALK-OUT SYSTEMS INC.” and is not sold to third parties. You may have questions as you read this document. For further information about “TALK-OUT SYSTEMS INC.” or the protection of personal information, please contact “TALK-OUT SYSTEMS INC.” Privacy Officer at «privacyofficer@talk-out.com». Our privacy policies and procedures are subject to change. For the most recent version of this Privacy Policy, please check our website «www.talk-out.com». Accountability “TALK-OUT SYSTEMS INC.” has appointed its Privacy Officer as the person who will be primarily responsible for “TALK-OUT SYSTEMS INC.”'s policies and procedures governing the protection of personal information. Our Privacy Officer may be reached at: «privacyofficer@talk-out.com». Identifying Purposes “TALK-OUT SYSTEMS INC.” collects personal information for a variety of purposes including processing your request for services from “TALK-OUT SYSTEMS INC.”. Personal information is used to verify, process and administer your product and service requests, maintain our commercial relationship with you, and analyze, understand and respond to your service needs. “TALK-OUT SYSTEMS INC.” also analyses and uses customer information to better improve the products that we offer to our customers. Where a third party or an affiliate of “TALK-OUT SYSTEMS INC.” has a product or service that may be of interest to you, we will forward information relating to any such product or service to you, unless you inform us otherwise, i.e. when you withdraw your consent to receive such information. Personal information is also used to communicate with you, for billing and provisioning purposes.“TALK-OUT SYSTEMS INC.” does not sell, rent or lease personal information to third parties. From time to time, “TALK-OUT SYSTEMS INC.” may outsource certain account processing, or other customer service functions to an affiliated company or a third party. In such cases, personal information will be provided to such affiliate or third party. However, “TALK-OUT SYSTEMS INC.” releases personal information only where that information will be maintained in confidence, based upon strict nondisclosure agreements with the third party. In the event that an affiliate or third party is located in the United States, your information may be processed and stored in the United States and as such, your information may be obtained by the governments, courts or law enforcement or regulatory agencies of the United States according to the federal and state laws of the United States. From time to time, “TALK-OUT SYSTEMS INC.” is also required to report to regulatory bodies or to present a summary of all our customer information, including your personal information, in statistical or analytical form to governmental authorities and industry organizations. When information is provided in statistical or analytical form, this means that information that might specifically identify you will not be disclosed. Instead, your information will be compiled into aggregate (i.e. group) form such that the user cannot identify or extract out your personal information. On certain occasions, “TALK-OUT SYSTEMS INC.” will collect personal information on its subscription formulas for services such as: the “Virtual office”, a “call plan service” or any related services offered by Talk-Out. Consent The knowledge and consent of a customer is required for the collection, use or disclosure of personal information, except where inappropriate. Examples of when this may occur, include but are not limited to, emergency situations, to prevent an illegal act, complying with a subpoena or warrant, or as required by law. Customers may withdraw consent to the collection, use and disclosure of information at any time by contacting our Privacy Officer. However, the withdrawal of consent to the collection, use and disclosure of information may affect “TALK-OUT SYSTEMS INC.”'s ability to offer or provide, or to continue to offer or provide products or services to you. When you apply for service from “TALK-OUT SYSTEMS INC.” we also need to use personal information for the purposes of facilitating the provision of service to you and for the purposes set out above. “TALK-OUT SYSTEMS INC.” can not in any situation proceed to a verification (ie. Credit check) after an application for services without having a signed form from the customer beforehand. As indicated in the “Limiting Collection” section, the conditions to subscribe to “TALK-OUT SYSTEMS INC.” services are present on all application for service forms. Limiting Collection “TALK-OUT SYSTEMS INC.” may only collect personal information that is necessary to conduct its business. The type of personal information that is collected may include: The customer's correspondence language preference, first, middle initial and last name, full mailing address, estimated long distance usage, date of birth, social insurance number, driver’s licence number and province or state of deliverance, credit or debit card number. Banking information to facilitate pre-authorized, or other forms of payments. The personal information collected is limited to information that is necessary for the purposes identified above. Certain personal information may also assist “TALK-OUT SYSTEMS INC.” to review and make a decision about the applicant's request for service. Information that specifically would identify you, such as a date of birth, is also necessary in order to properly identify you. Limiting Use, Disclosure and Retention “TALK-OUT SYSTEMS INC.”'s use of personal information will only be for the purposes listed above and, in particular to facilitate the provision of services to you. Information provided by “TALK-OUT SYSTEMS INC.” to affiliates, vendors or suppliers is provided under a contractual agreement that the information will be held in confidence, protected, and properly safeguarded according to the standards of “TALK-OUT SYSTEMS INC.”'s privacy policy. Personal information relating to customers may be shared with, and used or analyzed by, between or among “TALK-OUT SYSTEMS INC.”'s parent, affiliates and authorized agents and Resellers with whom “TALK-OUT SYSTEMS INC.” has entered into a commercial agreement to develop our business, better serve our customers and with third parties for certain account processing matters. Information may also be disclosed in connection with “TALK-OUT SYSTEMS INC.”'s corporate transactions or business. In each case, however, “TALK-OUT SYSTEMS INC.” will take steps to ensure the organization receiving the personal information will use and disclose the personal information for purposes in a manner consistent with this policy. “TALK-OUT SYSTEMS INC.” provides commissions to Resellers in accordance with “TALK-OUT SYSTEMS INC.'s” marketing plan. Personal information relating to customers may be provided in connection with “TALK-OUT SYSTEMS INC.’s” commissioning process. Retention Your personal information will be retained either in a file titled with your name at “TALK-OUT SYSTEMS INC.”’s corporate address as described on our website. “TALK-OUT SYSTEMS INC.” retains personal information only for as long as necessary in order to meet the purposes for which the information was collected or for legal purposes. When personal information is no longer required, that information will be destroyed, erased, or made anonymous. Accuracy “TALK-OUT SYSTEMS INC.” continually strives to maintain as high a level of accuracy as is reasonably achievable. Your confidential information will be kept in a file under your name at the “TALK-OUT SYSTEMS INC.” headquarters, 1250 blvd. Rene-Levesque West, Suite 2200, Montreal, Quebec, H3B 4W8. You have the right to request a change to your personal information records where you can establish that the record is inaccurate. Personal information is typically only updated in cases where we receive updated personal information from a customer or where required for business, financial reporting or other related purposes. In each case, “TALK-OUT SYSTEMS INC.” will update the information in our system upon receipt and verification, if necessary. Safeguards We have implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access disclosure, copying, use, or modification. Access to personal information within our computer system is available to all of our employees for the specific purpose of enabling us to properly service our customers and in connection with the purposes set out above. All employees (current and new) are required to confirm they have read and understood a confidentiality of information agreement and are regularly reminded that personal information may not be disclosed except in accordance with this policy. Personal information in hard copy (paper if necessary) is held securely within “TALK-OUT SYSTEMS INC.”. Access to “TALK-OUT SYSTEMS INC.”’s file storage room is granted to only a limited number of individuals who are also required to maintain the security of “TALK-OUT SYSTEMS INC.”'s files. Individual Access Requests for access to personal information should be forwarded, in writing, to the attention of the “TALK-OUT SYSTEMS INC.” Privacy Officer. As “TALK-OUT SYSTEMS INC.” carefully protects all personal customer information, requests for access must be accompanied by proof of identity. In the event the information provided is not sufficient to verify the identity of the person who has requested the information, our staff may require additional information to verify that access to personal information is only given to persons who are entitled to receive it. “TALK-OUT SYSTEMS INC.” may, for example, require information such as examples of telephone numbers the customer would have recently called, recent payments made to “TALK-OUT SYSTEMS INC.” and other relevant information as may be necessary. Possibility to make a complaint regarding privacy policies Any customer may make a complaint regarding the privacy policies stated above by communicating with the “TALK-OUT SYSTEMS INC.” personnel responsible of ensuring the proper application of “TALK-OUT SYSTEMS INC.” privacy policy. If you have any questions regarding this issue, please contact our privacy officer at the following address «privacyofficer@talk-out.com». “TALK-OUT SYSTEMS INC.” complaint procedures are available on demand. ******************* Should you have any questions with respect to the “TALK-OUT SYSTEMS INC.” privacy policy or if you do not consent to, or would like to limit, the manner in which information about you is collected, used or disclosed, or to withdraw your consent, please contact the “TALK-OUT SYSTEMS INC.” Privacy Officer by e-mail at «privacyofficer@talk-out.com». April 2009