Privacy Policy updated Jan 2009

All-Aboard Telecom Inc. (hereafter “All-Aboard Telecom “) respects your privacy and will only collect, use and disclose your personal information in accordance with this Privacy Policy.

This Privacy Policy outlines the type of personal information that is collected by All-Aboard Telecom , why and how it is collected, how All-Aboard Telecom uses and discloses the information, what safeguards are in place, how to change or withdrawal personal information and who to contact with privacy-related questions.

1. INTRODUCTION

This Privacy Policy applies to All-Aboard Telecom and its personnel, representatives
and agents. As used in this Privacy Policy All-Aboard Telecom does not include
resellers or distributors of All-Aboard Telecom products and/or services. All-Aboard
Telecom shall comply with Canadian federal and provincial legislation as it is enacted
and applicable privacy legislations in jurisdictions where All-Aboard Telecom carries on
business.

2. WHAT PERSONAL INFORMATION DOES ALL-ABOARD TELECOM COLLECT?

“Personal Information” as used in this Privacy Policy means information that
specifically identifies an individual and is provided to, or collected by, All-Aboard
Telecom and its’ staff or by All-Aboard Telecom’s agents, associates and affiliates on
behalf of All-Aboard Telecom .

“Personal Information” however, does not include an individual’s name, business title
or business contact information in their capacity as an employee.

3. WHY DOES ALL-ABOARD TELECOM COLLECT PERSONAL INFORMATION?

All-Aboard Telecom and its agents, associates and affiliates may collect, use and/or
disclose Personal Information for one or more of the following purposes:

  • to develop, enhance, market, sell, provide and inform individuals or businesses of All-Aboard Telecom products and services;
  • to update and verify All-Aboard Telecom’s databases and information provided by third parties;
  • to monitor communications to ensure the consistency and quality of the products and/or services of All-Aboard Telecom , its affiliates, suppliers, distributors, retailers and any other third parties with whom All-Aboard Telecom has a commercial relationship;
  • with respect to individual service providers, suppliers, distributors and retailers, to (1) consider whether All-Aboard Telecom or any of it’s affiliates should establish or continue a commercial relationship, including without limitation, to extend credit and to evaluate credit standing and to match credit bureau and/or credit reporting agency information, to check references and to confer with banking institutions; and (2) establish and maintain commercial relationships to provide products and/or services, administer accounts, make and receive payments, facilitate product delivery and returns and fulfill contractual obligations;
  • to conduct research and statistical analysis;
  • to distribute All-Aboard Telecom Newsletters, promotional information and any other information to individuals who have voluntarily enrolled in our mailing lists and/or emailing lists to detect and protect All-Aboard Telecom and other third parties against error, negligence, breach of contract, fraud and other illegal activity and to comply with All-Aboard Telecom’s audit requirements and to audit compliance with All-Aboard Telecom’s policies, procedures, laws and contractual obligations;
  • to engage in business transactions that may involve the sale of transfer of personal information, including the purchase, sale, lease, merger, amalgamation or financing involving All-Aboard Telecom or its affiliates, any particular brand, product line or business unit;
  • as permitted by, and to comply with, any laws or regulations;
  • and for any other purpose to which an individual consents – all reasonable steps will be taken to ensure that the new purpose is identified prior to actual use of the information

4. HOW DOES ALL-ABOARD TELECOM COLLECT PERSONAL INFORMATION?

Wherever possible All-Aboard Telecom will collect personal information directly from
the individual(s) concerned. In some cases, when deemed necessary, we will ask an
independent source to verify and supplement personal information.

5. HOW DOES ALL-ABOARD TELECOM DEFINE CONSENT?

Your submitting of Personal Information to All-Aboard Telecom means that you agree
and consent that All-Aboard Telecom can collect, use and disclose your Personal Information in compliance with this Privacy Policy. All-Aboard Telecom will not collect,
use or disclose Personal Information without requisite consent, except in certain
extraordinary circumstances. Such extraordinary circumstances shall include without
limitation, when legal, medical or security reasons make it impossible or impractical to
obtain consent or where it is otherwise in the individual’s best interest. At any time, subject to legal and contractual requirements and reasonable notice, you may refuse or withdraw your consent. It is important to note that if you refuse or withdraw your consent, All-Aboard Telecom may not be able to provide or continue to provide, products, services and/or information which may be of value to you. An individual from All-Aboard Telecom will advise you of the implications of such refusal or withdrawal.

To withdraw consent please contact the Chief Privacy Officer in writing:

All-Aboard Telecom Inc.
2000 Appleby Line, Suite 356
Burlington, ON
L7L 7H7
Attn: Privacy Officer

6. HOW DOES ALL-ABOARD TELECOM USE AND DISCLOSE PERSONAL INFORMATION?

In addition to the purposes identified in Section 3, from time to time All-Aboard Telecom
may use or disclose Personal Information to:

  • a person, who in the reasonable judgement of All-Aboard Telecom is providing or seeking the information as an agent of the subject individual;
  • service providers retained by All-Aboard Telecom to perform functions on its behalf, such as advertisers, market researchers, delivery contractors, website administrators, data processing, information technology and office services, provided such organization or individual does not collect, use or disclose the personal information for any other purpose other than to perform such functions or provide services to All-Aboard Telecom ; or
  • any third party where the subject individual consents to such collection, use or disclosure, or as required or permitted by law.

7. HOW DOES ALL-ABOARD TELECOM LIMIT THE COLLECTION AND RETENTION OF PERSONAL INFORMATION?

All-Aboard Telecom limits the collection of Personal Information to that which is
necessary for the purposes identified in this Privacy Policy as same may be amended
from time to time, or for any additional purpose identified before the collection of the
Personal Information. As well, Personal Information is not used or disclosed for
purposes other than those for which it was originally collected, except with consent or
as otherwise permitted by law.

All-Aboard Telecom will retain Personal Information only for so long as it is needed to
fulfill the purposes for which it was obtained and to meet any other legal requirement,
statutory or otherwise, from time to time.

8. HOWS DOES ALL-ABOARD TELECOM ENSURE ACCURACY OF PERSONAL INFORMATION?

All-Aboard Telecom strives to ensure that Personal Information is as accurate,
complete, and up-to-date as is necessary for the purposes for which it is to be used.
All-Aboard Telecom does not routinely update Personal Information therefore we rely
on the individual to notify us of any changes to their Personal Information. To update
Personal Information please contact the Chief Privacy Officer in writing:

All-Aboard Telecom Inc.
2000 Appleby Line, Suite 356
Burlington, ON
L7L 7H7
Attn: Privacy Officer

9. HOWS DOES ALL-ABOARD TELECOM ENSURE SAFEGUARDS OF THE PERSONAL INFORMATION?

All-Aboard Telecom endeavours to maintain adequate safeguards to protect against
loss, theft, unauthorized access, disclosure, copying, use or modification of Personal
Information in the care of the All-Aboard Telecom.

10. HOW DOES ALL-ABOARD TELECOM ENSURE ACCOUNTABILITY OF PERSONAL INFORMATION AND OPENNESS AND ACCESS TO PERSONAL INFORMATION?

All-Aboard Telecom is responsible for the Personal Information under its control and
has appointed the Chief Executive Officer to also manage the role of Chief Privacy
Officer to oversee our efforts to comply in all material respects with applicable privacy
legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those
designated by the Chief Privacy Officer (the “Privacy Team”) address and investigate
questions or concerns regarding Personal Information.

To reach the Chief Privacy Officer or a member the Privacy Team, please call 416-477-
2566 ext 200. A copy of this Privacy Policy is available at www.allaboardtelecom.ca
and any future updates or amendments will be posted as they occur.

All-Aboard Telecom will provide individual’s access to their Personal Information and
have the right to request that any inaccurate information be amended or corrected. All-
Aboard Telecom has the right to refuse a client for access to Personal Information if:

  • The information is protected by legal privilege;
  • Granting access would reveal confidential information pertaining to All-Aboard Telecom;
  • Doing so would reasonably be expected to threaten the life or security of another individual;
  • The information would likely reveal personal information about another individual;
  • The information would prejudice negotiation with you; or
  • To protect All-Aboard Telecom’s rights and property.

11. Challenging Compliance

We encourage you to discuss any privacy issues with the Chief Privacy Officer at:

All-Aboard Telecom Inc.
2000 Appleby Line, Suite 356
Burlington, ON.
L7L 7H7
Attn: Privacy Officer

12. Changes To This Privacy Policy

All-Aboard Telecom will from time to time review and revisit privacy practices and this
Privacy Policy. In the event of any material amendment, an appropriate notice will be
posted on our Website. You are encouraged to contact All-Aboard Telecom to establish
if any updates have been made to this Privacy Policy, which can be ascertained by the
date listed at the top of this Privacy Policy. All updates and amendments to this Privacy
Policy can be found at www.allaboardtelecom.ca

13. ALL-ABOARD TELECOM Website

Our Web site may contain links to other sites, which are not governed by this Privacy
Policy. On our Web site, like most other commercial Web sites, we may monitor traffic
patterns, site usage and related site information in order to optimize our web service.
We may provide aggregated information to third parties, but these statistics do not
include any identifiable personal information.

14. Communicating With Us

We recognize that convenience and quick access to information must be balanced with
security needs. We use many different means to communicate with customers, some
of which are more convenient such as e-mail. If you do not wish us to communicate
with you by e-mail, please advise and alternate arrangements will be made.

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