II. Privacy Policy

1. Personal Information Protection Policy

At Execulink Telecom, the privacy of your personal information has always been an important aspect of how we operate. On January 1, 2004, the Government of Canada implemented the federal Personal Information Protection and Electronic Documents Act (PIPEDA) that applies to all organizations and businesses that collect, use and disclose personal information in the course of business. As such, Execulink Telecom has developed the following Privacy Policy in order to ensure compliance with PIPEDA, as well as to inform our customers of our continuing commitment to the protection of their personal information. These policies apply to Execulink Telecom Inc. and any other companies that may become controlled by Execulink Telecom.

What is Personal Information?
Personal Information includes any factual or subjective information, recorded or not that identifies you as a specific individual. It does not include the sort of general information that could be found in a business or a telephone directory. This legislation establishes rules and principles for the collection, use and disclosure of personal information based on ten privacy principles. Our Personal Information Protection Policy sets out these principles in simple terms. It explains how we ensure that your privacy and the confidentiality of your personal information are protected.

2. The Ten Privacy Principles

Principle #1: Our Accountability for the Collection, Use or Disclosure of Personal Information
We are responsible for maintaining and protecting your personal information while it is under our control. This includes any personal information that may need to be disclosed to third parties. To help ensure the confidentiality of your personal information, policies and procedures have been established. We have designated a Privacy Officer who is responsible for compliance with the ten privacy principles. If you have any questions or inquiries about how your personal information is stored, or when it may need to be disclosed to others, our Privacy Officer is available to assist you and explain our policies.

Principle #2: Identifying Our Purpose for the Collection, Use or Disclosure of Personal information
Execulink Telecom will collect only the information that is necessary for your telecommunication services and will share information with third parties on a need to know basis. Your personal information will only be disclosed to third parties with your express consent or when necessary for legal reasons. We will ensure that customer confidentiality is maintained regardless of the technology used to communicate personal information. If you have any questions about these purposes, our Privacy Officer will be pleased to explain them to you.

Principle #3: Obtaining Your Consent for the Collection, Use or Disclosure of Personal Information
Execulink Telecom will make every reasonable effort to ensure that our customers or the customer's authorized representative understand and consent to how their personal information will be used. Seeking consent may also be impossible or inappropriate when the customer is a minor, seriously ill or mentally incapacitated. Written requests and consents to release information will be kept in the customer's records. We will disclose personal information to third parties only with your express consent, or when necessary for legal, audit or regulatory reasons. We will ensure that customer confidentiality is maintained regardless of the technology used to communicate personal information.

Principle #4: Limiting Our Collection of Personal Information
The collection of personal information will be limited to that which is necessary to provide the necessary telecommunications services to our customers. We will always collect personal information by fair and lawful means.

Principle #5: Limiting the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed for purposes other than for which it was collected, except with your consent or as permitted or required by law.

Principle #6: Keeping Your Personal Information Accurate
Execulink Telecom will ensure that personal information is as accurate, current and complete as is necessary for the purposes for which it was collected. If you have any questions about the accuracy and completeness of the personal information we have collected or retained, please do not hesitate to discuss this with our Privacy Officer.

Principle #7: Safeguarding Your Personal Information
Personal information will be protected by the security safeguards appropriate to the sensitivity of the information. Execulink Telecom will 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 collected and retained. As part of these precautions, we will restrict access to personal information to those employees or third parties that require access to the information in order to fulfill our responsibilities in providing your telecommunications services. As a condition of their employment, our employees with access to personal information are required, in writing, to respect the confidentiality of personal information. If an employee misuses the personal information to which they have access, this will be considered a serious offence. In the case of an employee, disciplinary action will be taken which, depending upon the degree of misuse, may include termination of employment.

Principle #8: Openness
Execulink Telecom pursues a policy of openness about the procedures it uses to manage personal information. We will make specific information about our policies and practices relating to the management of personal information available through the Privacy Officer.

Principle #9: Access to Personal information
Execulink Telecom will inform its customers of the existence, use and disclosure of their personal information upon request and provide access to that information. Our customers are able to challenge the accuracy and completeness of their personal information and have it amended as appropriate. In certain exceptional situations, we may not be able to provide you with access to all of the personal information we hold. Exceptions may include information that contains references to other individuals. Customers can obtain information or seek access to their individual customer records by contacting our designated Privacy Officer at the address below.

Principle #10: Challenging Compliance
A customer has the right to challenge our compliance with the above principles by contacting the Privacy Officer accountable for our compliance with the policy. Execulink maintains strict procedures for addressing and responding to all inquiries or complaints from its customers about its handling of personal information. We inform our customers about our privacy practices as well as availability of complaint procedures, if necessary. Our Privacy Officer will investigate all complaints concerning compliance with the privacy policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including the amendment of our policies and procedures. In exceptional circumstances, the Privacy Officer in compliance with our privacy policy may seek external legal advice where appropriate before providing a final response to individual complaints. If complainants are not satisfied with the response from our Privacy Officer they have the right to register their complaint with the Office of the Privacy Commissioner of Canada.

For Further Information, please contact our Privacy Officer:
Jonathan E. Scott, C.G.A., C.F.P.
Chief Financial Officer & V.P. Operations
Execulink Telecom
619 Main Street North
Burgessville, Ontario
N0J 1C0
Telephone: 519-468-3000
E-mail: PrivacyOfficer@execulink.com