LYCATALK PRIVACY POLICY

Introduction

At Lycatel Canada, Inc ("Lycatalk"), we look after your Personal Information carefully. We adhere to the requirements of the Personal Information Protection and Electronic Documents Act (the "Act") and other data privacy and data retention regulations applicable in your Province.

This Privacy Policy (together with our general terms and conditions which may be found in the Canadian section of www.lycatalk.ca describes how we generate, collect, use, process and store the Personal Information that you provide to us or that is generated or collected when you use our services. Please take a moment to read our Privacy Policy so you know what choices you have about your Personal Information. This Privacy Policy may change occasionally so it's a good idea to come back and read through it again, from time to time.

Information we may collect from you

We may collect and process the following Personal Information about you:

• Your name, address, date of birth, telephone number, call data records including Traffic Data and Location Data, top-up records, credit card or debit card details and billing records.
• If you contact our Customer Services Department, we may keep a record of that correspondence, including copies of e-mails and your e-mail address. We may also monitor or record any telephone calls made to our Customer Services Department for quality assurance.
• Information that you provide by filling in forms on our website: www.lycatalk.ca This includes information provided at the time of registering to use our website, subscribing to our products and services, posting material or requesting further products or services. We may also ask you for information when you report a problem with our website or our telephone services and products.
• Details of your visits to our website including, but not limited to, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• We may also ask you to complete surveys that we use for market research purposes, although you do not have to respond to them.
• Other data, from time to time, to help us provide you with improved products and services. For example, now and again we might ask you to fill in a questionnaire, just so you can let us know how we're doing.

IP addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, troubleshooting and to report aggregate information to our advertisers. This is statistical data about a user's browsing actions and patterns, and does not identify any individual.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service. Cookies enable us:

• To estimate our audience size and usage pattern.
• To store information about your preferences, and so allow us to customise our website according to your individual interests.
• To speed up your searches.
• To recognise you when you return to our website.

You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you log on to our website.

Where we store your Personal Information

Any information sent to us is encrypted (scrambled) using Secure Socket Layer (SSL) technology. This is industry standard encryption technology that protects your Personal Information whilst being sent over the internet from being intercepted and misused by third parties. When it reaches us, we then store it on a secure server so that it can only be read by authorised personnel. Although we make every effort to create a secure environment for your Personal Information, Lycatalk cannot guarantee the safety of any personal information you transmit to Lycatalk online.

The Personal Information that we collect from you may be transferred to and stored in a destination outside Canada. It may be processed by staff that operate outside of Canada and who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of payment details and the provision of support services. For example, Lycatalk uses call centre and technical services from associated companies in the UK, Ireland and India.

Where the data protection laws of these countries do not provide the same level of data protection as in Canada, we will take steps to ensure that your privacy rights are at least compliant with the requirements of Canadian Federal laws particularly requiring appropriate security measures from any such third parties, set out in a contract between us, to protect your Personal Information; and monitoring compliance with such security measures for the lifetime of our relationship with such third parties.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Uses made of your Personal Information

We use Personal Information held about you in the following ways:

• Verifying your identity and supplying information to the manager of the Integrated Public Number Database,
• supplying the Products and Services to you,
• the administration of your Account by the Customer Services Department,
• providing you with service information, for example about Network faults,
• the prevention or detection of fraud,
• market research and profiling your usage and purchase preferences, and
• complying with applicable laws and regulations.

Lycatalk and other Lyca companies may also use your Personal Information to contact you by post, telephone, e-mail or SMS to let you know about products and services offered by Lycatalk, other Lyca group companies and selected companies, including any special offers and promotions, which may interest you. If you do not wish to receive this information or be contacted in this way, you may at any time, free of any charge, opt out of this direct marketing by requesting to be put on a designated list. You may make this request by contacting the Customer Services Department or by sending an e-mail to unsubscribe@lycatalk.ca. We won't ever share your details with companies outside the Lyca group for marketing purposes without your consent.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in Sydney). We may make use of the Personal Information we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.

We may disclose your Personal Information to any member of our group of companies in respect of the uses set out above.

We may disclose your personal information to third parties if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation or to protect the rights, property, or safety of Lycatalk, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your Rights

You have the right to ask us not to process your Personal Information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to a marketing company. You can exercise your right to prevent this processing by checking certain boxes on the forms we use to collect your data at the time of collection or you can also exercise the right to opt out at any time by contacting the Customer Services Department at the address below.

Our website may, from time to time, contain links to and from the websites of our associated companies. If you follow a link to any of these websites, please note that these websites follow our own Privacy Policy and that we are responsible or liability for these policies.

Access to Information

You're welcome to ask us what information we have about you, any time you like. If you need us to send it to you, we reserve the right to charge a nominal fee for providing access to your information, to cover the cost of our administration. If any of the details are incorrect, let us know and we'll amend them right away. If you'd like us to send you the information, you can write to our Customer Services Department at the below address.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page.

Links from our Website to other Websites

Please be aware that our website provides access to other websites by linking to them. We are only responsible for the privacy, content or security of the Lycatalk website.

Contacting us

If you have any comments or queries concerning use of your Personal Information, please contact the Customer Services Department at cs@lycatalk.ca

Contacting the Office of the Privacy Commisioner of Canada

If you feel you concerns have not been addressed satisfactorily in relation to your Personal Information, youcan write to the Office of the Privacy Commissioner of Canada at the following postal address: 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3.