GroupeX Limited (“GroupeX”) recognizes the importance of privacy and the sensitivity of personal information. This Privacy Policy outlines how we manage the personal information we collect from you through this website.

Your Privacy Rights

The Personal Information Protection and Electronic Documents Act (Canada) (the “Act”) applies to our collection, use and disclosure of personal information. To comply with the Act, we have developed this Privacy Policy and trained our staff about our policies and practices.

What is “personal information?”

Personal information is any information that identifies you, or by which your identity could be deduced.

Why do we collect personal information from you?

We collect personal information from you for the following purposes:

• To answer any enquiries that you send to us through our website

• If you sign up for our newsletter, to send you periodic updates about our company, and our products and services

• If you contact us in relation to potential employment with us, to answer your inquiry, review any information that you may send to us and to correspond with you further on possible employment opportunities

How do we collect your personal information?

We collect information through our website only by lawful and fair means. Wherever possible we collect personal information directly from you, but we may also obtain information about you from other sources: for example, if you apply for employment with us, we may contact your references to obtain information about your prior work history.

Consent

In most cases, we shall ask you to provide consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your verbal consent. Sometimes, your consent may be implied through your conduct with us.

You may withdraw your consent at any time, subject to any applicable legal restrictions.

Disclosure of your Personal Information

GroupeX will disclose your personal information:

• When we are required our authorized by law to do so, for example if a court issues a subpoena;

• When you have consented to the disclosure;

• When the services we are providing to you require us to give your information to a third party your consent will be implied, unless you tell us otherwise;

• Where it is necessary to establish or collect amounts owed to us;

• If we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage) and the third party is bound by our Privacy Policy;

• If the information is already publicly known.

GroupeX does not disclose your personal information to any third party to enable them to market their products and services to you.

Updating Your Information

It is important that your personal information be accurate and up-to-date. If any of your personal information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?

GroupeX takes all reasonable precautions designed to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;

• restricted file access to personal information;

• deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access; and

• internal password and security policies.

How Long Do You Keep My Personal Information?

We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

Access to Your Personal Information

You may ask for access to any personal information we hold about you and receive an accounting of its use and disclosure.

Summary information is available on request. More detailed requests that require archival or other retrieval costs may be subject to administrative fees.

Correcting Errors

If GroupeX holds information about you and if you can establish that it is not accurate, complete or current, GroupeX will take reasonable steps to correct it.

Can I be Denied Access to My Personal Information?

Your rights to access your personal information are not absolute.

We may deny access when:

• denial of access is required or authorized by law;

• when granting you access would have an unreasonable impact on other people’s privacy;

• to protect GroupeX’s rights and property;

• where the request is frivolous or vexatious.

If we deny your request for access to, or refuse a request to correct information, we shall explain why.

Employment Inquiries

Although the Act does not apply to our employee information, we have elected to follow privacy “best practices” in this area. If you apply to GroupeX for a job, we need to consider your personal information as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job that you accept, the information will be retained with our privacy procedures for employee records.

Web Site

Our website contains links to other sites, which are not governed by the Privacy Policy.

On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregated information to third parties, but these statistics do not include any personal information.

The website uses SSL 256bit encryption.

Children Under the Age of 13

Our website is not intended for children under 13 years of age. No one under age 13 may submit any personal information to us through the website. We do not knowingly collect personal information from children under 13. If you are under 13, do not provide any information about yourself to us. If we learn we have collected or received personal

information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact our Privacy Officer at the address provided below.

Communicating with Us

You should be aware that email is not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy

Since GroupeX regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access

If you have any questions, or wish to access your personal information, please write to our Privacy Officer at:

info@groupex-solutions.com

3 Rowanwood Ave, Toronto, ON M4W 1Y5