We may share your personal information with our employees, contractors, consultants and other parties who require that information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of a sale of Embanet (or its assets), a financing of Embanet, the acquisition of Embanet of another business, or any other form of business transaction, combination, merger or joint venture. We will take reasonable steps to ensure that those parties to whom your personal information is disclosed are required to use and disclose your personal information only in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of Embanet's regular reporting activities to its related companies;
• to protect the rights and property of Embanet;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; or
• with your consent.

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure. As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or

variation of consent should be in writing and addressed to our Privacy Officer. We assume, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Embanet endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question.

These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question. Access to Your Personal Information You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing. Generally, your information is kept at our corporate offices at 225 Sparks Avenue, Toronto, Ontario M2H 2S5 CANADA.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information

that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

If we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of

any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy.
The contact information for our Privacy Officer is as follows:

Privacy Officer:
Balwinder Ahluwalia
Director, Information Technology
Embanet ULC
225 Sparks Avenue,
Toronto, Ontario
M2H 2S5 CANADA

Phone: 416-494-6622, extension 2270
E-mail: privacy@embanet.com
Fax: 416-494-1891