The scope and application of the Top Choice Media Group Privacy Code are as follows:

the Top Choice Media Group Privacy Code applies to Personal Information about Top Choice Employees and non-employee Persons who interact with Top Choice that is collected, used or disclosed by Top Choice.

The Top Choice Media Group Privacy Code applies to the management of Personal Information in any form whether oral, electronic or written. Top Choice Media reserves the right to amend this Top Choice Media Privacy Code from time to time.

The application of the Top Choice Media Group Privacy Code is subject to the requirements or provisions of any applicable legislation, regulations or agreements (such as collective agreements), or the order of any court or other lawful authority.

Exclusions from privacy protection: the Top Choice Media Group Privacy Code does not impose any limits on the collection, use or disclosure of the following information by a Top Choice Media Company: a) information that is publicly available, such as a Person’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about Top Choice Media customers, or number of visitors and average time spent on a website.

Top Choice Media has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Top Choice Media corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Top Choice, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

Top Choice Media will make a reasonable effort to make sure Persons understand how their Personal Information will be used by Top Choice . Top Choice Media will obtain consent from Persons before or when it collects or uses the Personal Information. Top Choice Media will not attempt to deceive Persons into giving consent.

A Person’s consent can be express, implied, or given through an authorized representative. A Person can withdraw consent at any time, with certain exceptions noted herein. Top Choice , however, may collect, use or disclose Personal Information without the Person’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

Note: If any Person at any time has any questions or concerns about Top Choice’s privacy practices, the Person can write to customer service:

By Mail: Privacy, the Top Choice Media Group 160 Applewood, Unit 23  Vaughan, On L4K 4H2

Subject to legal and contractual requirements, a Person can refuse to consent to Top Choice’s collection, use or disclosure of Personal Information about the Person, or a Person may withdraw the Person’s consent to Top Choice’s further collection, use or disclosure of Personal Information at any time in the future by giving Top Choice Media reasonable notice, unless: i) the consent relates to certain information required for credit approval which a Person applies for or accepts, ii) the consent is otherwise required by law or iii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If a Person refuses or withdraws the Person’s consent, Top Choice Media may not be able to provide the Person or continue to provide the Person with some products, services or information which may be of value to the Person.

Personal Information may be collected by Top Choice Media or third-party service providers on Top Choice’s behalf. Although information collected, used or disclosed on the Internet as described below often does not constitute Personal Information (and to the extent that such is the case, then the obligations under the Top Choice Media Group Privacy Code do not extend to such information), Top Choice Media provides the details below about Internet aspects of Top Choice Media Companies Services for the purposes of disclosure about Top Choice Media Companies Services.

When the user’s web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer’s “IP address.” For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time the user logs on.

Top Choice Media Companies may use the user’s IP Address to:

A cookie is a small text file, which often includes an anonymous unique identifier, that is sent to the user’s web browser from a website’s computers and is stored on the user’s computer’s hard drive. Cookies cannot be used to run programs or deliver viruses to a user’s computer.

Most browsers are initially set up to accept cookies. If a user prefers, the user can reset his/her browser either to notify the user when the user has received a cookie, or to refuse to accept cookies. The user should understand that while Top Choice Media Companies do not require a user to use cookies, certain Top Choice Media Companies Services will not function properly if a user sets his/her browser to not accept cookies.

Certain Top Choice Media Companies Services may contain electronic images known as Web beacons – sometimes called single-pixel gifs – that allow Top Choice Media Companies to count users who have visited those pages and to deliver co-branded services. Web beacons are not used to access Personal Information; they are a technique used to compile aggregated statistics about Top Choice Media Companies service usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Web beacon resides. Certain Top Choice Media Companies Services web pages may also contain Web beacons placed there by Top Choice Media Companies’ advertising partners to help Top Choice Media Companies determine the effectiveness of Top Choice Media Companies’ Internet advertising campaigns.

A Top Choice Media Companies Service may contain links to other websites and services. While Top Choice Media Companies try to link only to sites and services that share Top Choice Media Companies’ high standards and respect for privacy, a user should understand that Top Choice Media Companies are not responsible for the content of, or the privacy practices employed by, other companies or websites. This Top Choice Media Privacy Code applies only to the Top Choice Media Group Companies Services related to this Top Choice Media Privacy Code.

The majority of the advertisements which are displayed in connection with Top Choice Media Companies Services are served through one or more reputable Third Party advertisement-serving companies which deliver the advertisements to users in conjunction with Top Choice Media Companies Services. For more information about what information is collected and how information is used by a major Third Party advertising provider click here.

Top Choice Media Companies automatically collect certain information about the user’s computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring website addresses. This information is used by Top Choice Media Companies to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the Top Choice Media Group Companies Sites.

Certain Top Choice Media Companies Services may be co-branded and offered in conjunction with another company. If a user registers for or uses such services, both Top Choice Media Companies and the other company may receive information collected in conjunction with the co-branded services.

Top Choice Media Companies – all companies providing communications services under the Top Choice Media Group Inc. including its subsidiaries, and any successor company or companies thereof, as a result of corporate reorganization or restructuring.

Collection – the act of gathering, acquiring, recording or obtaining Personal Information from any source, including third parties, by any means.

Consent – voluntary agreement with the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the Person or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Top Choice . Implied consent is consent that can reasonably be inferred from a Person’s action or inaction.

Disclosure – making Personal Information available to a Third Party.

Employee – an employee or independent contractor (including freelancers)1 of Top Choice .

*The inclusion of independent contractors, including freelancers, within the definition of “Employee” is for convenience of reference only, and does in no manner imply that such individuals are employees of the company within the meaning of employment legislation or are in an employee-employer relationship with the company.

Individual – an individual other than an Employee who (a) corresponds with Top Choice , including complaints and including applications for employment; (b) enters an contest sponsored by Top Choice ; or (c) uses, or applies to use, the products or services of Top Choice .

Person – an Employee or an Individual.

Personal Information – information about an identifiable Person, but not: a) information that is publicly available, such as a Person’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about Top Choice Media customers, or number of visitors and average time spent on a website.

Third Party – a person other than the Person or his agent, or an organization other than a Top Choice Media Company.

Use – the treatment, handling, and management of Personal Information by the Top Choice Media Group Companies.

Top Choice Media is responsible for Personal Information under its control and shall designate one or more persons who are accountable for Top Choice ‘s compliance with the following principles.

(1.1) Responsibility for ensuring compliance with the provisions of the Top Choice Media Group Privacy Code rests with the senior management of Top Choice , which shall designate one or more persons to be accountable for compliance with the Top Choice Media Group Privacy Code. Other people within Top Choice Media Companies may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to- day collection and processing of Personal Information.

(1.2) The Top Choice Media Group Privacy Code in Detail Top Choice Media has designated a Chief Privacy Officer to oversee compliance with the Top Choice Media Group Privacy Code. The Chief Privacy Officer can be contacted at Chief Privacy Officer, 160 Applewood unit 23 L4K 4H2 Vaughn

(1.3) Top Choice Media is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. Top Choice Media shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7).

(1.4) Top Choice Media has implemented policies and procedures to give effect to the Top Choice Media Group Privacy Code, including: a) implementing procedures to protect Personal Information and to oversee Top Choice ‘s compliance with the Top Choice Media Group Privacy Code; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about Top Choice ‘s policies and practices; and d) developing public information to explain Top Choice ‘s policies and practices.

Top Choice Media has collected and collects Personal Information for the purposes set out below, and shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

(2.1) Top Choice Media has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Top Choice Media corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Top Choice , provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

(2.2) Top Choice Media shall specify orally, electronically or in writing the identified purposes to the Person at or before the time Personal Information is collected. Upon request, persons collecting Personal Information shall explain these identified purposes or refer the Person to a designated person within Top Choice Media who shall explain the purposes.

(2.3) Unless required by law, Top Choice Media shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Person.

The knowledge and consent of a Person are required for the collection, use or disclosure of Personal Information, except where inappropriate.

(3.1) Generally, Top Choice Media shall seek consent to use and disclose Personal Information at the same time it collects the information. However, Top Choice Media may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.

(3.2) In obtaining consent, Top Choice Media shall use reasonable efforts to ensure that a Person is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Person.

(3.3) Top Choice Media will require Individuals to consent to the collection, use or disclosure of Personal Information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

(3.4) In determining the appropriate form of consent, Top Choice Media shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Persons.

(3.5) In general, the use of products and services by an Individual, or the acceptance of employment or benefits by an Employee, constitutes implied consent for Top Choice Media to collect, use and disclose Personal Information for all identified purposes.

(3.6) An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact Top Choice Media for more information regarding the implications of withdrawing consent.

(3.7) In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. For example, Top Choice Media may collect or use Personal Information without knowledge or consent if it is clearly in the interests of the Person and consent cannot be obtained in a timely way, such as when the Person is a minor, seriously ill or mentally incapacitated. “the Top Choice Media Group may from time to time engage outside suppliers, including technology providers.”

Top Choice Media may also collect, use or disclose Personal Information without knowledge or consent if seeking the consent of the Person might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

Top Choice Media may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual or property is threatened.

Top Choice Media may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein.

The Top Choice , its outside suppliers and other third parties to whom we disclose information under this policy may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.

Top Choice Media shall limit the collection of Personal Information to that which is necessary for the purposes identified by Top Choice .

Top Choice Media shall collect Personal Information by fair and lawful means.

(4.1) Top Choice Media collects Personal Information primarily from Individuals or its Employees.

(4.2) Top Choice Media may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.

Top Choice Media shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Person or as required by law. Top Choice Media shall retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected.

(5.1) In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. (See Principle 3.7)

(5.2) In addition, Top Choice Media may disclose a Person’s Personal Information to: a) another person for the development, enhancement, marketing or provision of any of the products or services of Top Choice ; b) a person who, in the reasonable judgment of the Top Choice Media Group Companies, is seeking the information as an agent of the Person; c) any Top Choice Media Companies to permit the provision of services requested by the Person, and d) a Third Party or Third Parties, where the Person consents to such disclosure or disclosure is required by law.

(5.3) Top Choice Media may disclose Personal Information about its employees: a) for normal personnel and benefits administration; b) in the context of providing references regarding current or former employees in response to requests from prospective employers; or c) where disclosure is required by law.

(5.4) Only those Employees of Top Choice Media who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of Top Choice , are granted access to Personal Information about Individuals and Employees.

(5.5) Top Choice Media shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a Person, Top Choice Media shall retain, for a period of time that is reasonably sufficient to allow for access by the Person, either the actual information or the rationale for making the decision.

(5.6) Top Choice Media shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

(6.1) Personal Information used by Top Choice Media shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a Person.

(6.2) Top Choice Media shall update Personal Information about Persons as and when necessary to fulfill the identified purposes or upon notification by the Person.

Top Choice Media shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.

(7.1) Top Choice Media shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Top Choice Media shall protect the information regardless of the format in which it is held.

(7.2) Top Choice Media shall protect Personal Information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

(7.3) All employees of Top Choice Media with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.

Top Choice Media shall make readily available to Persons specific information about its policies and practices relating to the management of Personal Information.

(8.1) Top Choice Media shall make information about its policies and practices easy to understand, including: a) The title and address of the person or persons accountable for the compliance with the Top Choice Media Group Privacy Code and to whom inquiries or complaints can be forwarded; b) The means of gaining access to Personal Information held by Top Choice ; and c) A description of the type of Personal Information held by Top Choice , including a general account of its use.

(8.2) Top Choice Media shall make available information to help Persons exercise choices regarding the use of their Personal Information.

Top Choice Media shall inform a Person of the existence, use and disclosure of his or her Personal Information upon request and shall give the Person access to that information.

A Person shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

(9.1) Upon request, Top Choice Media shall afford to a Person a reasonable opportunity to review the Personal Information in the Person’s file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Person.

(9.2) In certain situations, Top Choice Media may not be able to provide access to all of the Personal Information that they hold about a Person. For example, Top Choice Media may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, Top Choice Media may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or if the information was collected as part of journalistic, literary or artistic activities. If access to Personal Information cannot be provided, Top Choice Media shall provide the reasons for denying access upon request.

(9.3) Upon request, Top Choice Media shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Top Choice Media shall provide a list of organizations to which it may have disclosed Personal Information about the individual when it is not possible to provide an actual list.

(9.4) In order to safeguard Personal Information, an individual or employee may be required to provide sufficient identification information to permit Top Choice Media to account for the existence, use and disclosure of Personal Information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

(9.5) Top Choice Media shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Person’s file. Where appropriate, Top Choice Media shall transmit to third parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.

(9.6 A Person can obtain information or seek access to his or her Personal Information by contacting a designated representative at Top Choice Media principal office.

(9.7) An employee can obtain information or seek access to his or her Personal Information by contacting his or her immediate supervisor within Top Choice .

A Person shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of Top Choice Media with the Top Choice Media Group Privacy Code.

(10.1) Top Choice Media shall maintain procedures for addressing and responding to all inquiries or complaints from Persons about Top Choice ‘s handling of their Personal Information. If any Person at any time has any questions or concerns about Top Choice ‘s privacy practices, the Person can either:

write to Customer Service – Privacy, the Top Choice Media Group,  160 Applewood unit 23 L4K 4H2 Vaughn provide information to Top Choice Media by sending an email with your inquiry to info@TopChoiceMedia.com

(10.2) Top Choice Media shall inform Persons about the existence of these procedures as well as the availability of complaint procedures.

(10.3) The person or persons accountable for compliance with the Top Choice Media Group Privacy Code may seek external advice where appropriate before providing a final response to individual complaints.

(10.4) Top Choice Media shall investigate all complaints concerning compliance with the Top Choice Media Group Privacy Code. If a complaint is found to be justified, Top Choice Media shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A Person shall be informed of the outcome of the investigation regarding his or her complaint.