URBAN NETWORKS INC. PRIVACY POLICY

Policies and procedures for handling customer information have been created by Urban Networks Inc. (“Urban”) with the understanding that Internet technologies are still evolving and that Internet business methods are continuing to evolve to meet the needs and opportunities of the changing technologies. As a result, Urban’s policies and procedures are subject to change.

In the course of serving its customers, Urban acquires, stores and transmits customer communications and information that customers may regard as private or sensitive. Some of this information, such as the customer’s name, address, telephone number, and credit card data, is provided to Urban by its customers in order to establish service. Other information, such as the customer’s account status, choice of services, and customer logs, is created and maintained by Urban in the normal course of providing service. Urban also uses cookies, which are small pieces of information that a web site can store in a designated file on a user’s computer for various internal reasons. In addition, Urban may store customers’ electronic mail and other communications as a necessary incident to the transmission and delivery of those communications.

This Privacy Policy is subject to change without notice, and it is a customer’s responsibility to regularly check for modifications.

Data Security

Urban will protect the confidentiality of its customers’ information, account information and personal communications in accordance with the law and the legitimate interests of Urban, its employees and other customers of Urban’s services.

In an effort to keep customer information confidential, all Urban employees are required to sign a confidentiality agreement that includes the following statement to protect customer information:

The Employee acknowledges that the Company has received, and in the future will receive, from third parties their confidential or proprietary information subject to a duty on the Company’s part to maintain the confidentiality of such information in accordance with the law and to use it only for certain limited purposes. The Employee shall retain in strictest confidence, both during and after termination of employment, all such confidential or proprietary information and shall not disclose it to any person or to use it except as necessary in carrying out the Employee’s work for the Company consistent with the Company’s agreement with such third party.

“Information” or “data”, as terms used in this policy, refer only to the records of a customer’s account with Urban and do not refer to any data files that the customer or their end users may store on any Urban server. Such data files will also be kept confidential by Urban, its employees and partners, however protecting such data from unauthorized access is provided only on a “best efforts” basis. There can be no guarantee that customer data is 100% safe from hackers or other unauthorized access and Urban is not liable for losses incurred by such intrusions.

How is customer information used?

Urban may use customer information to provide its customers with system information or information about new or upgraded products. Urban does not rent, sell, or share customer data or personal information with any third parties, other than as specifically authorized or directed by the customer.

Disclosure of customer information and communications

Unless you provide express authorization and consented, or such authorization or consent is contained in the Terms of Service to which you have agreed, Urban will not otherwise disclose its customers’ personal and account information except in the following circumstances:

(a) where Urban has reason to believe that disclosing such information is necessary to identify, make contact with, or bring legal action against someone who may be causing harm or interfering with the rights or property of Urban, Urban’s customers, or others;

(b) where Urban has a good faith belief that the law requires such disclosure;

(c) where a person who, in our reasonable judgment is seeking the information as your agent;

(d) where Urban determines the information is required by another telephone company, provided the information is required for the efficient and cost-effective provision of telephone service and disclosure is made on a confidential basis, with the information to be used only for that purpose;

(e) to a company involved in supplying you with telephone or telephone-directory-related services, provided the information is required for that purpose and disclosure is made on a confidential basis, with the information to be used only for that purpose;

(f) to an agent retained by us in the collection of your account or to perform other administrative functions for us, provided the information is required for and used only for that purpose;

(g) to an agent retained by us to evaluate your creditworthiness, provided the information is required for and is to be used only for that purpose, or where others request information about your credit experience with Urban;

(h) to a law enforcement agency whenever we have reasonable grounds to believe that you have knowingly supplied us with false or misleading information or are otherwise involved in unlawful activities;

(i) to a public authority or agent of a public authority if, in our reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(j) where such information is disclosed to other members of the Urban organization and to our agents and authorized dealers in order to service your account, respond to your questions and promote additional products and services offered by members of the Urban organization that may interest you. If you do not wish to receive offers or information from affiliated Urban entities, please contact Urban at unet.ca/contactus.

Express authorization and consent to disclosure may be obtained as follows:

(a) by written consent;

(b) by oral confirmation verified by an independent third party;

(c) by electronic confirmation through the use of a toll-free number;

(d) by electronic confirmation via the Internet;

(e) by oral consent, where an audio recording of the consent is retained by you; or

(f) by consent through other methods, as long as an objective documented record of your consent is created by you or by an independent third party.

Personal information collected in connection with the provision of the Services may be stored and processed in or outside Canada and may be subject to the laws of other jurisdictions.

Urban has no obligation to monitor its services and will not, except for reasons stated below, disclose to third parties the contents of any electronic mail or other electronic communications that Urban stores or transmits for its customers. The circumstances under which Urban will disclose such electronic customer communications are when:

(a) it is necessary in order to provide service to the customer properly;

(b) it is necessary to protect the legitimate interests of Urban and its customers;

(c) it is required to cooperate with interception orders, warrants, or other legal process that Urban determines in its sole discretion to be valid and enforceable; and

(d) it is necessary to satisfy laws, regulations, or governmental, legal, or law enforcement requests or to provide to a law enforcement agency when the contents appear to pertain to the commission of a crime. Urban may grant law enforcement agencies access to its equipment to monitor use of its services.