PRIVACY POLICY

At TradeUp, we value your business and respect your right to privacy. We want you to feel secure about any private information that you provide to us, and have therefore outlined our Privacy Policy below.

This Privacy Statement has been adopted by TradeUp Corporation and by those organizations using the TradeUp® trademarks under license from TradeUp Corporation (referred to collectively as “TradeUp”), in order to demonstrate their commitment to the protection of individual privacy. The following discloses the personal information collection, use and disclosure practices of TradeUp.

For the purposes of this Statement, “personal information” means information that is personally identifiable to individuals. “Non-identifiable information” means information that cannot be associated with or traced back to specific individuals with any certainty.

HOW AND WHEN TRADEUP COLLECTS PERSONAL INFORMATION
1. TradeUp collects personal information from individuals on a voluntary basis through surveys, contest entry forms, registration forms, questionnaires and transaction documents both online and offline. The personal information includes contact information (for example, name, mailing address, e-mail address, telephone number), demographic information, household information, preference information and transactionrelated information.

USE OF PERSONAL INFORMATION BY TRADEUP
2. TradeUp uses personal information that it collects for the following:

To communicate with individuals
To understand individual needs
To promote and offer products, services and special offers that meet individual needs or that might be of interest to individuals based on information provided and approved by TradeUp.

To provide individuals with products or services that are requested or that is part of TradeUp’s ongoing service with it’s customers
To conduct, process and complete transactions with TradeUp customers
The information also enables us to develop and customize our products and services to better meet the needs and preferences of customers.
TradeUp may, from time to time, contact individuals by electronic format, regular mail or telephone for any of the purposes set out above.

DISCLOSURE OF PERSONAL INFORMATION BY TRADEUP
3. TradeUp does not sell, rent or trade personal information that it collects. TradeUp will not knowingly disclose personal information to any third parties except in the following circumstances: When TradeUp has received consent to do so or under limited circumstances specifically described at such time as personal information is collected;

When TradeUp, in good faith, believes the law permits or requires such disclosure;

To affiliated and associated companies within the TradeUp group of companies and only for the purposes described in paragraph 2 above. These affiliated and associated companies and their respective employees are restricted from using the personal information for any other purpose other than as described in paragraph 2 above.

To its agents, professional advisors, promotional and marketing agencies, and to any other Third Parties in order to complete transactions, to process data and to service customers. These Third Parties and their respective employees are only provided with such personal information as is necessary to perform the services for which they have been contracted and are restricted from using the personal information for any other purpose other than as described in paragraph 2 above.

In the event of the sale of TradeUp, personal information may be one of the transferred business assets.

RETENTION OF PERSONAL INFORMATION BY TRADEUP
4. At such time as personal information is no longer required for the purposes stated in this Privacy Statement or other statutory requirements, such personal information will be made anonymous or destroyed.

COLLECTION, USE AND DISCLOSURE OF NON-IDENTIFIABLE INFORMATION
5. TradeUp collects and uses Non-Identifiable Information to assess the effectiveness of web site content and traffic. This allows TradeUp to improve the quality of visits to web sites managed by it by streamlining visitors’ ability to navigate these sites and developing featured programs and content that will be of interest to visitors. Aggregate non-identifiable information is used to perform statistical analyses of the collective characteristics and behaviour of individuals, and to measure demographics and interests.

6. TradeUp also uses aggregate non-identifiable information it collects to inform its current and prospective sponsors and advertisers about the number of visits to its web sites, the demographic characteristics of these visitors and the number of times visitors have viewed and “clicked” on their advertisement(s). TradeUp also discloses to advertisers the overall demographics available regarding visitors who “clicked” on their advertisement. Aggregate non-identifiable information may be used to describe TradeUp services and products to third parties such as prospective business partners and financial institutions. In any of these circumstances, only non-identifiable information in an aggregate form and not personal information is disclosed.

WEB SITES OPERATED BY THIRD PARTIES
7. Web sites operated by TradeUp may contain links to other web sites that may collect personal information. This Statement does not extend to the data collection, disclosure, use and retention practices of such third parties and TradeUp does not assume any responsibility for the privacy practices, policies or actions of such third parties. Individuals should read the privacy policies of such third parties, and make an informed decision whether or not to visit such web sites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.

SAFEGUARDING PERSONAL INFORMATION
8. TradeUp has taken measures to protect the security and confidentiality of personal information as are appropriate in the circumstances. Personal information is stored in confidential databases and locations in the Greater Toronto Area. These sites have appropriate security measures in place to protect against the loss, misuse and alteration of personal information under the care and control of TradeUp. Any information transmitted via the Internet, however, may be intercepted by third parties. TradeUp does not assume any liability for interception, alteration or misuse of information transmitted over the Internet. TradeUp employees are restricted from using and disclosing personal information collected by TradeUp other than in accordance with this Statement.

ACCESSING PERSONAL INFORMATION
9. Individuals have the right to access, verify and correct or amend all of their personal information collected by TradeUp. TradeUp believes that it is imperative that personal information be as accurate, complete and up to date as is necessary for the purposes for which it is collected. Accordingly, to help TradeUp keep personal information as current as possible, TradeUp encourages individuals to amend inaccuracies and make corrections in their personal information collected by TradeUp as often as necessary. To access verify and correct or amend personal information, please send an email to the Privacy Officer at TradeUp at privacy@TradeUp.com or call at 416-661-9290 , extension #1427.

HOW TO FILE A COMPLAINT
10. To file a complaint with TradeUp concerning the collection, use and/or disclosure of personal information, please send an email to the Privacy Officer at TradeUp at privacy@TradeUp.com or call at 416-661-9290, extension #1427. All complaints will be investigated by the TradeUp Privacy Officer as soon as is practical in the circumstances. Individuals will be notified of the outcome of the investigation of complaints clearly and promptly and will be notified of any relevant steps taken or to be taken as a result of a complaint.

THE CHOICE TO PROVIDE PERSONAL INFORMATION OR TO RECEIVE CERTAIN INFORMATION AND PROMOTIONAL MATERIALS
11. Individuals always have the choice whether or not they wish to supply TradeUp with personal information. Individuals wishing to “optout” of receiving certain informational and promotional materials from TradeUp or who otherwise object to the collection, use and disclosure policies as provided under this Privacy Statement, are asked to contact the Privacy Officer at TradeUp by email at privacy@TradeUp.com or call 416-661-9290, extension #1427.

Opt-out opportunities are also provided in other circumstances such as in certain promotional mailings. Individuals are reminded that the decision to withhold personal information or to object to the use and/or disclosure of personal information as provided in this Privacy Statement or in any agreement between such individuals and TradeUp, may, in certain instances, limit their ability to complete purchases of TradeUp products and services and limit their ability to access or take advantage of certain promotions and features.

Your personal information is obtained and used only with your consent that may be expressed or implied depending on the circumstance.