PRIVACY STATEMENT

Gold Line Telemanagement Inc., together with its related companies and affiliates (collectively “Gold Line”) is committed to the highest standards of protection for the personal information and privacy of its customers. As part of this commitment, Gold Line has adopted a privacy policy in line with the requirements of the Personal Information Protection and Electronic Documents Act. By accessing this website and/or engaging the services of Gold Line, the user expressly consents to the collection, use and/or disclosure of personal information in accordance with the Gold Line Privacy Policy which may be viewed by clicking on the indicated link.

PRIVACY POLICY

Collection of Personal Information:

Personal information that is collected by Gold Line includes information about an identifiable individual such as the individual's name, address, e-mail and telephone number as well as their financial information (like account or credit card numbers). Although personal information will be predominately collected from the individual, personal information may also be obtained with the consent of the individual from other sources (i.e. credit bureaus, financial institutions, etc). Nevertheless, any information obtained from such other sources will be subject to Gold Line's privacy policy as if the information originated from the individual him/herself. General contact information is used to send products, information, fulfill orders or get in touch with users, if necessary, to solve problems. Financial information is used to check the user's qualifications and bill the user for products and services ordered by the user.

(a) Linked Sites and Affiliates:

Personal information collected from Gold Line's affiliates, agencies and related institutions may also be combined with information obtained online at Gold Line's website or at any of Gold Line's customer service centers. Personal information collected may also be transferred both domestically and internationally to enable Gold Line to more effectively manage its customer information and to provide more efficient service tailored to the unique needs of its customers.

b) "Cookies":

Gold Line uses "cookies" to electronically collect information about the individuals who access the Gold Line website. Information collected via "cookies" includes the response rate to banners that appear on our site, the service provider of the individuals accessing the site as well as their browser type (e.g. Netscape, Explorer, etc), and other statistical information regarding your usage of our services. Such information allows Gold Line to assess the effectiveness of certain promotions and special offers available on the Gold Line website and to further accommodate the site to better suit the needs of the individuals who use it and help us improve the services available.

Use of Personal Information:

(a) By Gold Line:

Personal Information collected by Gold Line will be used to deliver services provided by Gold Line to its customers, verify customer identity, ensure proper billing information and measure customer interest in various services. Personal information may also be used by Gold Line or its affiliated or related companies to contact the customer regarding customer service issues, surveys, marketing or about special offers or promotions that may interest the customer.

Gold Line may use customer identifiable information to investigate and help prevent potentially unlawful activities that threaten the integrity of service or the network, or otherwise violate Gold Line’s terms and conditions.

Except as provided herein, Gold Line will not collect, use or disclose any personal information without first obtaining the consent of the individual customer to such collection use and disclosure. Gold Line will make every reasonable effort to ensure that the individual is advised of the purposes for which the personal information will be used. Further, Gold Line will only use the personal information for the purposes for which it was originally collected.

Except as provided herein, Gold Line will never use personal information collected for a purpose other than the one under which it was originally collected without first obtaining consent of the individual for such alternate use. Furthermore Gold Line will not release any personal information of a sensitive nature (i.e. gender, race, nationality, etc.) without the express consent of the individual to such release.

(b) Disclosure to Third Parties:

Except as provided herein, Gold Line will not share the personal information of its customers with third parties except where such disclosure is consented to and except where such disclosure is necessary in responding to the customer's request for products or services. In such cases and where ever possible Gold Line will request consent to third party disclosure at the time the personal information is collected.

(c) Disclosure required by law or under special circumstances:

Gold Line will access, collect and/or disclose personal information where required to do so by law pursuant to a search warrant, court order or other valid legal request, or under special circumstances where there exists a good faith belief that such access, collection and/or disclosure are warranted. Examples of such special circumstances of collection and disclosure include medical or security reasons. Gold Line may also disclose personal information to collection agencies for the purposes of collecting on accounts owing to Gold Line.

Control of Personal Information and withdrawing Consent:

Any individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The individual will be informed of the implications of such withdrawal on services provided by Gold Line or its affiliates as applicable.

Mobile App Contacts Usage:

This part of the privacy statement describes how GLTalk collects and uses the contact information you provide by granting the contacts access permission in the GLTalk Mobile Application (the “App”). It also describes the choices available to you regarding our use of your information and how you can access and update this information.

GLTalk may access the following personal information from your address book:

Contacts’ names
Contacts’ email
Contacts’ telephones
Contacts’ organization
Contacts’ postal address
Contacts’ birthday
Contacts’ gender

GLTalk uses this information to populate your Contacts data in the App.

To import your favorite contacts into the QuickDial list, if you also enable the “Busy Lamp Field” feature on a contact, the favorite contact’s number (URI) will be included in your SIP traffic, but will not be stored anywhere.

Enable the Smart Contacts feature, which helps you to make free calls and enjoy seamless communication with other users with SIP accounts on the same provider.

If your SIP account is configured to use the Smart Contacts feature, we securely upload your contacts to the server in order to recognize GLTalk Application users among your contacts.

We will only use your Contacts information for the specific reason for which it was provided to us.

You can execute your right to erase the collected contact data by uninstalling the GLTalk application at any time.

For any questions regarding contact information usage in the GLTalk application, please contact Support by sending an email to support@gltalk.com.

Accuracy of and Access to Personal Information:

Gold Line strives to keep the personal information of its customers accurate, up-to-date and complete for the purposes for which it is to be used. In this regard Gold Line customers can access their personal information at any time by contacting Gold Line's Customer Service and submitting a written request for such access. Gold Line will provide the individual with particulars as to the disclosure of his/her personal information and shall provide the individual with access to that information. The individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

To gain access to personal information held by Gold Line the individual making the request will be required to provide sufficient information to permit Gold Line to provide an account of the existence, use and disclosure of the personal information. In particular, verification of identity by user identification or password will be required before access to personal information is granted.

Safeguards for Protection of Personal Information:

Protection of personal information is of paramount importance to Gold Line. As such Gold Line has implemented security safeguards to protect personal information against loss, theft, and unauthorized access, disclosure, modification or use. Such safeguards include:

       restricted access to offices and records;

       security clearance measures and limited access on a "need-to-know" basis; and

       use of passwords and encryption for access to records;

Access to personal information by Gold Line employees is restricted to that which is necessary to perform their duties. Gold Line employees are aware of the importance of maintaining the confidentiality of personal information and are committed to that end.

Any personal information collected by Gold Line shall be retained only as long as necessary for the fulfillment of the purpose for which it was collected. Personal information that is no longer required to fulfill the identified purpose will be destroyed, erased or made anonymous. Gold Line will take all reasonable care in the destruction of or disposal of personal information to prevent unauthorized parties from gaining access to the information.

Children

We do not provide content on our Websites which are intended to attract or encourage the participation of children. We do not solicit or knowingly accept information from persons under the age of 18.

Complaints and Enforcement of Privacy Statement:

As part of Gold Line's commitment to protection of its customers' personal information and privacy, Gold Line welcomes comments, concerns and feedback regarding its adherence to its Privacy Statement. Gold Line is committed to addressing and resolving in a timely manner any complaints or inquires about our policies and practices relating to the handling of personal information. Accordingly, any complaints or inquires should be directed to:

Email: support@gltalk.com
Mail: c/o The Group of Gold Line
300 Allstate Parkway
Markham, Ontario L3R 0P2
Canada.

All complaints received by Gold Line will be investigated and if justified, Gold Line will take the appropriate measures, including if necessary, amending its policies and practices, to resolve the complaint.

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