With the continued rise of both consumers and businesses on the Internet, concern about privacy and the security of information has been brought to the forefront of public debate. The Spearhead Management Canada Ltd. commitment to privacy has evolved with technology, and with recent guidelines and discussions that pertain to collection, use and disclosure of this information.

SPEARHEAD MANAGEMENT CANADA LTD. is committed to recognizing the highest standards in all our services.

Accountability

Spearhead Management Canada Ltd. is responsible for the information under its control, and has designated an individual or individuals who are accountable for our compliance with these principles, and to any policies adopted.

Collection of Information

The collection of personal information will be limited to that which is necessary for the purposes identified by SPEARHEAD MANAGEMENT CANADA LTD., and all information will be collected by fair and lawful means.

Use, Disclosure and Retention

Personal information is not used or disclosed by SPEARHEAD MANAGEMENT CANADA LTD. for purposes other than those for which it was collected, except with the expressed consent of the consumer or as required by law. SPEARHEAD MANAGEMENT CANADA LTD. only uses and discloses personal information about consumers to unrelated third parties after the buyer has been informed in advance of the possibility of such use and disclosure, and has been given the opportunity to decline. Personal information is retained only as long as is necessary for the fulfillment of those purposes or as required by law.

SPEARHEAD MANAGEMENT CANADA LTD. executes accurate record keeping procedures. Consumers are also encouraged to provide accurate information when using the service.

SPEARHEAD MANAGEMENT CANADA LTD. has developed procedures to safeguard consumers' personal information, appropriate to the sensitivity of the information provided. This includes protecting the access to, use, disclosure, retention and disposal of personal information.

SPEARHEAD MANAGEMENT CANADA LTD. will readily make available information about its policies and practices relating to the management of personal information.

Upon request, any consumer will be informed of the existence, use and disclosure of his or her personal information, and will be given access to that information.

Consumers Come First

SPEARHEAD MANAGEMENT CANADA LTD. recognizes the interest and concerns of the consumer in developing privacy and information management principles. SPEARHEAD MANAGEMENT CANADA LTD. remains flexible in responding to changing consumer needs and expectations regarding privacy as the transaction services business continues to evolve.