Privacy

Accountability

Trader Corporation and its subsidiaries (collectively "TRADER", "we", "us") has a firm commitment to protecting the personal information of the individuals we deal with. Information, which can identify an individual ("personal information"), is often required to provide contact information for advertisers in our electronic and print photo classified publications, for business transactions and for customer relationship management purposes. This Policy applies to the personal information we collect about our customers, advertisers and suppliers in Canada and describes how we use and share this information. It also describes how we maintain and secure personal information and how the individual concerned may request access to it. This Policy does not apply to TRADER employee personal information or to information that does not qualify as "personal information" under applicable legislation in Canada.

Information Collection

TRADER collects personal information that may include:

• Contact information, which typically includes such information as an individual's name, address, telephone numbers, e-mail address, and fax number. In some circumstances, some of this information may be business information which is not covered by this Policy;
• Business information, which typically includes business contact information (such as name, telephone number, address). To the extent that this information is personal information under applicable legislation, it is governed by this Policy;
• Financial information, which includes information such as account payment history and status and credit information; and
• Other information provided by our individual customers or suppliers, including such information as an individual provides to participate in a contest offered by us, in response to a survey we may conduct, in subscribing to receive information from a Web site operated by us or in contacting us to obtain information on our services.

We collect personal information primarily from the individual concerned; however, we also collect contact information from our affiliates and from third parties, such credit bureaux and reporting agencies (who provide us with business and credit-related information).

Use and Disclosure of Information

TRADER will generally collect and use personal information for the following purposes:

• To evaluate and fulfil a request for our products, programs and services;
• For publication purposes or for posting on the Websites operated by TRADER, such as autotrader.ca, buysell.com, employmentnews.com, hospitalnews.com, agbuyersguide.ca and hometrader.ca (the "TRADER Websites");
• For sales and lead potential and for marketing purposes, for customer relationship management purposes;
• To administer participation in contests;
• To evaluate responses to surveys;
• To respond to inquiries for information about TRADER and its services;
• To ascertain and verify creditworthiness and share credit information with credit rating agencies;
• To administer, service and collect on accounts;
• In certain circumstances, to grant access to its customers to information on their own accounts;
• To process requests for the removal or correction of information from our files;
• To meet legal, regulatory, security and processing requirements; and
• To contact customers with marketing or promotional materials regarding TRADER products, programs and services or to assist its front-line staff in providing tailored sales offers to customers.

TRADER may exchange or merge personal information with data obtained from third parties for the same purposes. If an individual does not want us to use his/her contact information for marketing purposes, this person should exercise his/her option to opt out of this use by indicating his/her wishes by contacting privacy@trader.com.

Personal information may be shared from the TRADER Websites to third parties in the form of sales leads–which is a core service provided by TRADER through its websites. The info is entered into the online form and then emailed to the auto dealer or real estate agent. Furthermore, TRADER discloses information to Mosaic Sales Solutions Canada Operating Company for the purposes of ROI analysis and for consumer and advertiser research and strategy development. Our written agreements with such agents and contractors ensure that personal information can only be used for the purposes for which it was shared with the agents and contractors, and that the agents and contractors handle the personal information in accordance with this Policy.

In a context where all or part of TRADER's assets or business are or may be sold, financed, insured, securitized, assigned or otherwise disposed of, we may also disclose personal information to the companies involved in such a transaction, for the purposes of allowing those companies to decide whether to proceed with the transaction and, where applicable, to provide the products, programs and services that TRADER would otherwise provide and generally to carry on the TRADER business.

As part of our commitment to enhance our business services, TRADER may identify other uses and disclosures for personal information in the future. In that event, we will seek the consent of the individuals concerned where required.

Collection of Information Online

Some TRADER Websites registration forms require users to provide TRADER contact information (such as name and email address) and demographic information (such as postal code, age, or income level) and other information that is used by TRADER to provide services. TRADER uses the customer contact information from the registration forms to send the user information that he or she has requested regarding the TRADER Websites or regarding services offered by TRADER.

Some TRADER Websites use an ad form for customers to place online and/or print ads. One of the express purposes of the TRADER Websites is to gather contact information provided voluntarily by customers to be published either online or in print, as the case may be, and in connection with items that are for sale by customers. TRADER has no control over who views online or print ads. Contact information provided may be used to contact customers when necessary. TRADER collects customers' financial information (such as account or credit card numbers) to bill the user for products and services, but retains this information only as required to process the transaction and for as long as may be required by law.

Demographic and profile data is also collected on the TRADER Websites. TRADER uses this data to tailor each visitor's experience at the TRADER Websites, showing the user content that TRADER thinks he or she might be interested in, and displaying the content according to the user's preferences.

TRADER's online surveys ask visitors for contact information (such as email addresses) and demographic information (such as postal code, age, or income level). TRADER uses contact data from its surveys to send users information about our products and services. The TRADER Websites provide users the opportunity to opt-out of receiving communications from TRADER at the point where contact information is requested. Individuals also have the ongoing option of removing their contact information from our database so that they will not receive future communications or no longer receive service offered through the TRADER Websites.

If an individual decides not to provide us with personal information online, no material consequences will result, although this individual may be unable to participate in certain promotions, receive product information, or use portions of the TRADER Websites that require personalized information or applications.

TRADER may use software that receives and records the Internet Protocol (IP) address of the computer that has contacted the TRADER Websites. TRADER makes no attempt to link these addresses with the identity of individuals visiting the TRADER Websites.

TRADER Websites may use cookies to track user traffic patterns. A cookie is a small data file that certain Websites write to your hard drive when you visit them. A cookie file can contain information such as a user ID that the site uses to track the pages you've visited, but the only personal information a cookie can contain is information you supply yourself. A cookie can't read data from your hard disk or read cookie files created by other sites. TRADER does not correlate this information with data about individual users, nor does it share this information or sell it to any third party. TRADER uses this data to tailor the visitor's experience at the TRADER Websites, showing them content that we think they might be interested in, and displaying the content according to their preferences, to measure the use of our site and to improve the content of our sites. If you prefer not to receive cookies from the TRADER Websites, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. This could affect the areas of the TRADER Websites that are accessible to you.

TRADER may also use service providers to service third party's advertisements on our Websites or TRADER advertisements on other websites. In serving advertisements, these providers may place cookies on your browser computer and may collect certain anonymous information about your visits to other websites. This information may include browser type, IP address, domain name and the name of the webpage from which you entered our site, web activity and time of day. To opt-out of these cookies, please review the privacy policies of those websites and follow the instructions thereon. We may prepare aggregated user statistics or information summaries in order to describe our services to third parties such as prospective business partners and advertisers and for other lawful purposes.

There are links on the TRADER Websites which take you to other websites beyond our service. Any links provided to third party websites are provided solely for your convenience or to provide you with resources which are designed to assist and inform you with buying and selling various products and services. TRADER is not responsible for the privacy practices or the content of such third party websites. The operation and content of such websites is beyond our control. We do not endorse, in any manner whatsoever, or accept any responsibility for the information, content or other material which may be contained on such websites.

Your Consent

By providing us with your personal information, you consent to our collection, use and disclosure of that information as described in this Policy as amended from time to time or as described at or before the time of collection, use or disclosure, as the case may be. If you do not want your personal information to be collected, used or disclosed in this manner, then please either (1) do not submit your personal information to us, (2) exercise opt-out procedures described above or as may be offered at the time of collection, or (3) refrain from exercising opt-in procedures described above or as may be offered at the time of collection. If you have submitted personal information to us and wish to withdraw your consent to its retention, use or disclosure, please send an e-mail to privacy@trader.com. You may withdraw your consent, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent, we may not be able to provide some products or services to you.

Where permitted or required by law, TRADER may collect, use or disclose your personal information without your consent, for example, to collect a debt you owe us, to comply with a legally permitted inquiry by a government agency, or to comply with a court order.

Information Safeguards and Retention

TRADER will establish files containing personal information for the purposes outlined in this Policy. We use physical, organisational and technological safeguards to protect your personal information against theft, loss or unauthorized access, use, modification, disclosure or disposal. Authorized employees and agents of TRADER have access to this information, which will be accessible at our premises and those of our agents.

Generally speaking, you can visit the TRADER Websites without revealing personal information. However, given that electronically submitted data is not 100% secure, we make no warranties as to the security of any personal information you submit online, which you do at your own risk.

If links are provided from the TRADER Websites to sites of third parties, TRADER is not responsible for these third parties' policies or how they treat information about their users. We therefore encourage you to review the privacy policies of these websites before disclosing your information to any third party.

Policy Changes

We reserve the right to change and update the Policy and these changes will be made when appropriate, in a timely manner. We encourage you to examine our Policy from time to time to ensure you are aware of any changes we may have made.

Access and Correction

We attempt to keep files containing personal information as complete, up-to-date, and accurate as necessary for the identified purposes. Upon written request, TRADER will provide you access to your personal information, subject to certain exceptions as provided by the applicable legislation. If you notice any errors or omissions in your personal information, please notify us in writing and we will promptly correct them where appropriate.

Contact

If you have questions or complaints regarding our Policy, the security of your personal information or our compliance with the applicable personal information protection legislation, or if you wish to request access to or correction of your personal information, please contact our Privacy Officer via e-mail at privacy@trader.com or by sending a note explaining your request/complaint to the following address:

Privacy Officer

TRADER CORPORATION
16 Place du Commerce
Ile des Soeurs
Verdun, Quebec, H3E 2A5

Last update: March 9, 2011