BRAVO TELECOM is strongly committed to respecting and protecting your privacy, we take seriously the obligations to protect all personal information in our possession. This Privacy Policy outlines how BRAVO Telecom deals with personal information.

Definitions

In this Policy:

BRAVO, WE or US means BRAVO TELECOM.

- Glossary of terms

Collection means the act of gathering, acquiring, or obtaining personal information through BRAVO TELECOM’s website, by email, in person, by phone, or by mail or through any other source or means, including third parties.

Disclosure means making personal information available to a third party.

Personal information means information about an identifiable individual in any form, including, for example: name, age, contact information, previous phone numbers and credit information. Personal information does not include the business contact information of an individual, information about corporate or commercial entities, information exempted under PIPEDA, or information that cannot be associated with a specific individual.

PIPEDA means the federal Personal Information Protection and Electronic Documents Act.

Third Party means an individual or organization other than BRAVO TELECOM and the customer.

Privacy Officer means an individual designated by BRAVO TELECOM who is accountable for BRAVO TELECOM's compliance with this Policy.

Use means the treatment and handling of personal information by and within BRAVO TELECOM.

Accountability

BRAVO TELECOM will adopt policies and procedures to protect personal information, receive and respond to complaints and inquiries by providing information regarding these policies and procedures in an accessible format, and train its staff regarding these policies and procedures.

BRAVO TELECOM assumes responsibility for personal information in its possession or custody, and this responsibility extends to information that is communicated to a third party for processing purposes. Our clients and partners have obligations to consumers when accessing personal information from us or providing personal information to us. BRAVO TELECOM enters into arrangements so as to ensure that the requisite level of protection is afforded to personal information being processed by a third party and that third parties comply with applicable laws and obtain any necessary consents.

Identifying Purposes

BRAVO TELECOM is in the business of providing you a long distance call alternative with a VoIP telephony services, and collects such personal information as is necessary to provide these services.

The following are the particular purposes for which BRAVO TELECOM collects personal information (identified purposes):

-Providing its services and products to customers;

-Maintaining commercial relations and communicating with customers (e.g. regarding billing, advertising and promotions);

-In connection with a transfer, sale, financing or reorganization of BRAVO Telecom or its assets;

-Managing its operations;

-For specific purposes identified at the time of collection;

-Identifying customers needs and preferences;

-Satisfying legal and regulatory requirements.

If BRAVO TELECOM intends to use personal information that was previously collected for a purpose or purposes other than those set out above, BRAVO TELECOM will identify and explain the new purpose prior to its use. BRAVO TELECOM will obtain consent for the use of information for a new purpose prior to its use unless the new purpose is required by law or its use comes under the exceptions noted below.

On occasion, BRAVO TELECOM will communicate special bonuses and/or new product offers to you that may be of interest. As a BRAVO TELECOM customer, you are entitled to opt-out of receiving such information from BRAVO TELECOM; if you would prefer not to receive direct marketing materials of this nature, please inform us in writing at the following address:

Privacy Officer

BRAVO TELECOM.

5960 Jean Talon East Bur 204

Saint Leonard, Qc, Canada, H1S 1M2

This e-mail address is being protected from spambots. You need JavaScript enabled to view it

BRAVO TELECOM will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that which is required in order for BRAVO TELECOM to meet its stated purposes.

BRAVO TELECOM’s website may contain links to other sites that are not governed by this Privacy Policy. BRAVO TELECOM provides these links to customers only as a convenience; their presence does not signify or imply any endorsement or verification of these sites or the products and/or services advertised by those sites. BRAVO TELECOM assumes no responsibility for the collection, use and/or disclosure of personal information obtained on such other sites, and expressly disclaims any and all liability related to the collection, use or disclosure of such information.

Consent

An individual’s consent can be express or implied, or it may be given through an authorized representative (such as a legal guardian) or agent. Consent may be provided orally, in writing, or electronically. The form of consent sought by BRAVO TELECOM may vary, depending upon the circumstances, the type and sensitivity of information disclosed, and the reasonable expectations of the person about whom it collects personal information. BRAVO TELECOM will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate when the information is less sensitive. The use of products or services by a customer will be considered implied consent to the collection, use and disclosure of personal information for the particular purposes identified above. In some cases, consumers will not provide consent directly to BRAVO TELECOM, but to one of our agents. We work with our agents to make them aware of the importance of obtaining consumer consent prior to providing BRAVO TELECOM with personal consumer information.

An individual may withdraw consent at any time by providing BRAVO TELECOM with notice in writing, subject to any applicable legal or contractual restrictions. BRAVO TELECOM will inform the individual of the associated implications, including the fact that if consent is withdrawn, BRAVO TELECOM may be unable to process requests for certain products and services.

BRAVO TELECOM may also seek out personal information from third parties, including credit bureaus, existing or former employers, personal references, and other third parties who represent that they may disclose personal information about our customers.

Customers may visit BRAVO TELECOM’s website anonymously without revealing any personal information. When a customer visits the site, his or her IP address is collected by BRAVO TELECOM, so that the website can determine where to send the information that is being requested; this IP address does not identify a customer personally. Personal information is obtained through BRAVO TELECOM’s website only by the knowing and consenting supply of that information by a customer.

BRAVO TELECOM’s website uses cookies, which are files sent to your web browser from BRAVO TELECOM’s website and stored on your computer’s hard drive. These cookies are small text files which contain a unique identification number associated with your computer, to allow BRAVO TELECOM to collect aggregated, anonymous information on the use of its website (for example, which pages were visited, what content was downloaded, and the type of web browser employed). Cookies allow BRAVO TELECOM to track visitors to its site and compile related statistics and, in turn, enable BRAVO TELECOM to improve customers online experience and to monitor the site’s operation. BRAVO TELECOM does not collect personal information through the use of cookies on its website. The use of cookies is an industry standard and, in fact, is common across many industries. Customers may choose to configure their web browsers so as to reject all cookies or to notify the customer when a cookie is sent. Although customers need not accept cookies to visit BRAVO TELECOM’s website, the site’s functionality may be compromised. If cookies are not accepted, some features may not work properly.

Personal information will only be used or disclosed for the identified purposes and as authorized by PIPEDA and other applicable laws, except with an individual’s consent or as required or permitted by law, or in the circumstances described above.

There are some situations in which BRAVO TELECOM may disclose personal information about a particular customer to third parties. For example, BRAVO TELECOM may disclose information to the following parties:

- another telecommunications company, regarding the provision of services to a customer;

- companies providing communications directory services;

- persons involved in marketing or developing BRAVO TELECOM’s services;

- credit collections agencies;

- emergency services;

- people who are an agent of the customer, as reasonably determined by BRAVO TELECOM;

- third party affiliates of BRAVO TELECOM that fulfil certain administrative purposes on BRAVO Telecom’s behalf, such as billing; and any other third party, with the customer’s consent or as required by law.

Note that some of these parties to whom information may be disclosed may be located outside of Canada. If BRAVO Telecom believes that a third party is using personal information in a manner that does not comply with applicable laws, industry codes or contracts, BRAVO TELECOM will pursue corrective action, up to and including termination of the relationship.

Limiting Use, Disclosure and Retention

BRAVO TELECOM will retain personal information only for as long as is necessary for the fulfillment of the identified purposes or as otherwise permitted or required pursuant to applicable legislation. BRAVO TELECOM will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. BRAVO TELECOM will take due care when destroying personal information so as to prevent unauthorized access to the information. In any event, BRAVO TELECOM will retain personal information used to make any decisions about an individual for the requisite period of time in order to allow that individual access to the information after a decision has been reached; information will be retained long enough, should an access request or a challenge to that decision be brought, so that any recourse available at law may be fully exhausted.

BRAVO TELECOM will make reasonable efforts to ensure that the personal information it is using or disclosing is accurate and complete. BRAVO TELECOM undertakes to ensure that information will be sufficiently accurate and current so as to minimize the likelihood of outdated information being used in connection with any decision to be made about a particular individual. BRAVO TELECOM will not update personal information on a routine basis, unless doing so is required in order to fulfil the purposes for which that information was obtained. The extent to and speed at which personal information will be updated depends on the nature and use of that information.

In some cases, BRAVO TELECOM relies on third parties who in turn rely on you to ensure that certain personal information is current, complete and accurate. Where an individual demonstrates satisfactorily to BRAVO TELECOM that his or her personal information is inaccurate or incomplete, BRAVO TELECOM will amend the information, as required. If BRAVO TELECOM considers it appropriate, it will transmit the revised information to third parties who may access that information.

Safeguards

We take the protection of personal information seriously. BRAVO TELECOM protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. The safeguards employed are chosen to reflect the relative sensitivity of the information in question, the distribution and format of the information, and the method and location of storage of the information. These safeguards include:

Ø Physical measures, such as locked filing cabinets;

Ø Organizational measures, such as restricting employee access to files and databases as appropriate;

Ø Electronic measures, such as passwords and firewalls;

Ø Regular reviews of processes in place to safeguard personal information; and

Ø Investigative measures, where BRAVO TELECOM has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

BRAVO TELECOM is committed to refining its technological security features and introducing new features as they become available and reliable. However, the state of current technology is such that BRAVO TELECOM cannot ensure that its system is entirely sufficient or impermeable, and as such makes no warranties or representations to that effect. BRAVO TELECOM will not assume liability for any damages or liabilities (actual or consequential) that may result from security breaches or technical difficulties that in turn lead to a breach of this Privacy Policy, including those arising as a result of BRAVO TELECOM’s negligence.

BRAVO TELECOM communicates to its employees the critical importance of ensuring the confidentiality of all personal information in its control or possession, and its employees are governed by non-disclosure obligations that prohibit disclosure of any personal information for purposes other than the stated purposes. BRAVO TELECOM will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to you.

BRAVO TELECOM is open about the policies and procedures it uses to protect your personal information. This Privacy Policy can also be accessed online on BRAVO TELECOM’s website

www.bravotelecom.com.

To ensure the integrity of our security procedures and business methods, BRAVO TELECOM will not disclose sensitive information about its policies and procedures, nor will it disclose commercial information which it considers to be confidential.

Individual Access

Upon written request and authentication of identity, BRAVO TELECOM will confirm whether it possess information about an individual and will provide information regarding the collection, use and disclosure of that individual’s personal information and grant the individual access to that information, providing a reasonable opportunity to review his or her file. The accuracy of such information may be challenged and/or updated by that individual, and it will be amended as appropriate. The written request or application must contain sufficient information to enable BRAVO TELECOM to provide an account of the existence, use and disclosure of this information to third parties.

Typically, BRAVO TELECOM will provide the pertinent personal information at no cost, depending on the nature and extent of the request. However, BRAVO TELECOM reserves the right to impose a cost in appropriate circumstances; should a cost be imposed, BRAVO TELECOM will communicate the approximate cost to the individual and will await payment before proceeding. BRAVO TELECOM is committed to providing any requested information in a format that is accessible and easily understandable.

In response to any requests seeking further details regarding disclosure of personal information to third parties, BRAVO TELECOM will provide as much detail and information as is reasonably possible. Where BRAVO TELECOM cannot provide a fulsome list of the third parties to whom it has disclosed the relevant personal information, it will provide a list of the third parties to whom it may have disclosed such information.

In some situations, BRAVO TELECOM may not be able to provide access to certain personal information. This may be the case where, for example: disclosure would reveal personal information about another individual or sensitive commercial information and that information cannot be severed; the personal information is protected by solicitor-client or litigation privilege or would be prohibitively costly; the information was collected for the purposes of an investigation relating to investigation of a breach of an agreement or contravention of a law; or the information was generated in the course of a formal dispute resolution process. BRAVO TELECOM may also be prevented by law from providing access to certain personal information. Where possible, BRAVO TELECOM will disclose the reasons for denying access to an individual upon written request.

Challenging Compliance

Where an individual is unsatisfied with BRAVO TELECOM’s response to a challenge or a request for information, BRAVO TELECOM will record details of that challenge in the individual’s file.

BRAVO TELECOM has in place certain procedures in order to receive and respond to inquiries and complaints regarding its Privacy Policy and compliance therewith. BRAVO TELECOM will, on request, provide customers with information regarding its complaint procedures. Any inquiries, complaints or questions regarding this Policy, or compliance with the principles outlined herein, should be directed in writing to the BRAVO TELECOM Privacy Officer. Alternatively, you may also seek advice from the Office of the Privacy Commissioner of Canada, who may be contacted by mail or by phone but no longer by e-mail at:

By phone: 1-800-282-1376

By mail:

The Privacy Commissioner of Canada

112 Kent St., Place de Ville, Tower B, 3rd Floor

Ottawa, ON

K1A 1H3

BRAVO TELECOM may amend this Policy from time to time. It is your responsibility to review this Policy to check for updates.

BRAVO TELECOM has designated a Privacy Officer who is accountable for BRAVO TELECOM’s compliance with this Policy. The Privacy Officer may be reached at:

Privacy Officer

BRAVO TELECOM.

5960 Jean Talon East Bur 204

Saint Leonard, Qc, Canada, H1S 1M2

This e-mail address is being protected from spambots. You need JavaScript enabled to view it

Right to modify this policy

BRAVO TELECOM reserves the right to add, modify, or remove any section of this document in order for it to remain representative of BRAVO TELECOM's business operations and continue to be compliant with P.I.P.E.D.A.

You can determine when this policy was last updated by referring to the date marked at the bottom of this policy.

Last updated: 1^st December 2009