consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent sought by Medi-Quote Insurance Brokers may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, Medi-Quote Insurance Brokers takes into account the sensitivity of the personal information and the reasonable expectations of the individuals. Consent may be provided directly by an individual or by an authorized representative.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to Medi-Quote Insurance Brokers. The inclusion of independent contractors within the definition of “employee” is for convenience of reference only, and should in no manner imply that such independent contractors are employees of Medi-Quote Insurance Brokers within the meaning of employment legislation or are in an employee-employer relationship with Medi-Quote Insurance Brokers.

Medi-Quote Insurance Brokers: Medi-Quote Insurance Brokers IncTM and any subsidiaries, successor company or companies thereof, as a result of corporate reorganization or restructuring.

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

use: The treatment, handling, and management of personal information by and within Medi-Quote Insurance Brokers.

PRINCIPLE 1 – ACCOUNTABILITY

Medi-Quote Insurance Brokers is responsible for personal information under its control and shall designate one or more persons who are accountable for Medi- Quote Insurance Brokers’s compliance with this Privacy Code.
Medi-Quote Insurance Brokers is responsible for all personal information under its control and has designated the Medi-Quote Insurance Brokers Privacy Officer to oversee its privacy compliance. Other individuals within Medi-Quote Insurance Brokers may be delegated to act on behalf of the Medi-Quote Insurance Brokers Privacy Officer or to take responsibility for the day to day management of personal information.

As appropriate, Medi-Quote Insurance Brokers implements privacy policies and procedures to properly enforce this Privacy Code and Medi-Quote Insurance Brokers uses contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party or agent of Medi-Quote Insurance Brokers.

Medi-Quote Insurance Brokers has implemented privacy policies and procedures to give effect to this Privacy Code, including:
implementing privacy procedures to protect personal information and to oversee compliance with this Privacy Code;

establishing privacy procedures to receive and respond to inquiries or complaints; training employees about Medi-Quote Insurance Brokers’s privacy policies and procedures; and
developing publicly available information to explain Medi-Quote Insurance Brokers’s privacy policies and procedures.

PRINCIPLE 2 – IDENTIFYING PURPOSES FOR COLLECTION OF PERSONAL INFORMATION

Medi-Quote Insurance Brokers shall identify the purposes for which personal information is collected at or before the time such information is collected.
As part of our operations, Medi-Quote Insurance Brokers has collected and collects personal information for the following purposes:

to establish and maintain responsible relations with individuals;
to provide products and services to individuals;
to develop, enhance and market Medi-Quote Insurance Brokers’s products and services;
to understand individual’s needs in the areas of travel insurance;
to manage and develop Medi-Quote Insurance Brokers’s business and operations, including personnel and employment matters;
to conduct investigations relating to breaches of agreements or contraventions of laws;
to meet legal and regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Medi-Quote Insurance Brokers corporate reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Medi-Quote Insurance Brokers, provided that the personal information disclosed continues to be used by the entity acquiring the personal information either for evaluation of the possible transaction, or, on completion of any transaction, for the purposes permitted by this Privacy Code; or
to carry out any other purpose that an individual has authorized or that is required or permitted by law.
Further reference to identified purposes mean the purposes identified in this Principle.

PRINCIPLE 3 – OBTAINING CONSENT FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL INFORMATION

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain

circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.
Medi-Quote Insurance Brokers generally collects, uses, retains and discloses an individual’s personal information only with an individual’s knowledge and consent. Such consent may be obtained by a third party or agent of Medi-Quote Insurance Brokers. Medi-Quote Insurance Brokers may depart from this general consent principle only in accordance with the limited exceptions set forth in applicable laws such as PIPEDA (for example, Medi-Quote Insurance Brokers may collect personal information in the course of conducting an investigation where acquiring consent may compromise the accuracy or availability of personal information).

In obtaining an individual’s consent, whether express or implied, Medi-Quote Insurance Brokers will explain the purposes for which Medi-Quote Insurance Brokers will manage an individual’s personal information. Medi-Quote Insurance Brokers will not depart from these original and stated purposes unless an individual provides further consent or unless otherwise required or permitted by law.

Individuals may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. An individual’s may contact Medi-Quote Insurance Brokers for more information regarding the implications of withdrawing consent.

PRINCIPLE 4 – LIMITING COLLECTION OF PERSONAL INFORMATION

Medi-Quote Insurance Brokers shall limit the collection of personal information to that which is necessary for the purposes identified by Medi-Quote Insurance Brokers. Medi-Quote Insurance Brokers shall collect personal information by fair and lawful means.

In most cases, Medi-Quote Insurance Brokers will only collect personal information that is necessary for the purposes identified in this Privacy Code. Medi-Quote Insurance Brokers may collect personal information from other sources that represent that they have the right to disclose such information to Medi-Quote Insurance Brokers.

PRINCIPLE 5 – LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION

Medi-Quote Insurance Brokers shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Medi-Quote Insurance Brokers shall retain personal information only as long as necessary for the fulfillment of those purposes.

Medi-Quote Insurance Brokers will not disclose personal information for purposes other than those purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Medi-Quote Insurance Brokers may disclose an individual’s personal information:

when we have an individual’s consent, whether express or implied;
to third party agents or suppliers engaged by Medi-Quote Insurance Brokers to perform functions on our behalf;
to meet legal and regulatory requirements, including to protect or defend a legal interest, in connection with an actual or possible Medi-Quote Insurance Brokers corporate reorganization, merger or amalgamation with another entity, or natural or possible sale of all or a substantial portion of the assets of Medi-Quote Insurance Brokers; and
where required or permitted by law.
In such circumstances, Medi-Quote Insurance Brokers will not disclose more personal information than is required for the identified purposes. Medi-Quote Insurance Brokers will also, whenever it is reasonable and practicable to do so, enter privacy agreements with third parties with whom Medi-Quote Insurance Brokers discloses personal information.

Medi-Quote Insurance Brokers will retain personal information for a period of time only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law.

Depending on the circumstances, where personal information has been used to make a decision about an individual, Medi-Quote Insurance Brokers shall retain, for a period of time that is reasonably sufficient to allow for access by the individual, either the actual personal information or the rationale for making the decision.

Only those employees of Medi-Quote Insurance Brokers who require access for legitimate business reasons, or whose duties reasonably so require, are granted access to personal information.

Medi-Quote Insurance Brokers maintains reasonable and systemic controls, schedules and practices for personal information retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required or permitted by law to be retained. Such personal information is destroyed, erased or made anonymous as appropriate.

PRINCIPLE 6 – ACCURACY OF PERSONAL INFORMATION

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Medi-Quote Insurance Brokers makes reasonable efforts to ensure that the personal information it collects, uses or discloses is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. If an individual finds any errors in Medi-Quote Insurance Brokers’s personal information holdings, Medi-Quote Insurance Brokers should be informed and will make the appropriate corrections. Medi-Quote Insurance Brokers will convey these corrections to anyone that Medi- Quote Insurance Brokers may have misinformed. In circumstances where the

accuracy or completeness of personal information remains in dispute, Medi-Quote Insurance Brokers will make a note in its records of an individual’s opinion as to accuracy or completeness of the relevant personal information.

PRINCIPLE 7 – SECURITY SAFEGUARDS

Medi-Quote Insurance Brokers shall protect personal information by security safeguards appropriate to the sensitivity of the information.
Medi-Quote Insurance Brokers protects personal information against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Medi-Quote Insurance Brokers protects personal information regardless of the format in which it is held.

All employees of Medi-Quote Insurance Brokers with access to personal information are required as a condition of employment or engagement to respect the confidentiality of personal information and obligations set forth in this Privacy Code.

PRINCIPLE 8 – OPENNESS CONCERNING POLICIES AND PROCEDURES

Medi-Quote Insurance Brokers shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
Individuals should forward questions or concerns regarding Medi-Quote Insurance Brokers’s privacy practices to the Medi-Quote Insurance Brokers Privacy Officer.

PRINCIPLE 9 – ACCESS TO PERSONAL INFORMATION

Upon request, Medi-Quote Insurance Brokers shall inform an individual of the existence, use, and disclosure of his or her personal information and shall provide access to that information. An individual shall be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

An individual may request access to any personal information that Medi-Quote Insurance Brokers has concerning them by sending a written request to the Medi- Quote Insurance Brokers Privacy Officer. Medi-Quote Insurance Brokers may advise an individual in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days.

In accordance with PIPEDA and applicable laws and/or policies or procedures of Medi-Quote Insurance Brokers, we may not be able to provide personal information to an individual if doing so would violate the privacy of a third party or if certain personal information is subject to solicitor-client privilege, contains confidential commercial information or cannot be disclosed for other legal reasons. If Medi- Quote Insurance Brokers is unable to provide access to all or part of an individual’s personal information, we will explain our reasons for such a decision to the greatest extent permitted by law.

Personal information that is disclosed to third parties by Medi-Quote Insurance Brokers will be subject to the general laws of applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, Medi-Quote Insurance Brokers may not legally be permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, Medi-Quote Insurance Brokers shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the personal information. In providing an account of disclosure, Medi- Quote Insurance Brokers shall provide a list of organizations to which it may have disclosed personal information about an individual when it is not possible to provide an actual list.

In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit Medi-Quote Insurance Brokers to account for the existence, use and disclosure of personal information and to authorize access to an individual’s personal information. Any such information shall only be used for this purpose.

Where an individual has been provided with access to their personal information, they shall be able to challenge the accuracy and completeness of their personal information and have it amended as appropriate.

PRINCIPLE 10 – CHALLENGING COMPLIANCE

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Medi-Quote Insurance Brokers’s compliance with The Medi-Quote Insurance Brokers IncTM Privacy Code.

Questions or concerns regarding Medi-Quote Insurance Brokers’s privacy practices should be directed to the Medi-Quote Insurance Brokers Privacy Officer.

Medi-Quote Insurance Brokers will investigate all complaints concerning compliance with this Privacy Code and if a compliant is found to be justified, Medi- Quote Insurance Brokers shall take the appropriate measures to resolve the complaint including, if necessary, amending its privacy policies and procedures. Medi-Quote Insurance Brokers shall inform an individual of the outcome of an investigation regarding his or her complaint.

Additional Information
For more information regarding this Privacy Code or our privacy practices, please contact the Medi-Quote Insurance Brokers Privacy Officer at:

Medi-Quote Insurance Brokers Privacy Officer 505 Pandora Avenue West
Winnipeg, Manitoba

R2C 1M8

Phone: 204.947.9210
Toll Free Phone: 1.800.661.3098
Fax: 204.895.2918
E-mail: privacy@mediquote.ca
For additional information about your privacy rights, please visit the Office of the Privacy Commissioner of Canada’s Internet web site at www.priv.gc.ca.

MEDI-QUOTE INSURANCE BROKERS INC.

WEBSITE PRIVACY POLICY
Last Revised: September 10, 2009

This Internet Website Privacy Policy (this “Privacy Policy”) governs your access and use of the website located at www.mediquote.ca. Medi-Quote Insurance Brokers IncTM (“Medi-Quote Insurance Brokers”) owns and operates the services located at www.mediquote.ca (the “Site”).

IT IS IMPORTANT THAT YOU CAREFULLY READ THE FOLLOWING.

1. Acceptance of Terms
By accessing and continuing to use the Site, and by providing certain Personal Information (as hereinafter defined) to Medi-Quote Insurance Brokers through the Site, you are indicating your acceptance to be bound by the terms and conditions of this Privacy Policy. If you do not accept these terms and conditions, please do not access or use the Site, or provide Personal Information through the Site.

2. Modifications and Notices
Medi-Quote Insurance Brokers may revise this Privacy Policy, at any time, by updating this posting. Medi-Quote Insurance Brokers may provide notice to our users of such revisions by means of a general notice on the Site. Continued use of the Site after such revisions are posted will signify your agreement to these revised terms. Therefore, you should visit this page periodically to review this Privacy Policy.

3. Medi-Quote Insurance Brokers Respects Your Privacy
Medi-Quote Insurance Brokers is committed to protecting the privacy of all of our users to the Site and maintaining the integrity of any personally identifiable information (“Personal Information”) that we collect, use, retain or disclose via the Site. The purpose of this Privacy Policy is to inform you about how and why we collect Personal Information on the Site, to outline the steps we take to safeguard

your Personal Information, and to provide you with Medi-Quote Insurance Brokers contact information should you have any questions or concerns about our privacy practices.

In addition, Medi-Quote Insurance Brokers has adopted a more comprehensive organizational Privacy Code, which is available upon request.

4. General Information
The Site provides information intended to promote Medi-Quote Insurance Brokers’s products and services. Our Internet servers may passively and automatically collect certain information about website visitors’ traffic patterns, which may be linked to their Internet Protocol (IP) addresses (which are unique Internet addresses assigned to all Internet users by their Internet Service Providers). Server logs may record statistical information, such as visitors’ IP addresses, type of operating systems, time and duration of visit, pages requested, and identify categories of visitors by items such as domains and browser types. These statistics are generally collected and used on an aggregate basis.

The Site may contain links to other websites that are provided as a convenience only, and which may have different privacy policies and practices than Medi-Quote Insurance Brokers. Medi-Quote Insurance Brokers has no responsibility for such third party websites, and we encourage you to review the privacy policies of any third party websites you choose to visit.

5. Why does Medi-Quote Insurance Brokers collect your Personal Information? In the course of operating the Site, Medi-Quote Insurance Brokers has collected and collects Personal Information from individuals for the following purposes:

to establish and maintain responsible relations with individuals;
to provide products and services to individuals;
to develop, enhance and market Medi-Quote Insurance Brokers’s products and services;
to understand individual’s needs in the areas of travel insurance;
to manage and develop Medi-Quote Insurance Brokers’s business and operations, including personnel and employment matters;
to conduct investigations relating to breaches of agreements or contraventions of laws;
to meet legal and regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible Medi-Quote Insurance Brokers corporate reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of Medi-Quote Insurance Brokers, provided that the personal information disclosed continues to be used by the entity acquiring the personal information either for evaluation of the possible transaction, or, on completion of any transaction, for the purposes permitted by this Privacy Code; or

to carry out any other purpose that an individual has authorized or that is required or permitted by law.
Further reference in this Privacy Policy to “Identified Purposes” means the reasons set forth above.

6. Does Medi-Quote Insurance Brokers disclosure your Personal Information? Medi-Quote Insurance Brokers does not disclose Personal Information to third parties for purposes other than those for which it was collected, except with your consent or as required or permitted by law. In situations where we disclose Personal Information in accordance with this Privacy Policy to third parties, we do not disclose more information than is required and, where it is reasonable and practical to do so, enter privacy agreements with third parties with whom we disclose Personal Information.

7. How does Medi-Quote Insurance Brokers safeguard your Personal Information?
Medi-Quote Insurance Brokers protects Personal Information against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Medi-Quote Insurance Brokers protects Personal Information regardless of the format in which it is held. All employees of Medi-Quote Insurance Brokers with access to Personal Information are required as a condition of employment or engagement to respect the confidentiality of Personal Information and obligations set forth in this Privacy Policy.

8. Your Consent/Verifying and Amending Personal Information
You may withdraw your consent for Medi-Quote Insurance Brokers to manage your Personal Information in a particular way, subject to legal or contractual restrictions and reasonable notice. However, this may limit our ability to provide you with certain services and/or products. You may contact Medi-Quote Insurance Brokers for more information regarding the implications of withdrawing consent.

You can typically access and review your Personal Information held by Medi-Quote Insurance Brokers and make appropriate changes to it by contacting Medi-Quote Insurance Brokers. You may be required to put your request in writing and show us identification. The reason we ask for identification is to ensure that, among other things, we do not unintentionally change or release your Personal Information to a third party who is representing him/her as you.

For more information regarding this Privacy Policy, please contact the Medi-Quote Insurance Brokers Privacy Officer at:

Medi-Quote Insurance Brokers Privacy Officer 505 Pandora Avenue West
Winnipeg, Manitoba
R2C 1M8

Phone: 204.947.9210
Toll Free Phone: 1.800.661.3098 Fax: 204.895.2918
E-mail: privacy@mediquote.ca

You may update or make changes to your Personal Information maintained by us by writing or e-mailing to Medi-Quote Insurance Brokers at the addresses provided above. In addition, you may request access to, or correction of, your Personal Information by writing or e-mailing to Medi-Quote Insurance Brokers at the addresses provided above.

9. Resolving Your Concerns
If you would like more information about Medi-Quote Insurance Brokers’s privacy practices including a copy of the Medi-Quote Insurance Brokers IncTM Privacy Code, or if you would like to better understand and verify what Personal Information we have collected about you, please contact the Medi-Quote Insurance Brokers Privacy Officer. Please let us know about your questions or concerns and we will do our best to help you.