BUTTER AND EGG ROAD INC.

PRIVACY POLICY

Currency: January 26, 2013

At BUTTER AND EGG ROAD INC. (“Butter and Egg Road”, “we”, “our” or “us”), we are committed to protecting the privacy and the confidentiality of personal information of our members and potential members (“Customers”). In order to comply with applicable privacy legislation and to instil confidence in our Customers that the personal information they entrust to us is safe, we have developed this Privacy Policy. We want our Customers to know why we ask for their personal information, how we use it, what safeguards we employ and how to contact us with privacy-related questions.

In this Privacy Policy, “Personal Information” means information that specifically identifies a Customer as an individual and is provided to or collected by Butter and Egg Road. The type of personal information Butter and Egg Road collects, uses and discloses may include a Customer’s name, age, gender, purchase history, residential mailing address, residential phone numbers or email addresses, financial, credit and banking information. Personal Information does not, however, include a Customer’s business title, business address or business telephone number in such individual’s capacity as an employee of an organization or enterprise, or navigational information (which is anonymous and includes information such as your IP address, the type of browser you are using or the website you visited immediately prior to ours).

I.IDENTIFYING THE PURPOSES AND USE OF PERSONAL INFORMATION

Before collecting any Personal Information, Butter and Egg Road will identify why the Personal Information is required and how it will be used. This Personal Information is documented and kept on file at Butter and Egg Road’s offices at 3 Rowanwood Ave. Toronto Ontario, M4W 1Y5. Butter and Egg Road will obtain the Customer’s consent before using or disclosing Personal Information for purposes other than the original reasons given.

Butter and Egg Road collects and uses Customer’s Personal Information for the following purposes:

Collecting, recording and using Personal Information relevant to the performance of the services rendered to and for a Customer;
Opening an on-line account for a Customer and providing on-line services;
Protecting against fraud and error;
Recording and determining the services received by a Customer during his or her relationship with us;
Marketing our services;
Administration, billing, accounting and collection in relation to a Customer’s relationship with us;
Offering a Customer additional services which may be of interest to such Customer, and providing the Customer with a personalized experience;
Communicating with a Customer generally or to ensure Customer satisfaction;
Analysing trends, administering our website, tracking Customers’ preferences, gathering demographic information and conducting market research;
Improving the services offered to Customers in the future;
Communicating Personal Information to an agent, intermediary or other third party during the course of a contract or mandate for the performance of any of the purposes listed in this Privacy Policy;
Complying with all applicable laws; and
Such other specific purposes which are communicated to a Customer by Butter and Egg Road and its representatives before collection of the Personal Information.

We may use, share and disclose a Customer’s Personal Information to our affiliates, associates, agents, suppliers and such other third parties as Butter and Egg Road, acting reasonably, may deem necessary for the fulfillment of the purposes noted above or where otherwise permitted by law. In the unlikely event that Butter and Egg Road or substantially all of its assets are acquired by a third party, a Customer’s Personal Information may be one of the assets transferred to such third party and Butter and Egg Road may reasonably disclose such Personal Information to a prospective third party purchaser.

II.CONSENT

Except in certain extraordinary circumstances, Butter and Egg Road does not collect, use or disclose a Customer’s Personal Information without their knowledge and consent. Such extraordinary circumstances may include, without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent.

The Customer’s consent will be obtained at the time of collection of the Personal Information, or when a new use for the Personal Information is identified. A Customer may withdraw their consent at any time, subject to any legal or contractual restrictions and on the provision of reasonable notice to Butter and Egg Road. If a Customer chooses to withdraw his or her consent, he or she is required to do so in writing to the Chief Compliance Officer (please see section VII of this Privacy Policy). Any implications to withdrawing consent will be explained to the Customer at the time written notice of such withdrawal is received by Butter and Egg Road. Such implications may include, but are not limited to, a breakdown, interruption or cessation of Butter and Egg Road’s relationship with the Customer.

By retaining the services of Butter and Egg Road, Customers have consented to the disclosure of their Personal Information to a third party in the circumstances, or for the purposes, set out in this Privacy Policy.

III.LIMITING COLLECTION

Butter and Egg Road limits the collection of a Customer’s Personal Information to that which is necessary for the purposes identified in this Privacy Policy, or for any additional purpose identified to the Customer before collection of the Personal Information.

IV.LIMITING USE, DISCLOSURE AND RETENTION

Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Customer, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.

V.ACCURACY

Butter and Egg Road strives to ensure that Customer’s Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. Information is updated only when necessary to fulfill specified purposes. Customers should provide Butter and Egg Road with any updates to their Personal Information in writing to the Chief Compliance Officer (see section VII of this Privacy Policy) on a timely basis.

VI.SAFEGUARDS

Butter and Egg Road has security safeguards in place designed to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information under the care of Butter and Egg Road. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewalls to stop hackers, encryption software, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by Butter and Egg Road in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed.

E-mail is not a 100% secure medium, and Customers should be aware of this when contacting us to send Personal Information.

Butter and Egg Road may collect user information from its website (http://butterandeggroad.com/) (for example, via cookies which are alphanumeric identifiers transmitted from a website to a visitor’s browser and IP address). The information that is collected is generally not Personal Information as is does not allow us to identify you. This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our website. Some of our third party service providers (i.e. advertisers) may also use cookies on our website. We have no access to or control over these cookies. This Privacy Policy covers the use of cookies by Butter and Egg Road only and does not cover the use of cookies by any third parties. Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, some websites may not function properly or optimally.

The Butter and Egg Road website may contain links to other third party websites that are not governed by this privacy policy. Although we endeavour to link only to websites with high privacy standards, our Privacy Policy will no longer apply once you leave this website. We are not responsible for privacy policies employed by other third parties or any foreign affiliates, since they would be governed by privacy legislation applicable in their country of residence. We suggest, therefore, that you examine the privacy statements of those websites to learn how personal information may be collected, used and/or disclosed.

This Privacy Policy is governed pursuant to the laws of Canada and governs Personal Information regardless of your location when you access this website. Personal Information may be stored outside of the jurisdiction in which you reside and processed by us, one of our affiliates or a third-party service provider as set out in this Privacy Policy. Further, Canadian governmental authorities may be entitled to access your Personal Information.

VII.ACCOUNTABILITY AND OPENNESS

Butter and Egg Road is responsible for the Personal Information under its control and has appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy legislation and the terms of this Privacy Policy. All employees involved in maintaining or collecting Personal Information are trained via this Privacy Policy. Personal Information provided to third party service providers with whom Butter and Egg Road has a contractual agreement will have levels of protection comparable to the internal protection of Personal Information maintained at Butter and Egg Road.

The Chief Compliance Officer addresses and investigates questions or concerns regarding Customer’s Personal Information. The Chief Compliance Officer may be reached by mail at Butter and Egg Road Inc. 3 Rowanwood Ave. Toronto Ontario, M4W 1Y5, Attention: Chief Compliance Officer, or by telephone at (647) 887-4711. Copies of this Privacy Policy and any future updates or amendments here to are available at http://butterandeggroad.com/ and upon request in writing from Butter and Egg Road.

VIII.INDIVIDUAL ACCESS

Upon written request of a Customer, Butter and Egg Road will provide such Customer with access to his or her Personal Information. Butter and Egg Road will correct or amend any inaccuracies in the Customer’s Personal Information, and such amended information will be forwarded to any third parties who require access to the information. Butter and Egg Road has the right to refuse a request for access to Personal Information:

If granting access would reveal confidential commercial or financial information;
If doing so would reasonably be expected to threaten the life or security of another individual;
If the information was collected for purposes related to the detection and prevention of fraud;
If the information was generated in the course of a formal dispute resolution process;
If the information would likely reveal Personal Information about another Customer, as the case may be;
If the request is vexatious or frivolous; or
To protect Butter and Egg Road’s rights and property.

If the request of a Customer for such individual’s Personal Information is denied, the individual will be informed in writing of the reasons for the denial, as well as any recourse available to such individual.

Access to Customer’s Personal Information will be at no cost to such Customer. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.

IX.CHALLENGING COMPLIANCE

If a complaint (“Complaint”) regarding Butter and Egg Road’s handling of Personal Information is received, an individual (the “Investigator”) with the skills necessary to conduct an investigation fairly and impartially will be assigned. The Investigator will have access to all relevant records and will be permitted to speak with employees of Butter and Egg Road who handled the Personal Information access request. The complainant will receive notification of the outcome of the investigation clearly and promptly. Any inaccurate Personal Information or policy/procedure changes will be modified, if necessary, based on the outcome of the Complaint.

X.CURRENCY OF THIS PRIVACY POLICY

Butter and Egg Road reserves the right to change this Privacy Policy at any time and from time to time. Any changes or additions to section I of this Privacy Policy regarding those situations where Butter and Egg Road will collect, use or disclose Personal Information will not apply to a Customer without the prior consent of such Customer. All Customers are encouraged to contact Butter and Egg Road to determine if any updates have been made to this Privacy Policy.

BUTTER AND EGG ROAD USA, INC.

PRIVACY POLICY (United States)

Currency: January 26, 2012

At Butter and Egg Road USA, Inc. (“we,” “our” or “us”), we are committed to protecting the privacy, and confidentiality of certain personal information, of our members and other users (collectively “Customers”) of our web site located at www.butterandeggroad.com (the “Site”). In order to achieve this goal and instill confidence in our Customers that the personal information they entrust to us is protected, we have adopted this Privacy Policy. We want our Customers to know why we ask for their personal information, how we use it, what safeguards we employ to protect it and how to contact us with privacy-related questions.

In this Privacy Policy, “Personal Information” means information that, whether alone or together with other such information, may identify a Customer and is provided by such Customer to, or collected by, us through the Site. Personal Information may include, among other things, a Customer’s name, age, gender, purchase history, residential mailing address, residential phone numbers, email addresses, financial data, credit card information and banking information. On the other hand, Personal Information does not include, among other things, a Customer’s business title, business address, business phone number, any information relating to a Customer’s use of the Site (including, but not limited to, navigational history, IP address, and browser used) so long as such information cannot be linked to an individual, and any other anonymous information.

Use Of Personal Information

Personal Information will be collected, used and disclosed by us only as set forth in this Privacy Policy, and we will obtain a Customer’s consent before collecting, using or disclosing his or her Personal Information in a manner that conflicts with this Privacy Policy. We collect, use and disclose Personal Information only as reasonably appropriate for the following purposes:

Protect against, identify, and remediate fraud and errors on the Site;
Perform services requested by a Customer through the Site;
Open an on-line account for a Customer for the purchase of services through the Site;
Record and analyze services received by a Customer through the Site;
Market services offered by us on the Site to Customers and third parties;
Bill, collect and otherwise account for all amounts payable by a Customer through the Site;
Offer additional services on our behalf or on behalf of third parties that may be of interest to a Customer;
Personalize a Customer’s use of the Site;
Communicate with a Customer to ensure Customer satisfaction or otherwise for any legitimate business purpose;
Track Customers’ use of the Site, and collect and analyze data relating to such use, for any legitimate business purpose;
Improve services offered to Customers through the Site;
Performing our obligations under contracts or otherwise;
Respond to any situation in which the safety, property or rights of a Customer or third party may be at risk;
Comply with all applicable laws; and
Any other legitimate business purpose that is communicated to a Customer after his or her Personal Information is received by us.

We may also disclose Personal Information to our affiliates, agents, employees, and suppliers, plus third parties deemed appropriate by us, for the purposes set forth in this Section or as otherwise permitted by law. If we, or all or substantially all of our assets, are being acquired by a third party, a Customer’s Personal Information may be transferred to such third party prior to and after such acquisition.

Storage

Personal Information will be stored at our office located at 580 Broadway, New York, New York, 1001, at our office located at 3 Rowanwood Avenue, Toronto, Ontario M4W 1Y5 and/or on servers used by us and located in the City of New York or the City of Toronto.

Consent

Except as set forth in this Privacy Policy, we do not collect, use or disclose a Customer’s Personal Information without the consent of a Customer. In using the Site, Customers have consented to the collection, use and disclosure of their Personal Information as set forth in this Privacy Policy. A Customer may withdraw his or her consent at any time, subject to our then-existing contractual or other legal obligations and our having a reasonable opportunity to implement such withdrawal. If a Customer chooses to withdraw his or her consent, he or she is required to do so in a writing sent to Butter and Egg Road USA Inc., 580 Broadway, New York, New York, 1001, Attention: Chief Compliance Officer, or by e-mail to info@butterandeggroad.com. Any such withdrawal of consent by a Customer may result in, among other things, an inability to access or use the Site by such Customer.

Retention

Personal Information is only retained as long as may be necessary for the purposes for which it was collected by us and set forth in this Privacy Policy, as required by applicable law, or as provided in any document retention policy adopted by us from time to time, whichever is longer. After the expiration of the retention period described in the immediately preceding sentence with respect to any Personal Information, we will destroy, erase, or rendered anonymous such Personal Information.

Accuracy

We collect Personal Information only from Customers. Each Customer must provide Personal Information that is accurate, complete and up-to-date, and must update such Personal Information from time to time to maintain its accuracy and completeness. All updates to Personal Information can be submitted to us through the Site, in writing to Butter and Egg Road USA Inc., 650 6th Avenue, No. 6D, New York, New York 1001, Attention: Chief Compliance Officer, or by e-mail to info@butterandeggroad.com .

Safeguards

We use security safeguards designed to protect against loss, theft, and unauthorized access, disclosure, copying, use or modification of Personal Information. The nature of such safeguards depends on the sensitivity, format, location and storage of Personal Information, and may include, among other things, the use of locked cabinets, computer passwords, software firewalls, encryption software, restricted access and contractual obligations of confidentiality from third parties to whom Personal Information is disclosed. Since no transmission of information over the Internet or storage of electronic information is completely secure, it remains possible that a Customer’s Personal Information could be compromised, even though such safeguards are used by us.

Cookies

We may collect user information from the Site using “cookies.” Cookies, which are files placed in the browser directory of a computer’s hard drive for later retrieval, will enable the Site to recognize you as a prior user, provide the Site with information regarding your prior use, and otherwise assist us in making the Site more beneficial to you. Information collected from cookies, which is generally not Personal Information, will be used solely for enabling us to provide Customers with a customized on-line experience and to improve the Site.

Some of our third-party service providers (including, but not limited to, advertisers) may also use cookies on the Site. We have no control over these cookies, or the use by such third-party service providers of any information generated from them. This Privacy Policy only covers the use of cookies by us and any information generated from such cookies.

Although cookies are widely used, it may be possible to disable or delete cookies using your browser settings. However, if you disable or delete cookies, the Site may not function properly or optimally.

E-mail

A Customer may from time to time send an e-mail message to us in connection with such Customer’s use of the Site. Upon our receiving such a message, the e-mail address, as well as the contents of such message, will be used and stored by us to respond to such Customer, to improve the Site and for other legitimate business purposes.

Third-Party Web Sites

The Site may from time to time be linked to web sites that are not maintained by us. This Privacy Policy will not apply to such web sites, and we are not responsible for the handling of a Customer’s information by the third parties that maintain such web sites. You are encouraged to review the privacy policies of such web sites before disclosing any information to them.

Access

Upon the written request of a Customer, we will (a) provide such Customer with access to his or her Personal Information, and (b) correct any inaccuracies in such Customer’s Personal Information that are identified to us in writing by such Customer. All such inaccuracies should be sent to us at Butter and Egg Road USA Inc., 580 Broadway, New York, New York, 1001, Attention: Chief Compliance Officer, or by e-mail at info@butterandeggroad.com.

A request for access to Personal Information may be refused by us for any one of the following reasons:

If the information is protected by legal privilege;
If the information is confidential information of a third party;
If doing so would reasonably be expected to threaten the life or security of another individual;
If granting access would reasonably be expected to threaten the safety, security or property of a third party;
If the information was collected for purposes relating to the detection, remediation or prevention of fraud;
If the information was generated in the course of a formal dispute resolution process;
If the information would likely reveal Personal Information of another Customer;
If providing the information is no longer in our possession or under our control or providing the information is overly burdensome to us or a third party;
If the request is vexatious or frivolous; or
To protect our rights and property.

If the request of a Customer for his or her Personal Information is denied, such Customer will be informed in writing of the reasons for such denial.

Access to Customer’s Personal Information will be at no cost to such Customer. Nominal charges may apply, however, for the reproduction or transmission of Personal Information in response to a Customer’s request for access to Personal Information.

Changes

We reserve the right to change this Privacy Policy at any time and from time to time. Any such change will be effective upon our posting it to the Site. No such change affecting the use or disclosure of Personal Information will apply to any Personal Information collected by us prior to the effective date of such change, unless we receive a Customer’s consent to such change. All Customers are encouraged to check the Site from time to time to determine if any changes have been made to this Privacy Policy.

Applicable Law

This Privacy Policy will be governed by the law of the State of New York, without regard to principles of conflict of laws.

Additional Information

We have appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy laws and the terms of this Privacy Policy. The Chief Compliance Officer will investigate and respond to any questions or concerns regarding a Customer’s Personal Information or this Privacy Policy. He or she may reached by mail at Butter and Egg Road USA Inc., 580 Broadway, New York, New York, 1001, Attention: Chief Compliance Officer, or by e-mail at info@butterandeggroad.com .

Dated: January 14, 2013