PRIVACY POLICY FOR Milborne Real Estate Inc.

Our privacy policy includes provisions of the Personal Information Protection Act (ON) and the
Personal Information Protection and Electronic Documents Act (Canada), (the "Applicable Law").

SUMMARY OF PRINCIPLES

1. Accountability
Milborne Real Estate Inc. is responsible for personal information under its control and shall
designate one or more persons who are responsible for Milborne Real Estate Inc.’s compliance
with the principles contained in this privacy policy and for compliance with Applicable Law.

2. Identifying Purposes for the Collection of Personal Information
When required by Applicable Law. Milborne Real Estate Inc. shall identify the purposes for
which personal information is collected at or before the time that the information is collected.

3. Consent for the Collection, Use or Disclosure of Personal Information
When required by Applicable Law, the knowledge and consent of a Protected Individual are
required for the collection, use or disclosure of personal information.

4. Limiting the Collection of Personal Information
When required by Applicable Law, Milborne Real Estate Inc. shall limit the collection of personal
information to that which is necessary for the purposes identified by Milborne Real Estate Inc.
Milborne Real Estate Inc. shall collect personal information by fair and lawful means.

5. Limiting the Use, Disclosure and Retention of Personal Information
Milborne Real Estate Inc. shall not use or disclose personal information for purposes other than
those for which it was collected, except with the consent of the Protected Individual or in
accordance with Applicable Law. As required by Applicable Law, Milborne Real Estate Inc. shall
retain personal information only as long as necessary for the fulfillment of those purposes.

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.

7. Security Safeguards
As required by Applicable Law, Milborne Real Estate Inc. shall protect personal information by
security safeguards appropriate to the sensitivity of the information.

8. Openness Concerning Policies + Practices
Milborne Real Estate Inc. shall make readily available to Protected Individuals specific
information about its policies and practices relating to the management of personal information.

9. Customer and Employee Access to Personal Information
As required by Applicable Law, Milborne Real Estate Inc. shall inform a Protected Individual of
the existence, use, and disclosure of his or her personal information upon request and shall give
the individual access to that information. A Protected Individual shall be able to challenge the
accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance
A Protected Individual shall be able to address a challenge concerning compliance with the above
principles or with Applicable Law to the designated person or persons accountable for Milborne Real Estate Inc.'s compliance with this privacy policy.
WHO AND WHAT OUR PRIVACY POLICY APPLIES TOr Privacy Policy Applies to
This privacy policy applies to personal information about Protected Individuals that is collected,
used or disclosed by Milborne Real Estate Inc. and which is covered by Applicable Law.

This privacy policy does not apply to the following types of information:
* an employee's or customer's name, title, business address (including business email
address) or business telephone number or business fax number;
* other information that is not personal information protected by Applicable Law; or
* other information about the customer or employee that is publicly available or
which is specified by regulation under Applicable Law.
DEFINITIONS
“collection”: the act of gathering, acquiring, recording or obtaining personal information from any
source, including third parties, by any means.
“consent”: voluntary agreement with the collection, use and disclosure of personal information for
defined purposes. Consent can be either express or implied and can be provided directly by the
individual or by an authorized representative. Express consent can be given orally, electronically
or in writing, but is always unequivocal and does not require any inference on the part of Milborne Real Estate Inc.. Implied consent is consent that can reasonably be inferred from an
individual's action or inaction.
“customer”: an individual (in their capacity as an individual either personally, or through a
business carried on as a sole proprietorship or partnership) who uses, or applies to use, Milborne Real Estate Inc. products or services and the term ‘customer’ shall include a potential or
prospective customer who has provided personal information to Milborne Real Estate Inc.
“disclosure”: making personal information available to a third party.
“employee”: an employee of Milborne Real Estate Inc.
“personal information”: personal information as defined by Applicable Law about a Protected
Individual, but does not include aggregated information that cannot be associated with a specific
individual. For a customer, such information includes a customer's credit information, billing
records, service, and any recorded complaints. For an employee, such information includes
information found in personal employment files, performance appraisals, and medical and
benefits information, but does not include the employee's name, title, business address (including
e-mail address) or business telephone or fax numbers.
“Protected Individual”: means an individual whose personal information is protected by Applicable
Law. Those persons who are included in the definition of Protected Individual will vary depending
upon which Applicable Law applies to Milborne Real Estate Inc. in the circumstances.
Generally, the definitions will be the following.
Where the Applicable Law is the Personal Information Protection and Electronic
Documents Act (Canada), "Protected Individual" will generally include:
* an individual who is a customer of Milborne Real Estate Inc.; and
* an individual whose personal information is collected, used or disclosed by Milborne Real Estate Inc. in the course of commercial activity.
Where the Applicable Law is the Personal Information Protection Act (Ontario),
"Protected Individual" will generally include:
* an individual who is a customer of Milborne Real Estate Inc.; and
* an individual whose personal information is collected, used or disclosed by
Milborne Real Estate Inc.; and
* an employee of Milborne Real Estate Inc.
“third party”: an individual or organization outside Milborne Real Estate Inc.
“use”: the treatment, handling and management of personal information by and within Milborne Real Estate Inc.
OUR DETAILED PRIVACY POLICY
The following sections provide more detail on the summary of principles outlined above.
1. Accountability
1.1 The management of Milborne Real Estate Inc. is responsible for ensuring compliance with
this privacy policy and with Applicable Law. Milborne Real Estate Inc. shall designate one or
more persons to be accountable for compliance with this policy and with Applicable Law. Other
individuals may be delegated to act on behalf of the designated person(s) or to take responsibility
for the day-to-day collection and processing of personal information.
1.2 Milborne Real Estate Inc. shall make known, upon request, the name of the person or
persons who have been designated to take responsibility for compliance with this policy and with
Applicable Law.
1.3 Milborne Real Estate Inc. is responsible for personal information in its possession or control.
Milborne Real Estate Inc. shall use appropriate means to provide a comparable level of
protection while information is being processed by a third party.
1.4 Milborne Real Estate Inc. shall implement policies and procedures to give effect to this
privacy policy.
2. Identifying Purposes for the Collection of Personal Information
2.1 Milborne Real Estate Inc. collects personal information only for the following purposes
("identified purposes"):
* to establish and maintain responsible commercial relations with customers and to
provide ongoing service;
* to understand customer needs and preferences and to provide customers with
information related to those needs and preferences;
* to develop, enhance, market or provide products and services to customers
including contacting customers for these purposes using any contact information
that was provided to Milborne Real Estate Inc.;
* to manage and develop Rennie Marketing Systems' business and operations,
including personnel and employment matters; and
* to meet legal and regulatory requirements.
2.2 When required by Applicable Law, Milborne Real Estate Inc. shall specify orally,
electronically or in writing the identified purposes to the Protected Individual at or before the time
personal information is collected. Upon request, persons collecting personal information shall
explain these identified purposes or refer the Protected Individual to a designated person who
shall explain the purposes.
2.3 Unless permitted by Applicable Law or required by other laws, Milborne Real Estate Inc.
shall not use or disclose for any new purpose personal information that has been collected
without first identifying and documenting the new purpose and obtaining the consent of the
Protected Individual .
3. Consent for the Collection, Use or Disclosure of Personal Information
3.1 In obtaining consent and when required by Applicable Law, Milborne Real Estate Inc. shall
use reasonable efforts to ensure that a Protected Individual is advised of the identified purposes
for which personal information will be used or disclosed. Purposes shall be stated in a manner
that can be reasonably understood by the Protected Individual .
3.2 Generally, and when required by Applicable Law, Milborne Real Estate Inc. shall seek
consent to use and disclose personal information at the same time it collects the information.
However, the Milborne Real Estate Inc. may seek consent to use and disclose personal
information after it has been collected, but before it is used or disclosed for a new purpose.
3.3 Milborne Real Estate Inc. will require customers to consent to the collection, use or
disclosure of personal information as a condition of the supply of a product or service only if such
collection, use of disclosure is required to fulfill the identified purposes.
3.4 In determining, the appropriate form of consent, Milborne Real Estate Inc. shall take into
account the sensitivity of the personal information and the reasonable expectations of Protected
Individuals.
3.5 In general, the use of products and services or the acceptance of employment or benefits by
a Protected Individual, constitutes implied consent for Milborne Real Estate Inc. to collect, use
and disclose personal information for all identified purposes.
3.6 A Protected Individual may withdraw consent at any time, subject to legal or contractual
restrictions and reasonable notice. Depending upon the circumstances, the withdrawal of consent
may affect Milborne Real Estate Inc.' ability to provide products, services or employment to the
Protected Individual . Protected Individuals should contact Milborne Real Estate Inc. for more
information regarding the implications of withdrawing consent.
4. Limiting Collection of Personal Information
4.1 Milborne Real Estate Inc. collects personal information primarily from its customers and
employees but may collect personal information in appropriate circumstances from other
Protected Individuals.
4.2 Milborne Real Estate Inc. may also collect personal information from other sources including
credit bureaus, employers or personal references, or other third parties who represent that they
have the right to disclose the information.
5. Limiting Use, Disclosure, and Retention of Personal Information
5.1 Where Protected Individuals include customers, Milborne Real Estate Inc. may disclose a
customer's personal information to:
* a person who in the reasonable judgment of Milborne Real Estate Inc. is
seeking the information as an agent of the customer;
* another company involved in supplying the customer with services related to the
services provided by Milborne Real Estate Inc. (including the developers of real
estate projects for which Milborne Real Estate Inc. is providing marketing
services);
* a company or individual employed by Milborne Real Estate Inc. to perform
functions on its behalf, such as research or data processing;
* another company or individual for the development, enhancement, marketing or
provision of any of Milborne Real Estate Inc.' products or services;
* an agent used by Milborne Real Estate Inc. to evaluate the customer's
creditworthiness or to collect the customer's account;
* a credit reporting agency;
* a public authority or agent of a public authority, if in the reasonable judgment of
Milborne Real Estate Inc., it appears that there is imminent danger to life or
property which could be avoided or minimized by disclosure of the information;
and
* a third party or parties, where the customer consents to such disclosure, or
where disclosure is permitted by Applicable Law, or where disclosure is required
by other laws.
5.2 Where Protected Individuals include employees, Milborne Real Estate Inc. may disclose
personal information about its employees:
* for normal personnel and benefits administration;
* in the context of providing references regarding current or former employees in
response to requests from prospective employers; or
* where the employee consents to such disclosure or where disclosure is permitted
by Applicable Law, or where disclosure is required by other laws.
5.3 Only Milborne Real Estate Inc.' employees with a business need to know, or whose duties
reasonably so require, are granted access to personal information about Protected Individuals.
5.4 Milborne Real Estate Inc. shall keep personal information only as long as it remains
necessary or relevant for the identified purposes or as required by law. Depending on the
circumstances, where personal information has been used to make a decision about a Protected
Individual, Milborne Real Estate Inc. shall retain, for a period of time that is reasonably sufficient
to allow access by the Protected Individual, either the actual information or the rationale for
making the decision.
5.5 Milborne Real Estate Inc. shall maintain reasonable and systematic controls, schedules and
practices for information and records retention and destruction which apply to personal
information that is no longer necessary or relevant for the identified purposes or required by law
to be retained. Such information shall be destroyed, erased or made anonymous.
6. Accuracy of Personal Information
6.1. Personal information used by Milborne Real Estate Inc. shall be sufficiently accurate,
complete and up-to-date to minimize the possibility that inappropriate information may be used to
make a decision about a Protected Individual.
6.2 Milborne Real Estate Inc. shall update personal information about Protected Individuals as
and when necessary to fulfill the identified purposes or upon notification by the Protected
Individual.
7. Security Safeguards
7.1 Milborne Real Estate Inc. shall protect personal information against such risks as loss or
theft, unauthorized access, disclosure, copying, use, modification or destruction, through
appropriate security measures. Milborne Real Estate Inc. shall protect the information
regardless of the format in which it is held.
7.2 Milborne Real Estate Inc. shall protect personal information disclosed to third parties by
contractual agreements stipulating the confidentiality of the information and the purposes for
which it is to be used.
7.3 All of Milborne Real Estate Inc.' employees with access to personal information shall be
required to respect the confidentiality of that information.
8. Openness Concerning Policies and Practices
8.1 Milborne Real Estate Inc. shall make information about its policies and practices easy to
understand, including:
* the title and address of the person or persons accountable for Milborne Real Estate Inc.' compliance with Milborne Real Estate Inc.’s privacy policy and to
whom inquiries or complaints can be forwarded;
* the means of gaining access to personal information held by Milborne Real Estate Inc.; and
* a description of the type of personal information held by Milborne Real Estate Inc., including a general account of its use.
9. Customer and Employee Access to Personal Information
9.1 Upon request and as required by Applicable Law, Milborne Real Estate Inc. shall allow
Protected Individuals a reasonable opportunity to review the personal information held by Milborne Real Estate Inc.. Personal information shall be provided within a reasonable time, and, if there
is a charge for providing the information, the charge shall be a reasonable charge permitted by
Applicable Law.
9.2 In certain situations, Milborne Real Estate Inc. may not be able to provide access to all the
personal information that it holds about a Protected Individual. For example, Milborne Real Estate Inc. may not provide access to information if doing so would likely reveal personal
information about a third party or could reasonably be expected to threaten the life or security of
another individual. Also, Milborne Real Estate Inc. may not provide access to information if
disclosure would reveal confidential commercial information, if the information is protected by
solicitor-client privilege, if the information was generated in the course of a formal dispute
resolution process, or if the information was collected in relation to the investigation of a breach of
an agreement or a contravention of a federal or provincial law. If access to personal information
cannot be provided, Milborne Real Estate Inc. shall provide the reasons for denying access
upon request.
9.3 Upon request, Milborne Real Estate Inc. shall provide an account of the use and disclosure
of personal information and, where reasonably possible, shall state the source of the information.
In providing an account of disclosure, Milborne Real Estate Inc. shall provide a list of
organizations to which it may have disclosed personal information about the Protected Individual
when it is not possible to provide an actual list.
9.4 In order to safeguard personal information, a Protected Individual may be required to provide
sufficient identification information to permit Milborne Real Estate Inc. to account for the
existence, use and disclosure of personal information and to authorize access to the Protected
Individual's information. Any such information shall be used only for this purpose.
9.5 Milborne Real Estate Inc. shall promptly correct or complete any personal information found
to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall
be noted in the Protected Individual's file. Where appropriate, Milborne Real Estate Inc. shall
transmit to third parties having access to the personal information in question any amended
information or the existence of any unresolved differences.
9.6 Protected Individuals can seek access to their personal information by contacting our Privacy
Officer whose contact information is listed below.
10. Challenging Compliance
10.1 Milborne Real Estate Inc. shall maintain procedures for addressing and responding to all
inquiries or complaints from Protected Individuals about the handling of personal information.
10.2 Milborne Real Estate Inc. shall inform Protected Individuals about the existence of these
procedures as well as the availability of complaint procedures.
10.3 The person or persons accountable for compliance with Milborne Real Estate Inc.'s privacy
policy may seek external advice where appropriate before providing a final response to individual
complaints.
10.4 Milborne Real Estate Inc. shall investigate all complaints concerning compliance with
Milborne Real Estate Inc.’s privacy policy. If a complaint is found to be justified, Milborne Real Estate Inc. shall take appropriate measures to resolve the complaint including, if
necessary, amending its policies and procedures. A Protected Individual shall be informed of the
outcome of the investigation regarding his or her complaint.
10.5 A Protected Individual may seek advice from the Office of the Privacy Commissioner (Ontario) and, if appropriate, file a written complaint with that office. However,
the Protected Individual is encouraged to use Milborne Real Estate Inc. internal information and
complaint procedures first.
11. Additional Provisions
Our privacy policy is based on the ten principles of the Canadian Standards Association (CSA)
Model Code for the protection of personal information which was published in 1996 as a National
Standard of Canada.
If you have questions about our privacy policy, please submit them to our Privacy Officer whose
contact information is as follows:
Telephone: 416-958-9998