Privacy Policy

(last updated 2012 May 29)

This Privacy Policy describes what personal information Jostle collects, how Jostle uses
it, to whom it may be disclosed by Jostle, and the safeguards Jostle uses to protect it.

When Jostle updates this Privacy Policy, it will revise the “last updated” date at the top
of the Privacy Policy and will post the updated Privacy Policy on its Web Site and/or
email your system administrator who is responsible for managing the Jostle service,
prior to the changes becoming effective.

SUMMARY OF OUR PRIVACY MEASURES

Privacy is important to Jostle – the service (application) Jostle provides embodies
the ‘trust network’ between all the contributors to an organization. Jostle is committed to
maintaining the security, confidentiality and privacy of your personal information that it
has obtained or been provided with.

• We do not collect any personal information, other than what you, or your
  organization, provide directly to us, for example in an e-mail or via an entry in
  your Jostle Contributor Profile, or which you have authorized third parties to
  disclose to us.
• At the broadest level, only Users of the Jostle service that have been authorized
  by a Jostle system administrator for your organization, or that are part of a Jostle
  Team you contribute to, can access and view your Jostle Contributor Profile.
• However, Jostle provides further access and viewing controls, by empowering
  individual users such as you to further control and limit which types of Users
  are able to see certain pieces of personal information contained in your Jostle
  Contributor Profile.
• We will not sell or rent your personally identifiable information to third parties.
• Although we record where our users come from and their browsers by using
  cookies, to improve our site’s functionality, we never associate your personal
  information with such aggregated data on how people use Jostle.
• We may provide your personal information to others if: you specifically asked
  us to; or we have to by law; or we have to in order to deal with fraud, security or
  technical problems; or its necessary to protect Jostle, its users, or the public from
  imminent harm.
• We use third party service providers: to conduct site analytics to determine how
  to improve our web site’s usability; to track user requests and bug reports to help
  us resolve user issues; and to host the Jostle service.
• We update this policy from time to time, so its wise for you to check the Jostle
  web site periodically to see how we are protecting your personal information.

OUR COMMITMENT TO PRIVACY

Jostle wants to assure all users of Jostle services and web sites that it recognizes,
and takes all reasonable measures to meet, their expectations of privacy when their
personal information is collected, stored and used by Jostle. Jostle’s approach mirrors
the rigorous data privacy laws first implemented and strictly enforced in Europe in
the late 1990s. Canada’s implementation of an all-encompassing Federal privacy law
several years later was formally recognized by the European Commission as being
broadly equivalent to the EU Directive on data privacy and thus providing an adequate
level of privacy protection for individuals. The Province of British Columbia also enacted
a personal information privacy law a few years later which was recognized by the
Canadian government as being substantially similar to the Federal privacy law. Jostle’s
Privacy Policy has been created to comply with these privacy laws and to assure users
of its services that their personal information will be collected, stored and used only in a
manner that respects their privacy expectations.

SCOPE OF POLICY

This Privacy Policy applies only to personal information about identifiable individuals
such as an individual’s age, home phone, cell phone, personal email, home fax,
biography, skills, qualifications, social insurance numbers, social security numbers, etc.

This Policy does not apply to:

• information about corporate or commercial entities or information that is otherwise not of a personal nature;
• business contact information (address, phone, fax, email); or
• certain publicly-available information as stipulated by applicable laws.

PERSONAL INFORMATION COLLECTED

Jostle collects personal information in its business operations as follows:

• from Jostle employees, officers, directors, advisors, shareholders, consultants and suppliers who are individuals (“Jostle Partners”); one or more of — home or personal contact information, financial information, resumes, qualifications, academic histories, biographies, references, employment histories, family information, and similar information;
• from individuals reviewing Jostle products and services on its web site or otherwise (“Guests”); personal information provided by the Guests such as home or personal contact information, interests, biography, skills, qualifications, and similar information as determined by the Guests;
• from individuals who are part of or associated with a corporate or other organization that has subscribed to a Jostle service (“Subscriber”) that have been granted access by the Subscriber to the Jostle service, or individuals that have themselves subscribed to a Jostle service, (“Users”): one or more of — home or personal contact information, interests, biography, skills, qualifications, and similar information as determined by each Subscriber and by its Users.

This personal information about an individual User is collected by Jostle in one or more of the following ways:

• directly from the individual in person;
• by correspondence with the individual through such means as email, fax or the Jostle web site;
• from the Subscriber which the User is associated with; and
• from web sites or applications that the individual User has directed or linked Jostle to.

ACCOUNTABILITY

Jostle will be accountable and responsible for personal information that is under its
control. Jostle has designated a Privacy Officer to ensure Jostle’s compliance with this
Privacy Policy and to address any questions or concerns an individual may have.

PURPOSES

Jostle collects, uses and discloses personal information for the following purposes:

• with respect to information about a Jostle Partner; to manage and administer
  its relationship in the normal course of business with the Jostle Partner
  in the Jostle Partner’s capacity as an employee, officer, director, advisor,
  shareholder, consultant or supplier of Jostle, as the case may be,
• with respect to information about a Guest; to provide a demonstration of
  Jostle services and to provide information about Jostle to such Guest, and to
  answer any questions that such Guest may submit, and
• with respect to information about a User; to provide Jostle services to
  the User, including access to such services by other Users to the extent
  determined by the User and subject to any limitations imposed by any
  Subscriber that the User is associated with.

In particular, such purposes may include any one or more of the following specific goals
or objectives:

• authenticating identity;
• describing, supplying, administering and maintaining Jostle’s products and
  services;
• establishing and maintaining communications relating to Jostle’s existing and
  new products and services, responding to inquiries and resolving complaints;
• establishing, maintaining and expanding Jostle’s web site;
• establishing and maintaining Subscriber and User accounts and records;
• processing and collecting payments and debts, and making payments;
• tracking use of Jostle’s systems, services and web site;
• protecting Jostle’s systems and web site from unauthorized access;
• protecting Jostle, its suppliers, customers and others, from fraud and error;
• identifying and resolving technical problems concerning Jostle’s services and
  web site;
• as part of any due diligence required for, and to facilitate and complete, a
  Jostle financing, grant of security interest, merger, amalgamation, acquisition
  or sale of assets, and
• complying with legal requirements and acting pursuant to applicable laws and
  legal authorizations.

CONSENT

Jostle will always obtain each individual’s consent to collect, use and disclose the
individual’s personal information for the stipulated purposes, except where Jostle is
authorized or required by law to do so without consent. An individual’s consent can be
given to Jostle as follows:

• by the individual directly to Jostle,
• by the individual through its authorized representative to Jostle, such as by
  the User’s Subscriber to Jostle, and
• impliedly, such as by supplying the personal information in the course of
  using Jostle’s services.

An individual may withdraw consent at any time (subject to legal, contractual and
other restrictions as provided by law) upon reasonable notice in writing to Jostle. A
consequence of such notice is that Jostle may unable to provide certain of its services
or carry out the purposes or objectives for which the personal information was collected.

LIMITS ON COLLECTION OF PERSONAL INFORMATION

Jostle will not collect personal information indiscriminately and will limit its collection
of personal information to what is reasonably necessary for the purposes described.
Jostle may also collect personal information as authorized by law.

LIMITS FOR USING AND DISCLOSING PERSONAL INFORMATION

Jostle will only use and disclose personal information for the purposes which are
listed in this Policy, for other purposes for which Jostle has received consent, and
as otherwise authorized or required by law. Jostle will destroy or make anonymous
records containing personal information as soon as it is reasonable to assume that
(a) the original purpose is no longer being served by retention of the information, and
(b) retention is no longer necessary for legal or business purposes such as resolving
disputes or enforcing our agreements. Jostle will take due care when destroying
personal information to prevent unauthorized access to such information during its
destruction process.

Jostle will disclose personal information when required by law or upon its good-faith
belief that such action is necessary to cooperate with the investigations of purported
unlawful activities, or comply with legal process.

Jostle does not share any personal information with the Web sites to which Jostle links,
although Jostle may share aggregate, non-personally identifiable data with such web
sites. However, when authorized by you, Jostle will share your personal information
with a third party to facilitate the implementation or use of a third party application in
association with the Jostle Team Profile of teams you contribute to.

You will be notified, by a posting on the Jostle Web Site and/or by email to your system
administrator, of any material change in the ownership of Jostle or in the uses of your
personal information, as well as any choices you may have regarding your personal
information.

ACCURACY

Jostle will make reasonable efforts to ensure that personal information Jostle is
using is accurate and complete. In most cases, Jostle will rely on the individuals to
ensure that their information, such as street address, e-mail address or telephone
number, is current, complete and accurate. If individuals demonstrate the inaccuracy
or incompleteness of their personal information, Jostle will correct the information as
required. If appropriate, Jostle will send the corrected information to third parties to
whom the information had previously been disclosed. When a challenge by an individual
regarding the accuracy of the personal information is not satisfactorily resolved, Jostle
will annotate the personal information under its control with a note that a correction was
requested but not made.

SAFEGUARDING PERSONAL INFORMATION

Jostle protects the personal information in its custody or control by making reasonable
security arrangements to prevent unauthorized access, collection, use, disclosure
or disposal, in a manner appropriate for the sensitivity of the information. Upon prior
arrangement, Jostle will provide your system administrator with the opportunity to
visit Jostle facilities and review the ways Jostle manages and secures your personal
information. Confidentiality and security are not guaranteed when information is
transmitted through e-mail, electronic or wireless means. Jostle tries to ensure that a
comparable level of personal information protection is implemented by its suppliers,
agents, and representatives who are given access to such personal information,
although absolute security cannot be guaranteed. Jostle will always attempt to deal with
reputable companies who agree to respect user privacy and applicable privacy laws.
Jostle will attempt to notify you, either directly or through your system administrator,
as soon as reasonably possible after Jostle becomes aware of an actual or suspected
breach of the security of your personal information stored by Jostle.

PROVIDING ACCESS

Each individual has the right to access the individual’s own personal information held
by Jostle. Upon written request and authentication of identity by an individual, Jostle
will advise which personal information is under Jostle’s control, the ways in which
that information is being used, and the persons to whom such information may have
been disclosed. Jostle will try to make such information available within 45 days of the
request, or provide written notice where additional time is required to fulfil the request.

In some situations, Jostle may not be able to provide such access to certain personal
information. This may be the case where, for example, disclosure would reveal
personal information about another individual, the personal information is protected
by solicitor or attorney – client privilege, the information was collected for the purpose
of an investigation, or where disclosure of the information would reveal confidential
commercial information that could harm our competitive position. Jostle may also be
prevented by law from providing access to certain personal information. Where an
access request is refused, Jostle will provide notice in writing, giving the reason for
refusal and outlining further steps which are available to challenge such a decision.

COMPLAINTS

Any inquiries, complaints or questions regarding this policy or Jostle’s compliance with
privacy legislation, should be directed in writing to the Jostle Privacy Officer as follows:

Mail:

Jostle Corporation
2009 Ocean Wind Drive
Surrey, BC V4A 9K5

E-mail:
privacy@jostle.me

If you are not satisfied with the response you receive, you should contact the
Information and Privacy Commissioner for British Columbia:

Mail:

PO Box 9038, Stn. Prov. Govt.
Victoria, BC V8W 9A4

Location:
3rd Floor, 756 Fort Street
Victoria, BC V8W 1H2