Eyedro Green Solutions Inc. Privacy Policy

Version: 1.1
Posted on December 14th 2011

Preface

Eyedro Green Solutions Inc. is committed to keeping Personal Information it collects confidential. This Privacy Policy has been designed to inform officers, employees, contractors, agents and customers of Eyedro Green Solutions Inc. and individual members of the public of our commitment to and recognition of our obligation to meet the spirit and terms of applicable privacy laws, including, the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA) and the Municipal Freedom of Information and Protection of Privacy Act (Ontario).

This Privacy Policy describes the principles Eyedro Green Solutions Inc. will use to protect the privacy of Personal Information of customers and other individuals in its possession or control. It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the individuals' rights in respect of this information. This Privacy Policy incorporates and expands the 11 principles for the protection of Personal Information, as established by the Canadian Standards Association (CSA) and as adopted and amended by PIPEDA.

For the purposes of this Privacy Policy, "Personal Information" means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personal information does not include information that has been aggregated such that an individual's information cannot be identified.

In this Privacy Policy, "Eyedro", "we", "us" or "our" means Eyedro Green Solutions Inc. and "customer", "you", and "your" means the individual who is a customer, prospective customer, vendor or other individual member of the public whose Personal Information is in our possession or control. However, this Privacy Policy does not apply to information about business customers who carry on business as corporations, partnerships or other forms of association. Eyedro Green Solutions Inc. does, however, protect the confidentiality of such information in accordance with the law, including regulatory codes of conduct issued by the Ontario Energy Board, and contractual arrangements.

By accepting service from us, visiting or using our Website, or otherwise providing us with your Personal Information, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time. The terms in this Privacy Policy may be changed from time to time, so you should review it for changes periodically on our Website at Eyedro Privacy Policy.

Personal Information Protection Principles

• Accountability
• Identifying Purposes
• Consent, Limiting Use, Disclosure and Retention
• Scope of Data Collection
• Accuracy
• Safeguards
• Openness
• Individual Access
• Challenging Compliance
• E-Mail Communications
• Links to Third-Party Sites

1. Accountability

Eyedro is accountable for the protection of all Personal Information within the organization's possession or control, including any Personal Information that has been transferred to a third party for processing purposes. Eyedro may engage employees, contractors or other companies and third parties to perform services for Eyedro that involve access to Personal Information. Such third parties may be located outside of Ontario or Canada. Eyedro shall use contractual or other means to provide a comparable level of protection of this information while the information is being processed by such third parties.

If you have any questions about this privacy policy or our treatment of your personal data, please write to us via our online contact form (at eyedro.com) or by post to:

Eyedro Green Solutions Inc.
1 Yonge Street, Suite 1801
Toronto, Ontario, M5E1W7
Canada

2. Identifying Purposes

Eyedro will identify the purposes for which it collects Personal Information at or before the time the information is collected, such as when you apply for service from us. If Eyedro identifies other purposes for which any Personal Information we have collected from you may be used, Eyedro will seek your consent before such use. You may refuse permission for Eyedro to use your Personal Information for any new purpose unless the new purpose is required or permitted by law or regulatory authorities. However, refusal to provide such consent may prevent us from providing you with some services since we require a minimum amount of Personal Information about you to provide services to you. All Personal Information Eyedro collects from customers and other individuals (as applicable) is collected for one or more of the following purposes:

• To deliver products and services;
• To identify or contact customers, respond to customer inquiries and otherwise maintain business relations with customers;
• To bill and collect payment, to establish credit worthiness, or to sign up for pre-authorized payment;
• To create metrics of product and website usage patterns for the purpose of improving the user experience;
• To request customer participation in surveys or contests, or to notify customers about events, causes or programs sponsored by Eyedro;
• To provide individuals with information they have requested on Eyedro Green Solutions Inc. or one of its subsidiaries, such as financial quarterly reports or news releases;
• To prepare financial records for Eyedro and its subsidiaries.

Eyedro may monitor and/or record any telephone conversation with you for quality assurance and training purposes.

3. Consent, Limiting Use, Disclosure and Retention

Eyedro will obtain your consent before, or when, it collects, uses or discloses your Personal Information. Your consent to the collection, use and disclosure of your Personal Information may be either express or implied, depending on the circumstances, the purposes for which such Personal Information is being collected and the sensitivity of the information. For example, by accepting services from us, your consent to the collection, use and disclosure of your Personal Information for the purposes of providing you with such related services is implied. Consent may be obtained directly from you or from a third party that has obtained your consent to disclose your Personal Information to Eyedro. For example, if you sign a separate contract with a retailer, Eyedro may obtain your Personal Information from the retailer and Eyedro may provide your billing and consumption information to the retailer. Consent may also be given by an authorized representative such as a legal guardian or person with power of attorney. Eyedro will not use or disclose your Personal Information for purposes other than those for which it was collected except with your consent or as permitted or required by law or regulatory authorities.

Eyedro will collect, use or disclose your Personal Information without your knowledge or consent only in limited circumstances as permitted or required by law or regulatory authorities. Subject to certain legal and contractual restrictions and reasonable notice, you can refuse or withdraw your consent to the collection, use or disclosure of your Personal Information at any time. However, refusal to provide such consent, or withdrawal of such consent, may prevent us from providing you with some services since we require a minimum amount of Personal Information about you to provide services to you. Eyedro will explain the implications of such withdrawal or refusal to provide such consent.

Eyedro will not, as a condition of supplying you with a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the specified, legitimate purpose.

Under certain exceptional circumstances, Eyedro may have a legal duty or right to collect, use or disclose your Personal Information without your knowledge or consent.

In accordance with applicable laws, Eyedro will not disclose any consumer information (which may include Personal Information) to any of its affiliates without the consumer's written consent except where consumer information is required to be disclosed:

• for billing or market operation purposes;
• for law enforcement purposes; or
• for the purpose of complying with a legal requirement.

Eyedro will retain Personal Information only for so long as is necessary to fulfill the purpose for which it was collected and to meet our legal and contractual obligations.

Eyedro will not trade, rent or sell your Personal Information. However, in the course of a business transaction, such as a proposed sale of Eyedro's business or assets (or a part thereof), or a merger or amalgamation of Eyedro with another company, we may disclose your Personal Information to third parties such as prospective purchasers of Eyedro's shares, business or assets, and to their lawyers, accountants, financial advisors, agents and other representatives as necessary for the purposes of such transaction.

4. Scope of Data Collection

Eyedro shall limit the amount and type of Personal Information it collects to that which is necessary for the purposes identified, and shall collect such information by fair and lawful means. Depending on the circumstances, we may collect Personal Information listed below from individual customers:

• Customer name and address (mailing and service address) and other contact information (i.e. home and work telephone numbers and e-mail addresses);
• Facts about historic and current consumption of power for your home or business;
• Customer transactions with Eyedro Green Solutions Inc. (i.e. account balances, payment history, and account activity);
• General financial information (i.e. credit card number);
• Bank information requested for pre-authorized payments; and
• Information we receive from you through your correspondence or communications with us.

As is the case with Websites generally, when visitors access any of the Eyedro websites (eg. eyedro.com, store.eyedro.com, my-eyedro.com), the site software automatically collects the internet protocol (IP) address of the computer through which the user is connected to the Internet. The Eyedro websites also automatically collect information about the user's Internet browser software, operating system, the date and time of the user's visit, the URL of the last page visited by the user before entering the Eyedro family of Websites, the pages accessed while on our site, and other metrics captured by Google Analytics. This information is not used to gain Personal Information on individual users but is aggregated with that of other visitors to help us understand how the site is being used and how to make it better.

We may collect, store and use the following kinds of personal data:

• Information about your visits to and use of this website;
• Information about any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our goods or services;
• Information that you provide to us for the purpose of registering with us and/or subscribing to our website services and/or email notifications;
• Information that you provide to us during the set up and use of our products and services; and
• Data which your Eyedro product collects and transmits to our servers in relation to system events and measurement of temperature, power consumption etc

When a visitor accesses the Eyedro Website, a cookie is automatically installed on the visitor's computer hard-drive. A cookie is a small text file that contains a unique identification number, which can be used to identify the user's browser, but not the user. Cookies form an essential part of the Internet today by allowing servers to recognize users' browsers when the users return to previously visited Websites. Since cookies are only text files, they cannot "run" on your computer and have no ability to search your computer for information or to transmit information to anyone. Eyedro uses cookies to provide certain features on its Website. We do not use cookies to retain Personal Information. Users are free to prevent the installation of cookies on their computer hard-drive, including the Eyedro cookie, by simply disabling the feature in their browser's options. Some browsers allow users to accept or reject cookies as they are presented to the user. Please note that users will not be able to access some features and services of the Eyedro Website if they disable cookies.

Eyedro uses Website usage information about visitors to our Website who have responded to a promotional campaign about Eyedro's services for the purpose of future promotional campaigns, and evaluating usage statistics. For this purpose, we collect information about the campaigns and some of the pages you visit on our Website through the use of tracking numbers passed through URL's transferred to our servers as well as pixels tags (also known as clear GIFs).

As well, Eyedro may use third-party companies to host and serve online advertisements for Eyedro promotional campaigns. Pixel tags may be used in connection with online advertisements, for example, to allow us to count the number of times the advertisement was viewed versus the number of individuals who enrolled in the product or service advertised. Personal information about you is not collected by any such third-party companies, nor is any tracking information generated from the pixel tag used by them for any other purpose than to report advertising response and Website activity to us.

Eyedro may use aggregated (non-identifiable) power consumption data to improve its products and services, and user experience.

5. Accuracy

All Personal Information we collect and use is kept as accurate, complete and up-to-date as necessary for the purpose for which it is to be used. However, we rely on you to disclose all material information to us and to inform us of any errors or changes in such information.

Individuals may challenge the accuracy and completeness of Personal Information about them and have it amended, as appropriate, as set out in Section 8 below.

6. Safeguards

In fulfilling its responsibilities with respect to the confidentiality of Personal Information, Eyedro will employ a number of safeguards, appropriate to the sensitivity of the specific information, to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, such as locked filing cabinets, restricted access to offices, security clearances, limiting access on a "need to know" basis, use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and relevant third parties to ensure compliance.

7. Openness

This Privacy Policy is effective as of the Effective Date set forth at the beginning of this Privacy Policy. Eyedro will from time to time review and revise its Privacy Policy. Eyedro will make changes to its Privacy Policy available to its customers by such means as Eyedro's Website and email notifications.

8. Individual Access

Upon request and with satisfactory proof of the customer's identity, any customer of Eyedro may obtain information regarding the type, use and disclosure, of his, or her, Personal Information that Eyedro has in its possession or control. Any customer may request that his, or her, Personal Information be amended for purposes of accuracy and completeness. Eyedro may require the customer to provide such request in writing. We may also charge a nominal fee for responding to such requests, and, if so, will advise you in advance of such costs. This right of access, however, is not absolute. For instance, Eyedro may refuse to provide you with access to your Personal Information where such refusal is permitted or required by law or regulatory authorities.

9. Challenging Compliance

Any customer of Eyedro may challenge Eyedro's compliance with this Privacy Policy by contacting Eyedro's customer service representatives by any of the methods set out in section 1 above. Eyedro will investigate and respond to customer complaints and questions. If the customer is not satisfied with the way Eyedro's customer service representatives have responded to a complaint, the customer may address these concerns, in writing, to the Chief Privacy Officer at the address set forth in Section 1.

If the Chief Privacy Officer does not resolve the issue to the customer's satisfaction, the customer may contact the Privacy Commissioner of Ontario.

10. E-Mail Communications

Eyedro adheres to a no "spam" policy. Therefore, you will not receive regular, unsolicited e-mail communications from Eyedro unless you have agreed otherwise or such communications are required for the purposes identified in Section 2 above or to otherwise provide a product, service or information to you that you have requested.
Please note that Eyedro reserves the right to contact you, by e-mail or otherwise, if permitted or required by law or regulatory authorities or if there has been a violation of Eyedro's Website Terms of Use.

11. Links to Third-Party Sites

Eyedro's Website contains links to third-party Websites. Eyedro is not responsible for (a) any information you provide to Websites that you access through a link on our Website or (b) the privacy practices or the content of such Websites.