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                 Protecting the confidentiality of your personal information has
                      always been an important part of the way we do business. To ensure
                      that we protect your privacy, Sunny Oasis Internet Corporation
                      has adopted a Privacy Code. This Code sets out how and why we collect
                      and use personal information about our customers. It also explains
                      limited circumstances under which we may need or be required to
                      disclose it.                 
                 "Personal information" means information
                      that identifies you as a specific individual. It does not
                  include the sort of general information that could be found
                  in a business directory or a telephone book.  
                 Effective January 1, 2004, the Government of Canada will implement
                      the last phase of the Personal Information Protection and Electronic
                      Act (PIPEDA). This federal statute will then apply to insurance
                      companies and many other industry sectors.                 
                 This legislation establishes rules and principles for the use
                      and disclosure of personal information based on the ten privacy
                      principles developed by the Canadian Standards Association. These
                      principles recognize that we live in an era when commercial information
                      is exchanged and circulated by electronic means. It balances the
                      individual's right to privacy in their personal information with
                      the reasonable need of organizations to collect, use or disclose
                      personal information.                 
                 Under the new legislation, an organization may collect, use or
                      disclose personal information only for limited purposes that a
                      reasonable person would consider to be appropriate in the circumstances.                 
                 The Personal Information Protection and Electronic Act requires
                      us to provide the same safeguards for your privacy that we have
                      always provided on a voluntary basis. Our Privacy Code sets out
                      these principles in simple terms. It explains how we ensure that
                      your privacy and the confidentiality of your personal information
                      are protected.                 
               
              
              
                 Sunny Oasis Internet Corporation's Privacy Code is based on the
                        following ten principles adopted by the Personal Information Protection
                        and Electronic Act (PIPEDA).                   
               
              
              
                
                
                  As a customer of
                                    Sunny Oasis Internet Corporation, you have a right to expect
                    that your web design and hosting supplier is accountable for the personal
                                    information it collects and uses. "Customer" means a current
                                    and/or former client. 
                       
                   We are responsible for maintaining and protecting your personal
                                information while it is under our control. This includes any personal
                                information that may need to be disclosed to third parties for
                                processing or other administrative functions.
                              
                       
                   To help ensure the confidentiality of your personal information,
                                we have established policies and procedures to ensure that we comply
                                with the Personal Information Protection and Electronic Act. We
                                have designated a privacy officer who is responsible for our company's
                                compliance with the ten privacy principles by the Canadian Standards
                                Association.
                              
                       
                   If you have any questions or inquiries about how your personal
                                information is stored, or when it may need to be disclosed to others,
                                our privacy officer is there to assist and explain our policies
                                to you.
                                           
                 
               
              
              
                
                
                  Before or when
                          we collect information about you, we will explain how we intend
            to use it. Sunny Oasis Internet Corporation collects personal information
                          only for the following purposes:
                       
                  
                    -  to provide ongoing service to our customer;
 
                    - to help
                                us understand our customer's needs better;
 
                    - to develop,
                                enhance, market or provide products and services;
 
                    - to
                                  meet our legal and regulatory requirements. 
 
                   
                   Unless we are required by law, Sunny Oasis Internet Corporation
                          will not use or disclose any personal information that has been
                          collected without documenting the new purpose and obtaining your
                          consent. If you have any questions about these purposes, our privacy
                          officer will be pleased to explain them to you.
                       
                 
               
              
              
                
                
                  Sunny Oasis
                            Internet Corporation will make a reasonable effort to make
                            sure that its customers understand and consent to how their
                            personal information will be used by the Company.
                       
                   We will obtain your consent if we need to use your information
                          for any other purpose and before collecting information from third
                          parties such as other hosting or internet companies.
                       
                   In certain circumstances, however, personal information may need
                          to be collected, used or disclosed without the knowledge and consent
                          of the individual. For example, legal, medical, or security reasons
                          may make it impossible or impractical to seek consent.
                       
                   The Personal Information Protection and Electronic Act recognizes
                          that when information is being collected for the detection and
                          prevention of fraud or for law enforcement, seeking the consent
                          of an individual may defeat the purpose of collecting the information.
                          Seeking consent may also be impossible or inappropriate when the
                          individual is a minor, seriously ill, or mentally incapacitated.
                       
                   In obtaining your consent, we will always use reasonable efforts
                            to ensure that you are advised of the identified purposes for which
                          any personal information collected will be used or disclosed.                     
                 
               
              
              
                
                
                  We will
                          always limit the collection of personal information to that
                          which is necessary for the identified purposes. Typically,
                          this is information that is required to enable us to set up
                          billing services for your account. We may need to collect personal
                          information from other sources including credit bureaus.
                       
                   Under certain circumstances we need to collect information to
                            assist us in registering domain names or purchasing secure certificates
                            on behalf of our customers. This may involve the use of other agencies
                            to provide corporate or business information. We will always collect
                          personal information by fair and lawful means.                     
                 
               
              
              
                  
                    
                        Personal information will not
                            be used or disclosed for purposes other than for which it
                            was collected, except with your consent or as permitted or
                            required by law. Your personal information will be retained
                            only as long as it is necessary to fulfill those purposes.
                         
                         Sunny Oasis Internet Corporation may disclose a customer's personal
                          information to the following organizations:                     
                        
                          -  Another internet company for the reasonable provision
                                of internet services. 
 
                          -  Another person or corporation as part of conducting
                                business. This may include a domain registration
                            or secure certificate registration company, subject
                            to that corporation agreeing to manage personal information
                            in accordance with these privacy principles; 
 
                          -  A person or corporation that is involved in supplying
                                us internet services. 
 
                          -  A company or an individual employed by Sunny Oasis
                                Internet Corporation to perform data processing,
                            accounting, or statistical functions on our behalf; 
 
                          -  A person or corporation involved in the development,
                                enhancement, marketing or provision of our products
                            and services. This may include resellers or agents
                            of Sunny Oasis. 
 
                          -  An agent used by Sunny Oasis Internet Corporation
                                to evaluate your creditworthiness or to collect
                            an outstanding account. This may include credit grantors
                            and reporting agencies; 
 
                          -  A public authority or agent of a public authority,
                                if the information is required to comply with
                            a provincial or federal statute or regulation. 
 
                          -  A law enforcement agency, where our customer consents
                                to such disclosure or disclosure is required
                            by law or emergency. 
 
                         
                        Sunny Oasis Internet Corporation
                          does not provide or sell its customer lists to any
                          outside company for use in marketing or solicitation.
                          Only employees with a business "need to know",
                          or those whose duties require it, are granted access
                          to personal information about our customers.  
                         We keep personal information only as long as it remains necessary
                          or relevant for the identified purposes or as required by law.
                          Personal information that is no longer necessary or relevant for
                          the identified purposes or required to be retained by law is destroyed,
                          erased or made anonymous.
                         
                     
                   
                  
                  
                    
                    
                      Sunny Oasis
                              Internet Corporation makes every effort to ensure that personal
                        information about its customers is as accurate, complete, and up-to-date
                        as is necessary for the purposes for which it was collected.
                              
                       
                       This may require contact with you to confirm or update personal
                              information.
                              
                       
                       If you have any questions about the accuracy and completeness
                              of the personal information that we have collected or retained,
                              please do not hesitate to contact our privacy officer. If you need
                              to update some aspect of your personal information, please contact
                              us directly.
                                           
                     
                   
                  
                  
                    
                    
                      Sunny Oasis Internet
                          Corporation takes steps to protect personal information with
                          security safeguards appropriate to the sensitivity of the information.
                       
                       Specifically, we have stringent security measures in place to
                          protect personal information against such risks as loss or theft,
                          computer hackers, unauthorized access, disclosure, copying, use,
                          modification or destruction.
                       
                       Sunny Oasis Internet Corporation protects your personal information
                          regardless of the format in which it is held. We also protect personal
                          information we disclose to third parties by contractual agreements
                          stipulating the confidentiality of the information and the purposes
                          for which it is to be used.
                       
                       All our employees with access to personal information are required
                            as a condition of their employment to respect the confidentiality
                            of personal information.
                          
                     
                   
                  
                  
                    
                    
                      Sunny Oasis
                          Internet Corporation pursues a policy of openness about the
                          procedures it uses to manage personal information. We will
                          make specific information about our policies and practices
                          relating to the management of their personal information available
                          to customers upon request.
                       
                       We ensure openness by providing you with the following information:
                       
                      
                        -  the title and address of the privacy officer accountable
                                for our compliance with the policy;
 
                        - the name of the individual
                                  to whom inquiries or complaints can be forwarded;
 
                        - the
                                    means of gaining access to personal information
                          held by our company; and
 
                        - a description of the type of personal
                                    information held by Sunny Oasis Internet
                          Corporation, including a general account of its use. 
 
                       
                       Sunny Oasis Internet Corporation makes information available
                          to help its customers exercise informed choices regarding the use
                          of their personal information.
                       
                     
                   
                  
                  
                    
                    
                      Sunny Oasis
                          Internet Corporation informs its customers of the existence,
                          use, and disclosure of their personal information upon request
                          and provides access to that information. Our customers are
                          able to challenge or correct the accuracy and completeness
                          of their personal information and have it amended when appropriate.
                       
                       When a request is made in writing, we will inform you in a timely
                          fashion, of the existence, use, and disclosure of your personal
                          information and you will be given access to that information. In
                          order to safeguard your personal information, we may require you
                          to provide sufficient identification information to permit us to
                          authorize access to your file.
                       
                       In certain exceptional situations, we may not be able to provide
                          you with access to all of the personal information we hold. Exceptions
                          may include information that is prohibitively costly to provide,
                          information that contains references to other individuals, information
                          that cannot be disclosed for legal, security or commercial proprietary
                          reasons, information that is subject to solicitor-client or litigation
                          privilege, or, in certain circumstances, information of a medical
                          nature. If this is the case, Sunny Oasis Internet Corporation will
                          provide the reasons for denying access upon request.
                       
                       Customers can obtain information or seek access to their individual
                          files by contacting our designed privacy officer at the address
                          described below.
                        
                     
                   
                  
                  
                    
                    
                      A customer has the right to challenge
                          Sunny Oasis Internet Corporation's compliance with the above
                          principles by contacting the privacy officer accountable for
                    our compliance with the policy.
                       
                       Sunny Oasis Internet Corporation maintains strict procedures
                          for addressing and responding to all inquiries or complaints from
                          its customers about its handling of personal information. We inform
                          our customers about our privacy practices as well as availability
                          of complaint procedures, if necessary.
                       
                       Our privacy officer will investigate all complaints concerning
                          compliance with the privacy policy. If a complaint is found to
                          be justified, we will take appropriate measures to resolve the
                          complaint including the amendment of our policies and procedures.
                       
                       In exceptional circumstances, the privacy officer accountable
                            for compliance with our privacy policy may seek external legal
                            advice where appropriate before providing a final response to individual
                            complaints.
                          
                     
                   
             
                  
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