Phoenix Media Group Inc. Privacy Code

Most recently amended March 1, 2005.

Scope And Application Of The Phoenix Media Group Inc. Privacy Code:

The scope and application of the Phoenix Media Group Inc. Privacy Code are as follows:

The Phoenix Media Group Inc. Privacy Code applies to personal information about Phoenix Media Group Inc. employees and non-employee persons who interact with the Phoenix Media Group Inc. that is collected, used or disclosed by the Phoenix Media Group Inc.

• Employees in this context includes past and present employees and independent contractors of the Phoenix Media Group Inc.

• Non-employee persons in this context includes individuals who are readers, subscribers, advertisers, contest participants, job applicants, Internet users who are exposed to the media content of the Phoenix Media Group Inc.

The Phoenix Media Group Inc. Privacy Code applies to the management of personal information in any form whether oral, electronic or written. Phoenix Media Group Inc. reserves the right to amend this Privacy Code from time to time.

The application of the Phoenix Media Group Inc. Privacy Code is subject to the requirements or provisions of any applicable legislation, regulations or agreements (such as collective agreements), or the order of any court or other lawful authority.

Exclusions from privacy protection: The Phoenix Media Group Inc.  Privacy Code does not impose any limits on the collection, use or disclosure of the following information by a Phoenix Media Group Inc. company a) information that is publicly available, such as a person's name, address, telephone number and e-mail address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about Phoenix Media Group Inc. customers, or number of visitors and average time spent on a website.

Purposes for Collection of Personal Information:

The Phoenix Media Group Inc. has collected and collects personal information for the following purposes: a) to establish and maintain responsible commercial relations with individuals and to provide ongoing service; b) to understand individual needs; c) to develop, enhance, market or provide products and services; and d) to manage and develop its business and operations, including personnel and employment matters.

As examples of the above:

i) The Phoenix Media Group Inc. may from time to time use a person's personal information to contact the person about changes, enhancements, or similar notices;

ii) if a person indicated that he/she was interested in receiving offers or information from the Phoenix Media Group Inc. or certain of our selected sponsors or advertisers, the Phoenix Media Group Inc. may send the person materials about products and services that the Phoenix Media Group Inc. feels may be of interest to the person; and

iii) if a person enters a contest or other promotion offered on the windsoressexnews.com website, the Phoenix Media Group Inc. may, under the rules of the promotion, use the person's name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion.

Obtaining Consent:

The Phoenix Media Group Inc. will make a reasonable effort to make sure persons understand how their personal information will be used by the Phoenix Media Group Inc. Consent will be obtained from persons before or when it collects or uses the personal information. The Phoenix Media Group Inc. will not attempt to deceive persons into giving consent.

A person's consent can be express, implied, or given through an authorized representative. A person can withdraw consent at any time, with certain exceptions noted herein. The Phoenix Media Group Inc., however, may collect, use or disclose personal information without the person's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

Note: If any person at any time has any questions or concerns about Phoenix Media Group Inc. privacy practices, the person can write to The Phoenix Media Group Inc., 1775 Sprucewood Avenue, LaSalle, Ontario, N9J 1X7.

Refusing or withdrawing consent:

Subject to legal and contractual requirements, a person can refuse to consent to the Phoenix Media Group Inc. collection, use or disclosure of personal information about the person, or a person may withdraw the person's consent to the Phoenix Media Group's further collection, use or disclosure of personal information at any time in the future by giving the Phoenix Media Group Inc. reasonable notice, unless: i) the consent relates to certain information required for credit approval which a person applies for or accepts, ii) the consent is otherwise required by law or iii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If a person refuses or withdraws the person's consent, the Phoenix Media Group Inc. may not be able to provide the person or continue to provide the person with some products, services or information which may be of value to the person.

Internet Aspects:

Personal information may be collected when a user conducts activities on the Phoenix Media Group Inc. website (windsoressexnews.com) or related to services made available on the Phoenix Media Group Inc. website. Although information collected, used or disclosed on the Internet as described below often does not constitute personal information (and to the extent that such is the case, then the obligations under the Phoenix Media Group Inc. Privacy Code do not extend to such information), the Phoenix Media Group Inc. provides the details below about Internet aspects of Phoenix Media Group Inc. for the purposes of disclosure about our services.

Internet Protocol Address (IP Address)

When the user's web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address." For most users accessing the Internet from a dial-up Internet service provider (ISP), the IP address will be different every time the user logs on.

Phoenix Media Group Inc. may use the user's IP Address to:

• facilitate the diagnosis and remedy of a technical problem reported by the user's or Phoenix Media Group's technical team.

• display (or allow the display by third party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user's geographic area.

• estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.

Links To Other Sites And Advertisements

The Phoenix Media Group Inc. web page contains links to other websites and services. While the Phoenix Media Group Inc. tries to link only to sites and services that share our high standards and respect for privacy, a user should understand that the Phoenix Media Group Inc. is not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Code applies only to the Phoenix Media Group Inc.

The majority of the advertisements which are displayed in connection with the Phoenix Media Group Inc. are served through one or more reputable third party advertisement-serving companies which deliver the advertisements to users in conjunction with the Phoenix Media Group Inc.

Additional Information

The Phoenix Media Group Inc. automatically collects certain information about the user's computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring web site addresses. This information is used by the Phoenix Media Group Inc. to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the the Phoenix Media Group Inc. website.

Certain Phoenix Media Group Inc. services may be co-branded and offered in conjunction with another company. If a user registers for or uses such services, both the Phoenix Media Group Inc. and the other company may receive information collected in conjunction with the co-branded services.