Your Privacy Rights
From January 1, 2004 all businesses engaging in commercial activities must comply with the Personal Information Protection and Electronic Documents Act. This federal legislation gives you rights concerning the privacy of your personal information. ypOne is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy, and have trained our staff in regard to our policies and practices.

What is Personal Information?
Personal information is any information that identifies you, or by which your identity can be deduced. This information does not include your business name, address or telephone number.

Why Is Personal Information Collected by ypOne?
ypOne provides services and products to a wide range of customers. We collect personal information from our customers to provide the services requested.

How Do We Collect Your Personal Information?
We collect information only by lawful and fair means and not in any unreasonably intrusive way. We collect your personal information directly from you, with your implied consent and in the course of providing services to you.

Consent
Consent for the collection, use and disclosure of personal information may be obtained orally or in writing, and may be expressly given or implied.

Use of Your Information
We will use your personal information to provide the requested services to you, to administer our time and billing databases, and also to include you in any direct marketing activities. If you inform us that you no longer wish to receive information about our services, we will not send you any further material. ypOne does not disclose your personal information to any third party to enable them to market their products and services without first obtaining express consent from you. For example, we do not provide our customer mailing lists to other businesses.

Disclosure of Personal Information
Under certain circumstances, ypOne may need to disclose your personal information:

• when we are required or authorized by law to do so, for example if the court issues a subpoena;
• when you have consented to the disclosure;
• when the services we are providing to you requires us to give your information to third parties your consent will be implied, unless you tell us otherwise;
• where it is necessary to establish or collect fees;
• if we engage a third party to provide administrative services to us (like computer back-up services or archival file storage) and the third party is bound by our privacy policy;
• if we engage an expert on your behalf;
• if the information is already publicly known.

Updating Your Information
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If any of your information changes, please inform us so that we can make any necessary changes.

Is My Personal Information Secure?
ypOne takes all reasonable precautions to ensure your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among these steps to protect your information are:

• premises security;
• restricted file access to personal information;
• deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
• internal password and security policies;
• obligation of each ypOne employee to maintain customer confidentiality

Access to Your Personal Information
You may ask for access to any personal information we hold about you. Summary information is available upon request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees. Please make your request for information, in writing to our Privacy Officer.

Correcting Errors
If ypOne holds information about you and you can establish that it is not accurate, complete and up-to-date, ypOne will take reasonable steps to correct it.

Can I be Denied Access to My Personal Information?
Your rights to access your personal information are not absolute.
We may deny access when:

• denial of access is required or authorized by law;
• when granting you access would have an unreasonable impact on other people's privacy;
• when to do so would prejudice negotiations with you;
• to protect our company’s rights and property;
• where the request is frivolous or vexatious.
• If we deny your request for access to, or refuse a request to correct, information, we shall explain why. ypOne does not use your Social Insurance Number as a way of identifying or organizing the information we hold about you.

Can I Request Anonymity?
Whenever it is legal and practical, we may decide to deal with general inquiries on an anonymous basis (for example, by accessing general information on our website).

Credit Bureaus
To help us make credit decisions about our customers, prevent fraud, check identity of new customers and prevent money-laundering, we may on occasion, request information about you from the files of consumer reporting agencies.

How Long Do You Keep My Personal Information?
ypOne will keep your personal information as long as is necessary for us to complete our business with you, or as may be required by law, whichever is longer.

Communicating With Us
You should be aware that e-mail is not a 100% secure medium, and you should be aware of this when contacting us to send personal and confidential information.

Changes to this Privacy Policy
Since ypOne regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time.

Requests for Access
If you have any questions, or wish to access your personal information, please write to our Privacy Officer Angela Murphy, at ypOne, 803 Park Two, Sugar Land, Texas 77478. Or, by e-mail at amurphy@yponeinc.com

Employment Inquiries
The Act does not apply to our employee information. However, we have elected to follow privacy practices in this area. If you wish to apply to ypOne for a job, we need to consider your personal information as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.

Web Site
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include identifiable personal information.

Inquiries / Complaints
If you have any questions or concerns regarding how your personal information has, is or will be handled by ypOne or if you would like to register a complaint, please contact our Privacy Officer, Leslie S. Lynch, at: 803 Park Two, Sugar Land, Texas 77478. Or, by e-mail at: llynch@yponeinc.com