WALTHER ENTERPRISES
privacy policy

(Last Updated on Jan. 22, 2010)

Walther Enterprises respects the privacy of all of its users and is committed to protecting such privacy in accordance with this Privacy Policy. This Privacy Policy explains Walther Enterprises' and its subsidiaries' ("WE") treatment of your personally identifiable information collected in connection with your activities on or related to all WE websites referencing this Privacy Policy (the "WE Sites") and all services made available on the WE Sites (collectively, unless noted otherwise, the "WE Services"). This Privacy Policy also explains how you can ask questions and make suggestions about our privacy practices and review and update your personal information.

We urge you to read this Privacy Policy carefully and to check back periodically as this Privacy Policy may change from time to time. Please note that this Privacy Policy does not apply to the practices of companies or websites which are not owned or controlled by WE.

INFORMATION COLLECTED
In the course of operating the WE Services, we may collect two types of information about our users: Personal Information and Non-Personal Information.

"Personal Information" is personally identifiable information, such as your name, address, E-mail address, birth date and gender. Personal Information is collected by us when you choose to provide it to us when registering for a WE Service, such as when you choose to subscribe to a WE Service, enter a WE promotion or choose to receive a WE newsletter. In addition, if you choose to contact any of our customer service representatives, we may keep a record of that correspondence so that we may fully address the subject matter. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information.

Business contact information such as the name, title, business address, E-mail address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.

"Non-Personal Information" is information of an anonymous nature, such as your Internet Protocol Address (IP Address), the domain you may have used to access a WE Service, the type and version of browser or operating system you may be using, and the website you may have come from and visit next. Aggregate information, such as demographic statistics of our users (i.e., average age or geographical allocation of our users), number of visitors and average time spent on a WE Service, is also considered Non-Personal Information.

Non-Personal Information is collected or derived by us in the course of operating the WE Services. For example, our web servers may automatically collect Non-Personal Information which is provided through your browser or stored on a cookie or through a web beacon when you choose to visit a WE Service. Non-Personal Information is used by WE as described here.

USE OF PERSONAL INFORMATION
Personal Information may be used by us for the following purposes:

(a) providing you with the WE Services and information you have requested from us, including your use of the WE Sites. We may from time to time use your Personal Information to contact you about changes, enhancements or similar notices related to the WE Services;

(b) if you indicated that you were interested in receiving offers or information from WE or certain of our selected sponsors or advertisers, WE may send you E-mail materials and other mailings about products and services that we feel may be of interest to you. If at any time you would like to end your subscription to any such E-mail materials, follow the instructions at the end of the message;

(c) if you enter a contest or other promotion offered on a WE Site, we may, under the rules of the promotion, use your name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion;

(d) WE may also use Personal Information if it has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law or in order to protect or defend a legal interest.

DISCLOSURE OF PERSONAL INFORMATION
We will not sell or rent your Personal Information to anyone.

We will only disclose your Personal Information to third parties:

(a) where you have specifically given us your consent to disclose your Personal Information for a designated purpose;

(b) who are acting on our behalf as our agents, suppliers or service providers, solely to enable us to more efficiently provide you with the WE Services. Such entities act under strict contractual controls, requiring them to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of the WE Services;

(c) as may be set out in the Terms And Conditions applicable to a WE Service, to facilitate the provision of such WE Service, such as fulfilling legal requirements;

(d) as required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest;

(e) in connection with a WE corporate re-organization, merger or amalgamation with another entity, or a sale of all or a substantial portion of the assets of WE provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

LINKS TO OTHER SITES AND ADVERTISEMENTS
A WE Service may contain links to other websites and services. While we try to link only to sites and services that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Policy applies only to the WE Services referencing this Privacy Policy.

SECURITY
The security of your Personal Information is important to us. WE takes technical, contractual, administrative, and physical security steps to protect Personal Information that you provide to us. We instruct our employees with access to your Personal Information that it is to be used only in adherence with the principles set forth in this Privacy Policy and the laws applicable to each specific business.

In certain areas, such as when you provide credit card information to us, we work to help protect the security of your credit card information during transmission by using industry-standard Secure Sockets Layer (SSL) encryption technology.

CHANGES TO THIS PRIVACY POLICY
WE may from time to time change its Privacy Policy as new WE Services are added or old ones changed. Changes will be effective when notice of such change is posted at a WE Site. Please check this Privacy Policy regularly for updates by checking the date of "Last Update" at the top of this document.

ACCESSING AND CHANGING ACCOUNT OR REGISTRATION INFORMATION
WE provides you with the means to access, update, edit or delete any Account or Registration Information you may have provided to us at any time by sending an E-mail to the relevant WE Service, and requesting a change or deletion of such information as desired.

If you are unsure whether we have a record containing any of your Personal Information and would like to confirm whether or not we do, please send an E-mail to our Privacy Manager by , indicating all E-mail addresses that you may have given us.

If you decide at any time that you do not want to receive any E-mail materials to which you have subscribed, you may choose to unsubscribe to these E-mails by following the instructions at the end of the message.

QUESTIONS, COMMENTS OR SUGGESTIONS
If you have questions, comments or suggestions about this Privacy Policy or WE's privacy practices that were not answered here, send our Privacy Manager an E-mail by .

WE USE OF NON-PERSONAL INFORMATION
Non-Personal Information is collected or derived by us in the course of operating the WE Services. For example, our web servers may automatically collect Non-Personal Information which is provided through your browser or stored on a cookie or through a web beacon when you choose to visit a WE Service.

In addition to WE's practices related to IP Addresses, cookies or web beacons, Non-Personal Information is used generally by WE to monitor and improve the operation of the WE Services, to perform statistical analyses of the collective characteristics and behavior of our users, to measure user demographics and interests regarding specific WE Services, to describe our services to third parties such as prospective business partners and advertisers and to analyze how and where best to use our resources. No Personal Information will be disclosed during these activities.

WE may also use Non-Personal Information to inform our sponsors and advertisers as to the performance of a particular sponsorship (such as a contest) or advertisement. In such case we may disclose to those third-party sponsors and advertisers the overall aggregate demographics available regarding, for example, who participated in a contest or who saw and clicked on an advertisement. No Personal Information will be disclosed to these sponsors and advertisers as part of this process; only information in an anonymous, aggregate form will be disclosed.

IP ADDRESSES
An IP Address is the unique number which is assigned to every direct Internet access point. Many IP Addresses can generally be associated with certain Internet service providers or large organizations. IP Addresses do not contain any Personal Information. When you, through your browser, request a web page or similar Internet information from another computer on the Internet, your browser automatically provides that computer with an IP address to which it will send the requested information.

WE and IP Addresses:

(a) whenever you request a WE Service web page or certain other similar WE content, your browser automatically provides our computers with your IP Address, to which our computers will send the requested information. Each such request is logged by our computers with information including the IP Address of the computer that requested the page and is stored by our computers as needed for the purposes described in this policy;

(b) WE may use your IP Address to display more appropriate and relevant content and advertising, such as content and advertising based on your geographic area. Aggregate information derived from IP Addresses may be reported by WE to its advertisers and partners. For example, WE may report to its advertisers the estimated total number of users accessing a particular WE Site from a specific province;

(c) WE may use your IP Address to facilitate the diagnoses and remedy of a technical problem reported by you or our technical team.

COOKIES AND WEB BEACONS
A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser and will NOT let a website know any personal information about you, such as your name and address. Since cookies are only text files, they cannot run on your computer, search your computer for other information or transmit any information to anyone.

WE may use cookies to:

(a) monitor website usage and improve the operation and performance of the WE Services and to make our WE Services easier and more convenient to use. For example, cookies help us remember who you are through your browser settings so that we can offer and provide more personalized services (i.e., language preference). Cookies also allow us to save passwords and preferences for you so that you will not have to re-enter them the next time you visit a WE Service;

(b) measure aggregate user traffic and demographic statistics related to the WE Services and advertisements (i.e., number of users, average time spent, average age and similar statistics). This information helps us to better understand when to update, change or offer new services and provides us with details as to the performance of third-party advertisements and content. This information may be reported, in aggregate form only, to our current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports;

(c) display advertisements. WE and third-party advertising providers used by WE may use cookies when serving advertisements.

Cookies are used on many major websites. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You should understand that while WE does not require you to use cookies, certain WE Services will not function properly if you set your browser to not accept cookies.

Certain WE Services may contain electronic images known as web beacons sometimes called single-pixel GIFs that allow WE to count users who have visited those pages and to deliver co-branded services. Web beacons are not used to access your Personal Information; they are a technique used to compile aggregated statistics about WE Service usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. Certain WE Service web pages may also contain web beacons placed there by our advertising partners to help WE determine the effectiveness of our Internet advertising campaigns.

905-650-6611 — — Box 980, Virgil, Ontario L0S 1T0

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