Kevin Murphy is responsible for our privacy policies for both customer information and staff information. He trains all our staff in how to handle the personal information of customers. He also will be happy to provide any information about our policy and about your information, including copies of your personal information if we have that information. He can be contacted in any of the following ways:

Kevin Murphy
Privacy Officer
Advocate Group of Companies
Box 1000
Pictou, NS
B0K 1H0
Ph: 902-485-1900
Fx: 902-485-6353
Email: k_murphy@advocateprinting.ns.ca

2. Identifying Purposes

Each of the Advocate Group of Companies gathers information for different purposes.

PRINTING

In our Printing and Publishing operations we gather information:

PUBLISHING

Advocate publishes a wide variety of magazines and newspapers. We gather information for these operations:

RESEARCH

Our consumer research division conducts interviews with members of the public to assess public opinion. In conducting this research, it gathers publicly available information:

MAIL DISTRIBUTION

The Advocate Group of Companies also provides mail and flyer distribution services. To that end, it is the recipient of mailing lists provided by third parties. The information provided to use is used to process and deliver printed material on behalf of its clients. 3. Consent

The knowledge and consent of our customers are required for the collection, use and disclosure of personal information except where inappropriate.

In obtaining consent, we will use reasonable efforts to ensure that customer is advised of the identified purposes for which personal information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood.

The Advocate Group of Companies may disclose personal information without customer knowledge or consent to a lawyer representing us, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law. In the case of debt collection, only the information necessary to collect the debt is turned over (e.g., invoice details and contact information).

In general, the use of products and services by a customer constitutes implied consent for the Advocate Group of Companies to collect, use and disclose personal information for all identified purposes.

We also collect electronic information from our websites about your navigational preferences while on our websites. In some cases, digital logs of those preferences known as "cookies" are stored on your computer's website browser. Your browser has the option of denying cookies. Acceptance of cookies is assumed to be implied consent.

4. Limiting Collection

The Advocate Group of Companies limits the information we collect to that which is necessary to deliver goods and services and to meet standard billing, accounting and human resource practices.

We keep on our customer files your name, address, phone and fax numbers as well as your email address. We also record whether or not you have given us your authorization to use your personal information to promote our other products and services. We will assume you have refused this authorization unless you have given it in writing or by email. We also collect information from other sources including credit bureaus, references, and third parties who represent that they have the right to disclose the information.

5. Limiting Use, Disclosure, and Retention

We use the information you have provided to us only for the purposes outlined above, and we do not sell or lend out information to anyone else. Our employees do not have access to your records unless they are providing a service to you. Law enforcement agencies have a right under various laws to have access to the information you provided to us. We require them to provide warrants and lawful instruments before we provide them with your information.

We keep a record of your printing and subscription history in an active file for ten years. If you ask us, we will keep it in perpetuity; otherwise we will purge the files at that time.

The completed paper questionnaires from our public opinion research studies are kept for 12 months. They are then destroyed.

Databases provided to us by our clients are kept electronically on a secure computer. These database files are kept until the client has paid their bill and are then purged from the system. Clients can request that we keep them longer.

6. Accuracy

Prior to completing any work or processing a subscription we open a computerized client file. The information in this file is secure. The personal contact information is also displayed on your invoice or renewal forms. We encourage customers to verify that the information is accurate. It is not altered unless an error is detected or you inform us of a change. If you have concerns about the accuracy of our records, please speak with Kevin Murphy, our privacy officer; he will be happy to assist you.

7. Safeguards

The Advocate Group of Companies will protect your personal information by security safeguards appropriate to the sensitivity of the information. We will protect personal information against theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of format in which it is held.

Advocate will protect information disclosed 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 to respect the confidentiality of that information.

8. Openness

This policy, and our staff policy, are freely available from our privacy officer or from our various websites.

Upon request we will provide a description of the type of information we have in your customer or employee file and provide a general account of its use. Requests and inquiries should be made to:

Kevin Murphy
Privacy Officer
Advocate Group of Companies
B0x 1000
Pictou, NS
B0K 1H0
Ph: 902-485-1900
Fx: 902-485-6353
Email: k_murphy@advocateprinting.ns.ca

Our employee and customer privacy policies can be found at the following website addresses:

www.advocateprinting.com
www.advocatecommunications.com
www.omgatlantic.ca
www.ocean-resources.com
www.bargainhunterpress.com

9. Access

We will be happy to provide you with copies of all the records we have of your customer relationship with us. For competitive reasons, we will not provide information about our costs. If you feel that the information on your file is inaccurate, you are invited to bring it to the attention of our privacy officer and ask for it to be amended. In the event that we disagree with your view of the accuracy of the data, we will be happy to include your comments about the information into the file.

10. Challenging Compliance

We are anxious to ensure that our privacy policy meets your concerns and responds to your needs. Our privacy officer, Kevin Murphy, is available to receive your inquiries and complaints. He will investigate your request and respond to you with his findings within a reasonable amount of time (generally within 5 business days). If a complaint is found to be justified, the Advocate Group of Companies will take the appropriate measure to resolve the complaint to your satisfaction, including amending our policies and procedures.

If you are unhappy with the results of our efforts, you may complain to:

Office of the Federal Privacy Commissioner
112 Kent Street
Ottawa, Ontario
K1A 1H3
Toll-free: 1-800-282-1376
info@privcom.gc.ca.

Scope and Application

The above ten principles, which form the basis of the Advocate Group of Companies' privacy code are interrelated. We will adhere to the principles as a whole.

The scope and application of our privacy code is as follows:

=> A customer's name, address, telephone number and e-mail address, when listed in a directory or available through directory assistance;
=> An employee's name, title, business address (including e-mail address) or business telephone or fax number; or,
=> Other information about the customer that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Document Act.