We respect your Privacy and protect the confidentiality of your Personal Information.

This Privacy Policy of 407 ETR (“our”, “we” and “us”) has been established in accordance with applicable legislation and to inform our customers, service providers and other individuals (“you” and “your”) about our practices and procedures concerning the collection, use, disclosure and retention of Personal Information.

IMPORTANT POLICY HIGHLIGHTS

Keeping You Aware of and Informed about the Collection, Use and Disclosure of Your Personal Information

Applicable Canadian privacy legislation defines “Personal Information” as any recorded information about an identifiable individual or information that allows an individual to be identified. For the purposes of this Policy, Personal Information means recorded information about an identifiable individual other than information which is exempt under applicable legislation.

Highway 407 ETR is a state-of-the-art, open access electronic toll highway legislated to provide service under the Highway 407 Act (the “407 Act”). Under the 407 Act, we are authorized to collect, use and disclose your personal information for stipulated purposes as described in this Policy if you lease a transponder, or if a vehicle with licence plates registered in your name (the “Registered Holder”) travels Highway 407 ETR without the use of a transponder.

We may obtain your Personal Information from you, from the Ministry of Transportation, Ontario and similar entities for other jurisdictions (collectively, “MTO”) and, in certain cases, from a collection agency in order to bill you for use of Highway 407 ETR, to collect payment from you, as further described below. This Personal Information includes:

• Name
• Mailing address
• Telephone number
• Vehicle licence plate
• Driver’s licence
• Transaction history

When you lease a transponder, or when a vehicle travels Highway 407 ETR without the use of a transponder, a 407 ETR account is established upon the lease of a transponder or the first use of Highway 407 ETR, as the case may be, unless in the case of the lease of the transponder, you have registered for an Anonymous Account. Except in the case of an Anonymous Account, a 407 ETR account is always established in the name and address of the transponder lessee or Registered Holder, as the case may be, regardless of who drives the vehicle at the time of the recorded trip(s). In the case of the Registered Holder, we then collect Personal Information of that person from the MTO for billing and collection purposes. 407 ETR’s transponders are proprietary encrypted to further protect customers’ privacy and to prevent unauthorized use of the technology.

If you, as a transponder lessee or a Registered Holder, as the case may be, wish someone other than yourself to have access to all information on your account (such as a spouse or relative that manages your bills), please contact us to arrange this.

If you or someone on your behalf provides us and/or any of our agents with Personal Information of another individual, you represent to us at the time that such Personal Information is provided, that you have all necessary authority and/or have obtained all necessary consent from such person to enable us to collect, use, disclose and retain such Personal Information in accordance with and for the purposes set forth in this Policy.

We cannot and do not sell or otherwise disclose your Personal Information to any other company or organization to promote the products or services of that company or organization. We only disclose your Personal Information when authorized by the Act, for example, to limited third parties (such as a collection agency) in order to administer or collect payments on our behalf.

407 ETR PRIVACY POLICY

1. Accountability
2. Identifying Purpose
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure & Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance

1. Accountability

We are responsible for the Personal Information under our control and have designated a Privacy Officer to be responsible for our compliance with the principles, practices and procedures of this Policy and applicable privacy legislation. 407 ETR’s current Privacy Officer is Mr. R. Luyk, Vice President, Business Process Management.

Each of our directors, officers and personnel is responsible for the Personal Information in his or her possession or custody, as well as information that has been transferred to a third party agent for processing. Where a third party agent is located in a jurisdiction outside of Canada, Personal Information that is disclosed to and/or collected and used by that third party could be subjected to disclosure pursuant to, and as required by, the laws of that jurisdiction.

We collect, use, disclose and retain Personal Information only as permitted under the 407 Act, as amended from time to time, which permits 407 ETR to:

• collect and enforce tolls, fees and other charges owing with respect to the use of Highway 407 ETR,
• provide to organizations with whom we or the MTO have agreements relating to billing administration (including data processing), collection and enforcement of tolls,
• assist 407 ETR in traffic planning and revenue management with respect to Highway 407 ETR; and
• establish and maintain responsible commercial relations with our customers and to provide customers with information promoting the use of Highway 407 ETR or with respect to on-going service, for example, surveys to understand customer needs or advising customers on leasing, billing and payment options or other programs to meet their needs or that provide better value.

We will not collect, use or disclose your Personal Information, without your consent, except where we are required or permitted to do so by law, including under the 407 Act, such as where:

• such information could aid in an emergency situation where lives and/or safety may be at stake,
• such information is required to be disclosed for billing and/or collection of past due accounts and
• such information is required to be disclosed to establish and maintain responsible commercial relations with our customers and to provide customers with information promoting the use of Highway 407 ETR or with respect to on-going services such as surveys to understand customer needs or advising customers on leasing, billing and payment options or other programs to meet their needs or that provide better value.

When you lease a transponder, or when a vehicle with license plates registered in your name travels Highway 407 ETR, you consent to us collecting, using and disclosing your Personal Information, as it may change from time to time, for purposes identified in this Privacy Policy. This is in addition to any rights to collect, use and disclose such personal information under the 407 Act. In addition, by using our website, you consent to the collection, use and disclosure of Personal Information as described below in the Section “Privacy and Our Website”.

Subject to any legal and contractual requirements, you may request that we not retain your Personal Information by notifying us in writing and including your name, address and 407 ETR account number(s) in your communication to us. Please see the Section “Please Contact us if you have any Questions and Concerns” below for information as to how to contact us. Please note, however, that such Personal Information will only be deleted if all accounts established in your name have been paid in full, and our records show that a vehicle with licence plates registered in your name has not traveled Highway 407 ETR since your request. If a vehicle registered in your name subsequently travels Highway 407 ETR, a new account, including your Personal Information, will be established, as described above.

We shall limit the collection of Personal Information to that which is necessary for the purposes identified in the Section “Identifying Purpose” above and shall collect the information by fair and lawful means. The type of Personal Information usually collected and maintained is described under the Section “Important Policy Highlights” above.

We shall not use or disclose your Personal Information for purposes other than those for which it was collected, except with your consent or as required by law. In particular, we do not trade or sell your Personal Information.. We shall retain Personal Information only as long as is necessary for the fulfillment of the purposes stipulated in this Policy.

We strive to ensure that your Personal Information is maintained accurately, and is complete and up-to-date as is necessary for the purpose for which it is to be used. Nonetheless, we encourage you to review and confirm the accuracy of all Personal Information provided to us. If changes or corrections are required to your Personal Information, we urge you to immediately contact us as described in the Section “Please Contact us if you have any Questions or Concerns” below. We will update our records accordingly.

By law, you must provide the MTO with a change of address notice within 6 days of moving. We are not provided automatic updates by the MTO. Therefore, to ensure prompt and accurate billing, we also require that you forward this important change of address information to us in the manner set out in the Section “Please Contact us if you have any Questions or Concerns” below.

We protect all Personal Information regardless of the format in which it is held. Protections include administrative and technological safeguards appropriate to the sensitivity of your Personal Information, such as:

• physical measures – locked filing cabinets and restricted access to cabinets and offices,
• organizational measures – security clearances, verification and limited access on a "need to know" basis, and
• technological measures – the use of passwords and encryption.

As indicated above, any third party involved in processing your Personal Information on our behalf is bound to comply with this Privacy Policy and must therefore provide a comparable level of protection for your Personal Information.

We will make readily available to you specific information about policies, practices and guidelines relating to our management of Personal Information. The current version of our Privacy Policy is available on our website. Upon request, this Privacy Policy is also available offline in printed form. We are also pleased to respond to any questions you might have about this Privacy Policy or about our management of Personal Information. For more information, see the section "Please Contact us if you have any Questions or Concerns" below.

In accordance with applicable legislation, we will give you access to your Personal Information retained by us within the time periods prescribed by applicable legislation after receipt of your written request accompanied by satisfactory identification. You also have the right to know of the existence of , and our use and disclosure of your Personal Information. We may charge a nominal fee for responding to any request, and if so, we will give you notice in advance of the costs associated with processing your request.

If we deny a request for access to your Personal Information, we will advise you in writing of the reason(s) for the refusal. You may challenge our decision by contacting us in the manner set out in the Section “Please contact us if you have any Questions or Concerns” below. Examples of the reasons why we may not be able to provide you with access to your Personal Information include where:

• providing such access would likely reveal Personal Information about a third party,
• the information cannot be disclosed for legal, security or commercial proprietary reasons, or
• the information is subject to solicitor-client or litigation privilege.

You may also challenge the accuracy and completeness of your Personal Information and request that it be amended, as appropriate.

You may address a concern or challenge concerning our compliance with any of the above principles in the manner outlined in the Section "Please Contact us if you have any Questions or Concerns" below.

If you have any questions or concerns regarding our collection, use or disclosure of your Personal Information, please contact our Privacy Office at:

Customer Advocacy & Privacy Office
6300 Steeles Avenue West,
Woodbridge Ontario, Canada
L4H 1J1

or our customer service line at 1-888-407-0407.

See FAQ section for answers to commonly asked questions about Highway 407 ETR.

Privacy and our Website

• Cookies – When an individual visitor accesses our website, we may use a browser feature called a “cookie” to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor accessed our website, the date and duration of the visit, the number of visits, the average time spent on our website, the pages viewed and the number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the browser of the visitor, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know the identity of the individual visitors. In addition to the Identified Purposes set out in this Privacy Policy, we may use this website information and share it with other organizations with which we have a commercial relationship to mea sure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.

Online Communications

• If our website visitors wish to ask a question, obtain information, review or download a document, and participate in contests and surveys, they will need to submit Personal Information to us in order to enable us to provide the requested information or service. If you are known to us as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.

Changes to the Privacy Policy

We reserve the right to modify or supplement this Policy at any time. If we make a change to this Policy, we will post such changes on our website and make the revised Policy and changes available offline upon request to our Privacy Officer. However, we will obtain any consent required under applicable privacy laws if we seek to collect, use, disclose or retain your Personal Information for purposes other than those to which consent has already been given, unless otherwise required or permitted by law.

October 19, 2006