Arctic Glacier respects your right to privacy and has developed this Privacy Statement to inform you about our privacy practices.

Overview

Privacy is of great concern to most users of the Internet and is a critical part of an enjoyable and satisfactory user experience. We are acutely aware of and sensitive to the privacy concerns of our unitholders, customers and other visitors to our Web site. Whether you are a unitholder, customer or other visitor to our Web site, we assure you that we do not collect personal information from you unless you provide it to us. We do not automatically gather any personal information during your visit to our Web site.

Please note that our site contains links to other sites including Stockwatch, The Toronto Stock Exchange and the International Packaged Ice Association. Arctic Glacier is not responsible for the privacy practices, privacy statements, or content regarding these other sites.

INFORMATION WE GATHER FROM YOU

Personal Information

We do not collect any personal information from a visitor to our site unless a visitor explicitly and intentionally provides it. Under no circumstances do we collect any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life. If you are simply browsing our site, we do not gather any personal information about you.

When you send us an e-mail or complete an on-line employment application, we will use the information that you provide to respond to concerns that you direct to our attention or to process your request. Arctic Glacier reserves the right to disclose such personal information to its affiliates, subsidiaries and third party agents in this regard.

Statistical Information About Your Visit

When you visit our site, our computers may automatically collect statistics about your visit. This information does not identify you personally, but rather about your visit to our site. We may monitor statistics such as how many people visit our site, the user's IP address, which pages people visit, from which domains our visitors come and which browsers people use. We use these statistics about your visit for aggregation purposes only. These statistics are used to help us improve the performance of our Web site.

Use of Cookies

We only use "cookies" for the purpose of collecting non-personal information and technical data so as to develop general Web site statistics such as browser information, page visit frequencies and how long visitors spend on a page. A "cookie" is a piece of information that our Web site sends to your browser, which then stores this information on your system. If a cookie is used, our Web site will be able to "remember" information about you and your preferences either until you exit your current browser window (if the cookie is temporary) or until you disable or delete the cookie. Many users prefer to use cookies in order to help navigate a Web site as seamlessly as possible. You should be aware that cookies contain no more information than you volunteer, and they are not able to "invade" your hard drive and return to the sender with personal or other information from your computer.

Disclosure by Law and Protection of Arctic Glacier and Others

If we are required by law to disclose certain information to local, provincial, state, federal, national or international government or law enforcement authorities, we will so. In addition, Arctic Glacier may share information in order to investigate, prevent, or take action regarding illegal activities or suspected fraud, or enforce or apply Arctic Glacier's agreements.

Surveys

From time-to-time we may request information from visitors via surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Survey information will be used for purposes of monitoring or improving the use of and satisfaction with this Web site, and improving our customer service.

Changes to this Privacy Statement

If a material change is made to this Privacy Statement and/or the way we use our visitors' personally identifiable information, we will post prominent notice of the nature of such change on the first page of this Privacy Statement.

© 2005, Arctic Glacier Inc. All rights reserved.

The Arctic Privacy Commitment

The Arctic Privacy Policy incorporates the provisions of Part 1 of the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) along with the ten principles of the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information that form the basis of Schedule 1 to PIPEDA.

Arctic will continue to review its Privacy Policy from time to time to ensure that it remains relevant and in step with any changes that may occur to any applicable privacy legislation.

Introduction

Arctic is a leading producer, marketer and distributor of high-quality packaged ice to consumers in Canada and the United States under the brand name of Arctic Glacier® Premium Ice. Arctic is the largest producer of packaged ice in Canada and is among the largest producers in the United States, serving over 70,000 retail, commercial and industrial customer locations throughout six provinces in Canada and fifteen states in the central, midwest, northeastern and western United States.

Customer privacy has always been a high priority at Arctic. Our privacy policy is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided to our customers and employees. The objective of the policy is to promote responsible and transparent practices in the management of personal information, in accordance with the provisions of PIPEDA.

Definitions

Arctic - Arctic Glacier Inc. and its subsidiary companies, as they may exist from time to time.

Collection - the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Arctic. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.

Customer - an individual who uses Arctic’s products or services, where such individual is a final consumer or an individual carrying on business alone, as a sole proprietorship, a partnership with other individuals.

Disclosure - making personal information available to a third party.

Employee - an employee of Arctic.

Personal Information - information about an identifiable customer or employee, but does not include aggregated information that cannot be associated with a specific individual.

For a customer, such information includes a customer's credit information, billing records, service and equipment, and any recorded complaints. For an employee, such information includes information found in personal employment files, performance appraisals, and medical and benefits information, but does not include the employee's name, title, business address (including e-mail address) or business telephone or fax numbers.

Third party - an individual or organization outside Arctic.

Use - the treatment, handling, and management of personal information by and within Arctic.

Privacy Principles

1. Accountability

Arctic is responsible for personal information under its control and shall designate one or more persons who are accountable for compliance with PIPEDA.

Responsibility for ensuring compliance with the Arctic Privacy Policy lies with Arctic's Privacy Officer, Neil Winther. The Privacy Officer shall implement policies and procedures to give effect to the Arctic Privacy Policy, including:

a) implementing procedures to protect personal information and to oversee Arctic’s compliance with the Arctic Privacy Policy;
b) establishing procedures to receive and respond to inquiries or complaints;
c) training and communicating to staff about Arctic’s policies and practices; and
d) developing public information to explain Arctic’s policies and practices.

Arctic’s Privacy Officer will be happy to respond to inquiries about the Arctic Privacy Policy or respond to the needs of a particular individual whose personal information is in our possession. The Officer will also upon request supply the individual with a copy of such personal information.

Our Privacy Officer can be contacted by one of the following methods:

- By telephone: 204-786-0236
- By facsimile: 204-783-9857
- By email: nwinther@arcticglacierinc.com
- By mail: 625 Henry Avenue; Winnipeg, MB; R3A 0V1; Canada

2. Identifying the Purposes for the Collection of Personal Information

Arctic shall identify the purposes for which personal information is collected at or before the time the information is collected.

Arctic collects customer and employee personal information only for the following purposes:

a) To establish and maintain responsible commercial relations with customers and to provide ongoing service;
b) To understand customer needs and preferences;
c) To develop, enhance market or provide products and services;
d) To manage and develop Arctic’s business and operations, including personnel and employment matters; and
e) To meet legal and regulatory requirements.

Arctic shall specify orally, electronically or in writing the purposes of collecting an individual’s personal information to the individual at or before the time that personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to the Privacy Officer who shall explain these purposes.

Unless required by law, Arctic shall not use or disclose an individual’s personal information for any new purpose without first identifying and documenting the new purpose and obtaining the individual’s consent.

3. Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a customer or employee are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.

For example, Arctic may collect or use an individual’s personal information without his or her knowledge or consent if it is clearly in their interests and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.

We may also collect, use, or disclose personal information without an individual’s knowledge or consent if seeking consent might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of a federal or a provincial law or where the life, health or security of an individual is threatened.

We may also collect, use, or disclose personal information without an individual’s knowledge or consent to a lawyer representing Arctic in the collection of a debt, to comply with a subpoena, warrant or other court order, or as may be required or authorized by law.

Generally Arctic shall seek consent to use and disclose personal information at the same time or before it collects the information. However we may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.

4. Limiting the Collection of Personal Information

We limit the information we collect to that which is necessary to conduct business, deliver a high level of service and to perform standard billing and accounting practices. Arctic gathers information for no other purpose.

Arctic collects personal information from its employees and customers as well as from other sources that may include credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.

a) Name, address and telephone number;
b) Email address and facsimile number;
c) Occupation;
d) Language preference;

5. Limiting Use, Disclosure and Retention of Personal Information

Arctic shall not use or disclose an individual’s personal information for purposes other than those for which it was collected, except with the individual’s consent or as required by law. Personal information shall only be retained as long as necessary to fulfill the purpose for which it was collected. Arctic will not sell an individual’s personal information to third parties.

Arctic may disclose a customer’s personal information to:

A third party or parties, where you consent to such disclosure or as we are required by law.

Arctic may disclose personal information about its employees:

a) For normal personnel and benefits administration;
b) In the context of providing references regarding current or former employees in response to requests from prospective employers; or
c) Where disclosure is required by law.

Arctic shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, Arctic shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.

Arctic shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

6. Accuracy of Personal Information

Personal information shall be accurate, complete and up to date as is necessary for the purposes for which it is to be used.

Personal information used by Arctic shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.

Arctic shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual. If an individual has concerns about their information’s accuracy, they may contact Arctic’s Privacy Officer.

7. Security Safeguards

Arctic shall protect every individual’s personal information by security safeguards appropriate to the sensitivity of the information. Such personal information shall be protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of its format.

Arctic will protect an individual’s personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is being used.

All Arctic employees who have permission to access personal information for business purposes shall be required to maintain the confidentiality of such information.

8. Openness Concerning Practices and Policies

Arctic shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.

Arctic shall make information readily available, including:

a) The means of contacting the Privacy Officer accountable for Arctic’s compliance with the Privacy Policy;
b) A description of the type of personal information held by Arctic, including a general account of its use;
c) A copy of any brochures or other information that explains Arctic’s policies and standards;
d) A list of personal information that is made available to related organizations such as subsidiaries.

9. Customer and Employee Access to Personal Information

Upon request, Arctic shall inform the customer or employee of the existence, use and disclosure of his or her personal information and shall give the individual access to that information. The information will also be provided upon request to the customer or employee at minimal or no cost, in an understandable form and within a reasonable amount of time.

In certain situations, Arctic may not be able to provide access to all the personal information that it holds regarding a customer or employee. For example, Arctic may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Arctic may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor - client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Arctic shall provide the reasons for denying access upon request.

Upon request, Arctic shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Arctic shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.

In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit Arctic to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose.

Customers can obtain information or seek access to their individual files by contacting the Arctic Privacy Officer. Employees can obtain information or seek access to their individual files by contacting their immediate supervisor within Arctic.

10. Challenging Compliance

A customer or employee shall be able to address a challenge concerning compliance with the above principles to Arctic’s designated Privacy Officer.

The Arctic Privacy Officer shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees regarding Arctic’s handling of personal information. Customers and employees shall be informed of the existence and availability of these complaint procedures.

Arctic shall investigate all complaints concerning compliance with the Arctic Privacy Policy. If a complaint is found to be justified, Arctic shall take appropriate measures to resolve the complaint including if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.

To contact the Office of the Federal Privacy Commissioner, write to: 112 Kent Street, Ottawa, Ontario, K1A 1H3 or visit their web site at: www.privcom.gc.ca.