We, at Northern Reflections Ltd. are firmly committed to protecting the privacy, confidentiality, accuracy and security of our customer's personal information. We do not collect any personally identifying information about customers unless it has been specifically provided to us by the customer. We will not sell, trade or rent any personal information of our customers to any third parties. If you are under 18 be sure to obtain your parent(s) or guardian(s) permission before you send any personal information to us. We have created this privacy policy in order to demonstrate our firm commitment to protect our customer's privacy and to answer the following questions:

• What personal information may be collected from you as our customer
• How is the personal information used
• With whom may the information be shared
• What choices are available to you regarding collection, use and disclosure of the information
• What kind of security procedures are in place to protect loss, misuse or alteration of information under our control
• How can you correct any inaccuracies in the information
• How long do we keep your personal information

Our privacy policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information (CAN/CSA-Q30-96) and describes how Northern Reflections subscribes to the following Ten Privacy Principals in summary:

Principle 1 - Accountability
Northern Reflections is responsible for maintaining and protecting customer personal information under its control. Northern Reflections has formed a Privacy Team comprised of associates who are accountable for Northern Reflections' compliance with our Ten Privacy Principles.

Principle 2 - Identifying purposes
The purpose for collecting personal information from our customer will be identified before the information is collected.

Principle 3 - Consent
We shall require the customer's knowledge and consent for the collection, use or disclosure of their personal information, except where required or permitted by law.

Principle 4 - Limiting Collection
Any personal information we collect from our customer, by fair and lawful means, will be limited to only those details necessary for the identified purpose. We will not collect more information than we need to fulfill the purpose identified to our customer.

Principle 5 - Limiting Use, Disclosure, and Retention
Our customer's personal information will not be used or disclosed for purposes other than those for which it was collected, except with the customer's consent or as required by law. We will keep customer's personal information only for as long as necessary to fulfill the purpose identified to our customer.

Principle 6 - Accuracy
We will keep our customer's personal information accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 - Safeguards
Customer's personal information shall be protected with security measures that are appropriate for the sensitivity level of the information.

Principle 8 - Openness
We will provide and make readily available to customers information on our policies, procedures and practices relating to how the customer's personal information is managed.

Principle 9 - Customer Access
Upon request, a customer will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. A customer may verify the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Compliance
A customer may forward any questions or enquiries about compliance with these privacy principles to our Privacy Team Coordinator.

Northern Reflections' optional registration form requires you to provide us with contact information (such as your name, address, and e-mail address). This contact information may be used to send you information about Northern Reflections, the latest fashion news and advance notice of upcoming in-store sales, events, discounts and promotions and is used to contact you when necessary to answer your questions and to respond to your feedback, responses, etc. This contact information is transferred via secure automatic data transfer to our e-mail service provider who tracks campaign activities and results and provides information about our customers' needs. Northern Reflections uses contractual or other comparable means to protect customers' personal information and to make sure that the e-mail service provider uses the information only for these stated purposes. If you would like to be added to or removed from the e-mail lists, you can:

• E-mail Customer Relations at NRCustomer.Relations@NorthernReflections.com
• Call Customer Relations at 1-877-902-5608
• Send standard mail requests to the following postal address:
  
  Northern Reflections Ltd.
  c/o Customer Relations
  2375 Skymark Avenue
  Mississauga
  Ontario
  L4W 4Y6

Northern Reflections uses URL addresses to analyze trends, administer Web sites, track users' movements throughout the Web site and gather broad demographic information for aggregate use. URL addresses are not however linked to personally identifiable information.

We may occasionally run contests on our Web sites where visitors are asked for personal information such as name, e-mail addresses or telephone numbers. Participation in our contests is not mandatory. If however, you choose to participate, we may use this contact information to send you information about other contests and about Northern Reflections. This contact information is transferred in a secure online environment to Northern Reflections' Web site development service provider to manage the entries. Northern Reflections uses contractual or other comparable means to protect customers' personal information and to make sure that the Web site development service provider uses the information only for these stated purposes. If you have participated in a past contest but no longer wish to receive information or to be contacted, you have the following options:

• E-mail Customer Relations at NRCustomer.Relations@NorthernReflections.com
• Call Customer Relations at 1-877-902-5608
• Click on the unsubscribe link included at the bottom of each of our e-mails and follow the instructions indicated on the webpage Send standard mail requests to the following postal address:
  
  Northern Reflections Ltd.
  c/o Customer Relations
  2375 Skymark Avenue
  Mississauga
  Ontario
  L4W 4Y6

We may also run contests in our stores where you will complete an entry form providing your personal information such as name, address, telephone number and e-mail address. The personal information you provide is used solely for purposes of the contest and to contact you if you win. After the official draw, all entry forms are destroyed, unless you have otherwise consented to let us use your personal information for another purpose.

If you elect to use our referral service to inform a friend about our site or product offering, you will be asked to provide the friend's name and e-mail address. We do not, however, retain the friend's name and e-mail address in our database or any other place.

We have established security measures appropriate to the sensitivity level of information to protect against unauthorized access, disclosure, inappropriate alteration or misuse of information.

To keep our customers' personal information secure, we use industry-leading Secure Socket Layer (SSL) technology. When you submit personal information on our Web site it is immediately encrypted.

Cookies are small data files stored on your computer to allow information flow. We do not use cookies to store your personal information.

Our home office employees are required to comply with our Information Security Policy. In addition, all employees, including store employees, are required to abide by the privacy standards we have established. They are also required to work according to ethical behavior standards as set out in our Code of Conduct and to sign a Certificate of Compliance annually. Unauthorized access to and/or disclosure of customer personal information by an employee of Northern Reflections is strictly prohibited.

Our customers become members of this loyalty program by completing an enrollment form and purchasing a membership at any one of our stores. The personal information collected on this enrollment form is used to provide our customers with rewards based on purchases made. It is also used to communicate regular notice of sales, special incentives, store events and bonuses to our members by direct mail, e-mail or telephone marketing. Personal information is stored on a secure database maintained by our loyalty program service provider. The personal information in this database is used to collect and summarize sales information and buying trends to better understand what our Northern Friends customers buy and how to communicate with them. We also may use this information to help us explore what new products and services to offer to our Northern Friends. In order to accomplish this, we sometimes contract trusted outside organizations to analyze the information maintained in the database using contractual or other comparable means designed to protect the privacy of customers' personal information. They are also prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide.

Northern strives to keep your personal information as accurate and up-to-date as necessary. We provide you with the opportunity to update personal information you have provided, or, opt-out of receiving communications from us at any time. You have the following options for removing your information from our database or marketing lists, so as not to receive any future communications or offers of services or to update your personal information:

• E-mail Customer Relations at NRCustomer.Relations@NorthernReflections.com
• Call Customer Relations at 1-877-902-5608
• If you subscribed on our Web site, click on the unsubscribe link included at the bottom of each of our e-mails and follow the instructions indicated on the web page
• Send standard mail requests to the following postal address:
  
  Northern Reflections Ltd.
  c/o Customer Relations
  2375 Skymark Avenue
  Mississauga
  Ontario
  L4W 4Y6

If you have any questions or concerns about our personal information handling practices, please contact our Privacy Team Coordinator using any of the following methods:

• by telephone at 1-866-884-2587
• by standard mail to the following postal address:
  
  Northern Reflections Ltd.
  c/o Private Team Coordinator
  2375 Skymark Avenue
  Mississauga
  Ontario
  L4W 4Y6

Northern Reflections Ltd. reserves the right to change or modify this privacy policy and our information handling practices, but we will not do so without posting a modification date.

The provisions and practices set out in our privacy policy apply to all our retail stores in Canada and to the retail stores in the U.S., of our affiliate, Northern Reflections Ltd., and to the following Web sites:

www.northernreflections.com
www.northernreflections.us