PRIVACY POLICY

Druxy’s Inc., as the operator of the Druxy’s family of companies, including but not necessarily limited to Druxy’s Franchising Inc. as franchisor for the Druxy’s system of quick-service delicatessen restaurants and through its affiliated corporations, is also the operator of corporately-owned delicatessen restaurants, is committed to the protection of its customers’ Personal Information (as defined below). As evidence of this commitment, we have implemented the following Privacy Policy (the “Policy”), which complies with or exceeds the requirements of the federal Personal Information Protection and Electronic Documents Act, also known as “PIPEDA”. References in this Policy to “we”, “our”, “the franchisor” or “Druxy’s” are references to Druxy’s Inc., its affiliated corporations, and its franchisees unless otherwise indicated.

This Policy is designed to assist our franchisees, employees, and customers in understanding how we collect, store, use, disclose, protect and ensure the accuracy of information collected and controlled by Druxy’s. It also applies to all Personal Information held in Druxy’s databases and utilized by our franchisees and employees.

What is personal information?
The Personal Information Protection and Electronic Documents Act became enforceable in respect of the public sector in Canada on January 1, 2004, to ensure that information that individuals provide in commerce as any form of “record”, including photographs, commentary, or factual information, is used in an appropriate manner, with their consent, and properly protected by those to whom the Personal Information is given. The legislation defines Personal Information as “information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization”. In other words, it is information particular to an individual that would allow them to be identified. This would include your name, residential address, e-mail address(es), telephone number, credit card particulars, and your personal purchasing history.

Why we collect personal information
Druxy’s collects personal information in order to facilitate the services that are offered through our network of franchisees and our corporately-owned restaurants to you, the customer. This means that our affiliated corporations, franchisees and employees collect Personal Information in order to assist you with offering the most enjoyable and satisfying dining experience possible. Druxy’s not only collects Personal Information about its customers but also about its franchisees, for example, to determine their credit-worthiness or for the preparation and/or registration of documents needed to grant a franchise to an individual. Druxy’s, its affiliated corporations and its franchisees may put Personal Information to a variety of uses, which may include invoicing customer accounts as appropriate; communicating information and offers to customers; to better understand, analyze, and respond to our customers’ needs and preferences, and to subsequently develop, enhance, and/or provide products and services to meet those needs. We do not collect Personal Information for any other reason other than as described in this Policy, nor is it used in any way other than as described herein.

Consent
We try to ensure that you understand how we use your Personal Information. One of the ways this is done is by obtaining your consent. Consent may be either express or implied. Express consent is given when we specifically ask you if it acceptable to you that we gather certain information and you explicitly agree that it is. Implied consent occurs when you provide information that may be Personal Information without objection. As we obtain only the 670683v1 information necessary to assist you with the transaction you require, we operate under the understanding that you have agreed to provide us with this Personal Information voluntarily and with knowledge of this Policy whenever you do so.

Use and retention of your personal information
We will retain your Personal Information for as long as we provide or may potentially provide services to you. When your Personal Information is no longer necessary to Druxy’s for the purposes described in this Policy, we will destroy, erase, or de-personalize the Personal Information. The only exception to this will be where we may be required to keep or provide your Personal Information as a result of legislation, as required by law or government regulation, or due to a binding court order.

No sharing, selling or bartering of your personal information
Your Personal information is not given, rented, or sold to any third party for any reason. It may be combined with other Personal Information collected by Druxy’s or our franchisees to provide us with aggregate statistical information about our customers’ purchasing/service usage preferences, but at no time will your Personal Information be shared with any other parties that might be involved in this aggregate collection of Information. ACCURACY To ensure that the Personal Information you provide to us is accurate, complete, and up-to-date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the Personal Information we may hold. SECURITY We employ ongoing security measures in an effort to protect Personal Information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. Your Personal Information is protected by implementing the following kinds of safety precautions:

1. physical, such as the locking of filing cabinets or restricting access to certain areas of our offices to appropriate personnel;
2. administrative/organizational, such as the implementation of proper policies to be followed by all Druxy’s employees, agents, franchisees and affiliates, and to ensure that they are trained to know their ongoing obligations to you. Employees, agents, our affiliated corporations and our franchisees are provided with only the Personal Information that is necessary for them to perform their duties properly and with no other Information or for any other purpose, and
3. technological, such as the utilization of passwords, encryption, and secure servers on all of our computers and/or electronic databases. Personal Information is stored on-site at our franchisees’ places of business, on-site at the locations of any corporate-owned restaurants, and/or at Druxy’s head office in Gormley, Ontario, Canada, and is protected using some or all of the above safeguards, as appropriate.

Access
You are entitled to know what Personal Information about you that we have collected, as well as how it has or will be used. If you provide a written request for this information, we will provide it 670683v1 to you within 60 days of confirmation of your identity. We will inform you whether or not we hold Personal Information about you and, when possible, the source of the Information, its use, and any parties to which it may have been disclosed.

This Policy can also be viewed through the Druxy’s website, at www.druxys.com, or via letter mail upon request. You may be required to provide sufficient proof of your identity at this time to ensure the safety and security of the Information we hold and that it is provided to individuals in accordance with this Policy. In the event that we cannot provide a complete list of the Personal Information that we have collected about you, we will provide you with the reasons why your access to this information is being denied. This usually takes place in only limited circumstances, where we may not be able to supply Personal Information as a result of legal requirements. Whenever possible, we will give you given appropriate reasons as to why this is the case, however, in certain instances, such as in certain criminal investigations, we may not be able to provide you with any reasons as to why your Personal Information cannot be provided.

Satisfaction
We are committed to ensuring that you have full knowledge of how and why we collect your Personal Information, and what is done with it. If you wish to offer comments or challenge the compliance with the federal or provincial legislation of the Policy, we invite you to send a letter addressed to Druxy’s Inc., Attention: Privacy Compliance Officer, 52 Abbotsford Rd., Gormley, Ontario, L0H 1G0. We will respond as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address the concern or implement the suggestion, including, if necessary, amending the policies and procedures of Druxy’s.

Amendment to the Druxy’s privacy policy and procedures
This Privacy Policy is in effect as of January 1, 2004. Druxy’s recognizes that legal interpretation of PIPEDA and future Provincial privacy legislation may impact its privacy policies and procedures. Our privacy officer will review and revise this Privacy Policy from time to time, and notification of any revisions will be posted on the Druxy’s Internet web site, as well as communicated to Druxy’s franchisees and corporate stores nationwide. Privacy Policy changes will apply to the Personal Information collected from the date of the posting of the revised Privacy Policy to the Druxy’s Internet web site.

More information
For more information about Druxy’s Privacy Policy, please contact Harold Druxerman, Vice-President Finance and Administration, at Druxy’s Inc., 52 Abbotsford Rd., Gormley, Ontario, L0H 1G0 Telephone: (416) 637-5970, Fax: (416) 637-5971, or on-line at harold@druxys.com.