PRIVATE POLICY

PLEASE NOTE: OUR PRIVACY POLICY CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE RESPONSIBILITY TO BE AWARE OF CHANGES. Varna Canada Inc DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THIS WEB SITE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT PROVIDE ANY INFORMATION TO Varna Canada Inc OR USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEBSITES REFERRED TO IN THIS PRIVACY POLICY. This policy applies to Varna Canada Inc collection, use, storage and disclosure of information by Varna Canada Inc on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to Varna Canada Inc other information collection, including the purchase of customer lists from third parties. Varna Canada Inc is not responsible for the information collection or privacy practices of third web sites or applications.

1. Collection of Information.

1.1 Survey Information. Varna Canada Inc collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a Varna Canada Inc. survey, order form, or a registration page either online or offline, or using online or offline surveys, order forms, or registration pages operated by third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, Varna Canada Inc or a third party (a “Third Party”) may ask an individual to provide various information to Varna Canada Inc, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education, and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). Varna Canada Inc may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to Varna Canada Inc or Third Party, but an individual may receive incentives from Varna Canada Inc or a Third Party in exchange for providing Survey Information to Varna Canada Inc.

1.2 Third Party List Information. Varna Canada Inc collects information from individuals when an individual provides information to a third party and Varna Canada Inc subsequently purchases, licenses, or otherwise acquires the information from the third party (the “Seller”). Such purchased information may include but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, credit card information, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, Varna Canada Inc seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to Varna Canada Inc and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.

1.3 Other Information. Other occasions when Varna Canada Inc obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Varna Canada Inc or by a third party, (2) when an individual requests assistance through Varna Canada Inc customer service department, and (3) when an individual voluntarily subscribes to a Varna Canada Inc service or newsletter (together, “Other Information”).

1.4 Cookies, Web Beacons, and Other Info Collected Using Technology. Other occasions when Varna Canada Inc. obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by Varna Canada Inc. or by a third party, (2) when an individual requests assistance through Varna Canada Inc. customer service department, and (3) when an individual voluntarily subscribes to a Varna Canada Inc. service or newsletter (together, “Other Information”).

(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows Varna Canada Inc. to identify the individual with his or her corresponding data that resides in Varna Canada Inc. database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies to use all of the features and functionality of the Websites. (b) Web Beacons. A web beacon is programming code that can be used to display an image on a web page (by using a programming function — see http://truste.org for more information), but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows Varna Canada Inc. to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, Varna Canada Inc. might place, with the consent of a third party website, a web beacon on the third party’s website where fishing products are sold. When Bill, an individual listed in Varna Canada Inc. database, visits the fishing website, Varna Canada Inc. receives notice using the web beacon that Bill visited the fishing site, and Varna Canada Inc. would then update Bill’s profile with the information that Bill is interested in fishing. Varna Canada Inc. may thereafter present offers of fishing related products and services to Bill. In addition to using web beacons on web pages, Varna Canada Inc.. also uses web beacons in email messages sent to individuals listed in Varna Canada Inc. database. (c) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is Varna Canada Inc.'s use of new and evolving technology. As a result, Varna Canada Inc. strongly encourages individuals to revisit this policy for any updates regarding its use of technology.1.5 Outside Information. Varna Canada Inc. including information located in public databases (“Outside Information”).

1.6 Individual Information. As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information Varna Canada Inc. gathers or receives about individuals.

1.7 No Information Collected from Children. Varna Canada Inc. will never knowingly collect any personal information about children under the age of 13. If Varna Canada Inc. obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, Varna Canada Inc. has no such information to use or to disclose to third parties.

1.8 Credit Card Information. Varna Canada Inc.may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from Varna Canada Inc. When the Credit Card Information is submitted to Varna Canada Inc. such information is encrypted and is protected with SSL encryption software. Varna Canada Inc. will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.

2. Use of Individual Information.

2.1 Discretion to Use Information.

Varna Canada Inc. MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION. The following paragraphs in Section 2 describe how Varna Canada Inc. currently uses Individual Information, but Varna Canada Inc. may change or broaden its use at any time. As noted below, Varna Canada Inc.may updates this policy from time to time. Varna Canada Inc. may use Individual Information to provide promotional offers to individuals using email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties, please inform us by contacting customer service at (437)222-0098 and we will certainly honor your request.

2.2 Email.

Varna Canada Inc. uses Individual Information to provide promotional offers by email to individuals. Varna Canada Inc. may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list.

2.2(a) Content of Email Messages.

In certain commercial email messages sent by Varna Canada Inc. an advertiser’s name will appear in the “From” line but hitting the “Reply” button will cause a reply email to be sent to Varna Canada Inc. The “Subject:” line of Varna Canada Inc. email messages will usually contain a line provided from the advertiser to Varna Canada Inc.

2.2(b) Solicited Email.

Varna Canada Inc. only sends email to individuals who have agreed on the Websites to receive email from Varna Canada Inc. or to individuals who have agreed on third party websites to receive email from third parties such as Varna Canada Inc. does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email do not apply to Varna Canada Inc.'s email messages.

2.3 Targeted Advertising.

Varna Canada Inc. uses Individual Information to target advertising to an individual. When an individual is using the Internet, Varna Canada Inc. uses Technology Information (see also Section 2.5 below) to associate an individual with that person’s Individual Information, and Varna Canada Inc. attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest utilizing Technology Information, and otherwise. Varna Canada Inc. may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.

2.4 Direct Mail and Telemarketing.

Varna Canada Inc. uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.

2.5 Use of Technology Information.

Varna Canada Inc. and Hairmuses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of Rank Media Agency’s web sites are most frequently visited. This information helps Varna Canada Inc.

2.6 Profiles of Individuals.

Varna Canada Inc. uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.

2.7 Storage of Individual Information.

Varna Canada Inc. stores the Individual Information in a database on Varna Canada Inc. computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under Varna Canada Inc. control. Notwithstanding such measures, Varna Canada Inc. cannot guarantee that its security measures will prevent Varna Canada Inc. computers from being illegally accessed, and the Individual Information on them stolen or altered.

3. Dissemination of Individual Information.

3.1 Sale or Transfer to Third Parties.

Varna Canada Inc. MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN Varna Canada Inc. SOLE DISCRETION. If you do not wish us to use personal information about you to promote or sell our products and services or to sell, transfer or otherwise provide personal information about you to third parties.

3.2 Order Fulfillment.

Varna Canada Inc. will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using Varna Canada Inc. web sites or when responding to offers provided by Varna Canada Inc.

3.3 Legal Process.

Varna Canada Inc. may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.

3.4 Direct Mail and Telemarketing.

Varna Canada Inc.uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.

3.5 Summary Data.

Varna Canada Inc.. may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.

3.6 Access.

Individuals have access to their Individual Information collected to provide an opportunity for an individual to correct, amend, or delete such information. Access can be obtained by contacting customer service at the number on the order page. Varna Canada Inc. may also grant advertising clients and email services, providers? Access to an individual’s email address to verify the origin of the Individual Information collected.

4. Privacy Practices of Third Parties.

4.1 Advertiser cookies and web beacons.

Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and the Internet generally may use their cookies, web beacons, and other technology to collect information about individuals. Varna Canada Inc.. does not control Advertisers’ use of such technology and Varna Canada Inc. has no responsibility for the use of such technology to gather information about individuals.

4.2 Links.

The Websites and email messages sometimes contain hypertext links to the web sites of third parties. Varna Canada Inc. is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. Varna Canada Inc. does not operate or control in any respect any information, software, products or services available on such third-party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.

4.3 Affiliated Companies.

Varna Canada Inc may disclose, transfer, and sell Individual Information to entities affiliated within Varna Canada Inc. Discretion.

4.4 Business Transfers.

As we continue to develop our business, we might sell or buy stores, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the customer consents otherwise).