NAUGHTY BISCOTTI PRIVACY POLICY

OVERVIEW

Naughty Biscotti, Inc. ("Naughty Biscotti") is committed to protecting your privacy. This Policy explains how we protect your privacy as a purchaser of our interactive products and services or as a visitor to our websites located at: <www.naughtybiscotti.com>

WHAT PERSONAL INFORMATION DO WE COLLECT?

Personal information refers to information that identifies you such as your name and address. At various places throughout our websites, you are asked to voluntarily provide us with personal information if you wish to purchase products or you wish to obtain other services such as our online newsletter called Naughty Biscotti News or you wish to participate in a contest. The following is a list of the ways that Naughty Biscotti collects personal information from you:
a. Ordering from the Naughty Biscotti Online Store. We ask for your name, address and credit card number when you purchase products online such as food products, biscotti.
b. Warranty Registration. If you purchase a Naughty Biscotti product, we ask that you register for your product warranty online or by mail. We collect your name, address, email address and telephone number, as well as the name of the product that you purchased, the date of purchase and the purchase price.
c. Online subscription to Naughty Biscotti News. We ask you for your email address when you subscribe online for Naughty Biscotti News at <newsletter@naughtybiscotti.com>. You may unsubscribe for Naughty Biscotti News at any time.
d. Online Surveys. Occasionally we may ask visitors of our website to provide us with personal information about their preferences about food products, where they purchase food products and the like.
e. Online Contest. From time to time, we sponsor games and sweepstakes online. To participate, we ask for your name, address, email address and may ask for other information.
f. Customer Service/Help Desk/Online Support. If you contact our Customer Service or Helpdesk by phone, we ask for your name and phone number. If you contact our Customer Service or Helpdesk over the Internet, we ask for your name and email address. We may require further information in order to provide you with technical support. If your are placing an order for a particular product, we require your address for delivery and credit card information.

WHAT OTHER INFORMATION DO WE COLLECT FROM YOU?

Naughty Biscotti's website automatically collects the following non-personally identifiable information from visitors of our site:
o the Internet Protocol (IP) address of your computer, which is a number automatically assigned to your computer when you are surfing the Web.
o the IP Address of your Internet Service Provider
o your browser and platform type (e.g. a Netscape browser on a Windows platform)
o the date and time you access our site
o the sections of the website you visit, as well as the pages read and the images viewed
o certain content that you download from the website
We do not link any of the above information with information that is personally identifiable to you. This means that although your session on our website is recorded, you remain anonymous to us. We collect this date in an aggregate format for a number of reasons. For example, the information about our visitors' browsers tells us what kind of browsers we need to support. Other information lets us know how many visitors come to our site and what sections are the most popular. In this way, we can constantly update and revise our website to be more appealing for our visitors. We do not share this aggregate data with third parties.

COOKIES

Our website uses "per-session cookies" on the pages of the Online Naughty Biscotti Store. We use per-session cookies to facilitate your online purchases of products. Cookies enable our websites to save and retrieve information that you enter into the "shopping cart" as you make your way through our Online Store. Without per-session cookies, you would have to re-fill your shopping cart each time you left the pages of the Online Store, and your movement around our online store would be much slower. Per-session cookies are only stored in memory for the length of your visit to the store and expire when you leave our websites. You can set your browser to detect and reject cookies, however, if you choose to reject cookies, you will be unable to use our online shopping facilities.

HOW DOES NAUGHTY BISCOTTI USE THE INFORMATION IT COLLECTS?

Naughty Biscotti uses the information that it collects to process purchase transactions, to administer our product warranties, to administer games and sweepstakes and to provide you with services that you request such as our Naughty Biscotti News. We use the information that we collect from online surveys to improve our products and our site. We also use your personal contact information to send you promotional offers, new announcements and other news about Naughty Biscotti. However, if you do not wish to receive our marketing communications, let us know by contacting our Webmaster
By email: webmaster@naughtybiscotti.com
By telephone: 1-877-262-6422
Any other uses of your personal information that are not identified here will be disclosed to you at the time of collection, and we will make all reasonable efforts to obtain your consent, where appropriate.

DO WE DISCLOSE YOUR PERSONAL INFORMATION

With the following exceptions, Naughty Biscotti does not give, rent or sell personal information about its customers to third parties. In certain limited circumstances authorized by law, Naughty Biscotti may be required to disclose your personal information. Information provided to other third parties is used only for the purposes stipulated and is subject to strict confidentiality requirements. These parties may include:
" Agents acting on our behalf, such us companies performing maintenance on our system;
" Credit reporting agencies, in the event that we require verification of your credit information;
" Collection agencies, in the event that we need to collect overdue accounts;
" Law enforcement agencies, in case we are required by subpoena to provide such information to them;
" if Naughty Biscotti is ever involved in the sale or transfer of all or part of its business, Naughty Biscotti may disclose your personal information to the purchaser, however, we would require the purchaser to handle your personal information in a manner consistent with this Privacy Policy
" Regulatory bodies, in the event that our system is subject to a compliance audit

NAUGHTY BISCOTTI ONLINE RETAIL PARTNERS

Naughty Biscotti has a number of online retailer partners, whose websites you can access from our website. Although we recommend them to you based on their reputation for providing safe and secure online purchasing of our products, we make no warranty about their goods and services, the content on their websites or their protection of your personal information. This Policy does not apply to their activities and we encourage you to view their privacy policies and to contact these companies directly if you have any questions about their collection, use and disclosure of your personal information.

OUR PRIVACY POLICY AND CHILDREN

Naughty Biscotti uses best efforts to comply with the Marketing Association's Code of Ethics and Standards of Practice in its marketing to children and teenagers, and in its online contests.

SAFEGUARDS

Naughty Biscotti uses security measures to ensure that the information that you provide to us through our websites and that we retain on file are secure from loss, theft, as well as unauthorized access, disclosure, copying, use or modification. These security measures include appropriate technologies, such as firewalls.

CODE OF CONDUCT

Naughty Biscotti makes all reasonable efforts to comply with the Personal Information Protection and Electronic Documents Act, and has devised a Code of Conduct to in respect of its handling of your personal information:

1. Accountability

We are responsible for personal information under our control and shall designate one or more persons accountable for our compliance with the Code of Conduct.

2. Identifying purposes for collection of personal information

We shall identify the purposes for collection of personal information at or before the time the information is collected.

3. Consent

We will only collect, use and disclose personal information with your knowledge and consent, except where inappropriate. You may withdraw your consent at any time, subject to legal/contractual restrictions, and reasonable notice.

4. Limiting collection of personal information

We shall limit collection of personal information to what is necessary to fulfill the purposes identified, and such information shall be collected by fair and lawful means.

5. Limiting use, disclosure and retention of personal information

We shall not use or disclose personal information for purposes other than those for which it was collected, except with your consent or as required by law, and shall use our best efforts to retain personal information only for as long as is necessary to fulfill those purposes.

6. Accuracy of personal information

Personal information shall be accurate, complete and up-to-date, but we shall not routinely update personal information, unless necessary to fulfill the purposes for which it was collected.

7. Safeguards for protecting personal information

We shall protect personal information by security safeguards which are appropriate to the sensitivity of the information.

8. Openness about policies and practices

We shall make readily available to you specific information about our policies and practices relating to the management of personal information.

9. Individual Access to your personal information

Our internal policies regarding security, fraud prevention and protection of information may prevent us from allowing you access to your personal information from time to time. However, upon request, we shall use our best efforts to inform you of the existence, use and disclosure of your personal information. If you can demonstrate the inaccuracy or incompleteness of your personal information, we shall use our best efforts to amend the information as required.

10. Challenging compliance

You shall be able to challenge our compliance with this Personal Information Code of Conduct to the designated person accountable for our compliance, indicated below.

CHANGES TO THE PRIVACY POLICY

This version of our Policy has been in effect since 2003. Due to the evolving nature of the technologies used by Naughty Biscotti to communicate with you, we may occasionally update this Policy. Please check this page periodically for changes.

ACCESS TO YOUR PERSONAL INFORMATION, QUESTIONS, COMPLAINTS OR COMMENTS

With certain exceptions, you are entitled to full access to your personal information that we have on file and you may request that the information be deleted, updated or otherwise modified. If you wish to have access to your personal information, or if you have any questions or comments about this Privacy Policy, or if you have a complaint about our privacy practices, please contact Naughty Biscotti Customer Service at:
By email: customerservice@naughtybiscotti.com
By telephone: 1-877-262-6422