PRIVACY POLICY

Overview

Aragon Group (collectively "we" or "us") is serious about protecting your privacy. We understand your concerns with regard to how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This notice (the "Privacy Policy") describes what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it. This Privacy Policy is incorporated into and is a part of the Terms and Conditions of the Aragon Group web site (www. Aragon Group.com or any replacement site, the "Site"). We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms and Conditions. By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

What Information Do We Collect?

We may collect certain identifying information from or about you (and organizations with which you are affiliated, hereinafter "your company") in connection with your use of this Site, including registration for programs provided by Aragon Group, or through other communications that you or your company may have with us, including any survey or interview responses and other data provided by you or your company (collectively, "Collected Information"). Collected Information may include, but not be limited to, your name, title, company name, address, telephone number, fax number, email address, credit card information, and any other information submitted by you or your company. In addition, we may retain metadata regarding your use of the Site and the content of any correspondence and other communications that you may have with us. This information helps us to improve the Site, including the contents, materials, opportunities, and services that we feature or describe on the Site.

As with many other Web sites, the Web servers used to operate the Site may collect certain data pertaining to you and the equipment and communications method that you use to access the Internet and the Site. Unless otherwise described in this Privacy Policy or our Terms and Conditions, this information will be used solely for internal business purposes. In addition, such information does reveal such things as the Internet protocol ("IP") address assigned to your computer, specific pages that you accessed immediately prior to, or after, visiting the Site. If you are receiving communications such as emails or newsletters that we may periodically post, publish, or distribute, we may collect information regarding when you received, opened reviewed and responded to such emails or other communications that we sent to you. The purposes for which this information is collected and used include facilitating Site operation and system administration, generating aggregate, non-identifiable statistical information, monitoring and analyzing Site traffic and usage patterns, and improving the content and content delivery with regard to the Site, emails, and the online media, content, materials, opportunities, and services that we describe or make available on the Site.

How Do We Use The Information That We Collect?

Financial Information

Features exist on the Site that enable Site users to register for events and training workshops online using their credit/debit card, and therefore, we may request that a user supply his or her credit card number and expiration date of such credit card ("Financial Information"). The Financial Information collected by us during these online transactions is used solely by us and is not shared with outside parties except for the purposes of finalizing the transaction. Financial Information is not used for any other purpose whatsoever. Aragon Group is committed to protecting the security of your Financial Information and has in place various commercially reasonable security measures to safeguard this information from unauthorized access, use, and/or disclosure, including encrypting such Financial Information while in electronic transmission. Once a transaction is completed, Aragon Group purges the Financial Information used to facilitate or consummate the transaction.

Additional Information

In addition to the uses mentioned or described above, or otherwise described in our Terms and Conditions, we may use the information that we collect from or about you for certain purposes that are relevant to our relationship with you, such as: to provide training workshops if you register for such workshops;to analyze and improve the content, features, materials and opportunities that we make available on the Site or through other communications with you; to notify you of changes made to the Site or new opportunities made available on or through the Site or from Aragon Group; to evaluate your needs and customize the Site content delivered to you according to those needs; and for other legitimate and lawful business purposes.

With Whom Do We Share Information That We Collect?

In addition to the uses mentioned or described above, or otherwise described in our Terms and Conditions, in the course of conducting our business, we may transfer the Collected Information about you or your company to our offices throughout the world.

We may disclose information about you if we become subject to a subpoena or court order, or if we are otherwise legally required to disclose information. We may also use and disclose information about you to establish or exercise our legal rights, to enforce the Terms and Conditions, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As Aragon Group continues to grow and develop, it is possible that its corporate structure might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, customer information will most likely be, and should be expected to be, one of the transferred business assets.

What Choices Do You Have?

You may elect at any time to opt-out of receiving emails and newsletters that we may periodically post, publish or distribute. Except for information collected by automated means, when corresponding with Aragon Group or our representatives, or when making a request for information or otherwise interacting with Aragon Group through the Site, you choose what information to supply, what questions to pose and comments to make, whether you wish to receive further information, and by what method of communication such information should be delivered. Please take care to share only such information as is needed or that you believe is appropriate.

How Do We Protect Information Collected About You?

Aragon Group takes commercially reasonable measures to secure and protect information transmitted via or stored on the Site. Nevertheless, communications over the Internet are not completely secure, and no security system is impenetrable. We cannot and do not guarantee that any communications or any electronic commerce conducted on or through the Site, or that any information that you submit or that we collect, in connection with the Site or otherwise, will be totally secure. You agree to immediately notify us of any breach of Site security, or of this Privacy Policy or the Terms and Conditions of which you become aware.

How Do We Process Information Collected About Non-US Residents?

If you are a resident of a non-US jurisdiction, we process and protect information about you in the same manner as otherwise described in this Privacy Policy. You should note Aragon Group is organized under the laws of Delaware; and our operations as well as the servers that support this Site are located in the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your home country. In addition, if you would like to request access to your own personal data, or otherwise seek to exercise any specific rights you may have under applicable data protection laws, please contact us at:

Aragon Group
80 Bedford Road
Toronto, ON M5R 2K2
Canada

or at the following email address: PMcWhinney@AragonGroup.com

Linked Sites

For your convenience, some hyperlinks may be posted on the Site that link to other Web sites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We encourage you to seek out and read the privacy policy of each Web site that you visit. In addition, should you happen to initiate a transaction on a Web site that our Site links to, even if you reached that site through our Site, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked site. You should read that site's privacy policies to understand how personal information that is collected about you is used and protected.

Changes to Privacy Policy

From time to time, we may change our privacy practices, and this Privacy Policy, because of changes in relevant and applicable legal or regulatory requirements, our business practices, or in our attempts to better serve your needs and those of our other customers. Notice of such changes to our privacy practices will be given in the manner described in the Terms and Conditions and a revised Privacy Policy will be posted on the Site.

Who Can You Contact For More Information?

If you have any questions or suggestions about the Site, ARAGON GROUP, or our services, or privacy practices, please contact us at the numbers or address given below.

Aragon Group
80 Bedford Road
Toronto, ON M5R 2K2
Canada

or at the following email address: PMcWhinney@AragonGroup.com

This Privacy Policy is effective as of: 2.17.09

Acknowledgement

BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES AND DISCLOSURES OF COLLECTED INFORMATION ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS REFERENCED ABOVE.