BOSHART INDUSTRIES INC.

PRIVACY POLICY

Effective Date: January 1, 2004


Boshart Industries Inc. is dedicated to maintaining the accuracy, privacy, and security of your Personal Information. This Privacy Policy provides our principles related to the protection of the Personal Information of our customers, suppliers, and other entities with which we engage in commercial activities and has been designed to be compliant with the federal Personal Information Protection and Electronic Documents Act. (PIPEDA).


1. Who is Boshart Industries Inc.?


Boshart Industries Inc. ("Boshart"), headquartered in Milverton, Ontario, Canada manufactures quality products for the water well, plumbing, irrigation, pool and spa, HVAC, and industrial markets.


2. Definition of Personal Information


Personal Information is any information that identifies you, or by which your identity could be learned, but does not include your name, title, business address, or business telephone number. Examples of Personal Information include your home address, home telephone number, personal email address, billing and account information, numbers which may identify you (e.g. credit card), and transaction history.


3. Consent


You have the choice of whether or not to give us your Personal Information. If you submit your Personal Information to us, we will tell you why we are collecting it. For example, if you are asked to fill out a credit application, you may be required to provide Personal Information to us in order that we can assess our ability to do business with you.


By providing your Personal Information to Boshart or its agents, you are agreeing and consenting that Boshart may collect, use and disclose your Personal Information for the limited purposes outlined in this Privacy Policy and as permitted or required by law. Wherever possible, we collect Personal Information directly from you. If you wish to withdraw, refuse, or limit your consent in any manner, please contact our Privacy Officer.


4. Why do we collect Personal Information?


Boshart collects Personal Information for the following limited purposes:

a) to meet safety, security, and legal requirements;

b) to conduct market surveys and to provide you with direct marketing materials;

c) to manage our relationship with you and ability to respond to your inquiries;

d) to maintain customer and supplier lists; and

e) to satisfy other reasonable business interests (e.g. collecting on outstanding accounts, assessing your credit rating).


5. How do we maintain your Personal Information?


Boshart maintains your Personal Information in secured locations and on servers controlled by us. We have developed and implemented security safeguards appropriate to the sensitivity of the Personal Information. These safeguards include:

a) premise security;

b) restricted file access to personal information;

c) deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;

d) internal password and security policies;

e) limited access to where personal information is stored;


6. When do we disclose your Personal Information?


We do not share, sell or rent your Personal Information to third parties for their own use without your consent.


Under certain circumstances, Boshart will disclose your Personal Information:


- when required or authorized by law to do so (e.g. if a court issues a subpoena);

- when you have consented to the disclosure;

- where it is necessary to establish or collect accounts for services rendered or work performed;

- if we engage a third party to provide services to us (e.g. a computer technician) and the third party is bound by our Privacy Policy;

- if the information is already publicly known; and

- to meet an emergency need.


7. Accountability of your Personal Information


Boshart is responsible for the Personal Information collected and maintained by us and which is under our control. In order to fulfill this responsibility:


a) We have designated a Privacy Policy Officer to be responsible for Personal Information; Personal Information is retained as long as is reasonable to fulfill the purposes for which it was collected, which in general is five to seven years depending on the sensitivity of the Personal Information;


b) We have taken the following measures to ensure compliance with this Privacy Policy:


1) developed procedures to protect Personal information;

2) developed procedures to receive and respond to complaints and inquiries;

3) trained our staff about our policies and practices respecting Personal information; and

4) developed and distributed information to our staff and the general public explaining our policies and procedures respecting Personal Information.


8. Accuracy of your Personal Information


Boshart is committed to maintaining accurate, complete and up-to-date Personal Information. We may periodically request information, written or otherwise, from you to ensure that the Personal Information collected and maintained by us is up-to-date and accurate. If during the time we are working with you on a matter and any of your Personal Information changes, please inform us so that we can make any necessary changes in your active file(s) and on our databases.


9. Who do I contact regarding access to and changes to my Personal Information?


If you wish to access your Personal Information, please contact our Privacy Officer at the address set out below. Please make your request in writing, or via e-mail. However, we reserve the right to confirm your identity before complying with any access requests.


Although Boshart strives to ensure your Personal Information is correct, accurate and complete, you can challenge the completeness of your Personal Information under our care and control. Where you can successfully demonstrate that an error in the accuracy or completeness of your Personal Information exists, we will take reasonable steps to correct it.


There may be a charge for providing this information in which case you will be notified in advance and may withdraw your request or challenge the reasonableness of the charge.


10. Can my request for access to my Personal Information be denied?


Boshart may deny access to Personal Information when:


a) denial of access is required or authorized by law (e.g. when a record containing Personal Information is subject to a claim of privilege);

b) information relates to existing or anticipated legal case;

c) when granting you access would have an unreasonable impact on another person's privacy;

d) when to do so would prejudice negotiations with you;

e) to protect our rights and property;


If Boshart denies your request for access to, or refuses to correct Personal Information, we shall provide reasons.



11. Is Personal Information collected on our Web site?


A visitor to our Web site (www.boshart.com) is not required to reveal any individually identifiable information, nor is such information collected by electronic means.


On our Web site, like most other commercial Web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our Web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable Personal Information.


Our Web site contains links to other sites, which are not governed by this Privacy Policy.


12. Changes to this Privacy Policy


Boshart regularly reviews all of its policies and procedures, and we reserve the right to change our Privacy Policy from time to time. In the event of any change to our Privacy Policy, the amended version will be posted on our Web site. Policy changes will apply to the Personal Information collected from the date of posting and will not be applied to existing Personal Information maintained by Boshart without the consent of the person concerned.


13. Who do I contact if I have more questions?


Boshart is pleased to answer any further questions you may have concerning the privacy of your personal information. If you have any questions, please contact our Privacy Officer:


Arnie Gaunt, CMA
Controller

Boshart Industries Inc.
PO Box 310
25 Whaley Avenue
Milverton, Ontario, Canada
N0K 1M0

Tel: (519)595-4444
Fax: (519)595-4380