This Policy was last modified on November 26, 2007.

This is a legal document. Please read it carefully. It describes how you can consent to Adirondack’s collection and use of your personal information and how Adirondack will then collect and use that personal information. Please review this document periodically as we may modify it from time to time.

1. ADIRONDACK’S COMMITMENT TO PRIVACY

Adirondack Transit Lines Inc. (“Adirondack” or “we” or “us”) is committed to protecting the privacy of its customers and the users of its website (“you”). This Policy describes Adirondack’s policies and practices with respect to the collection, use and disclosure of your personal information through Adirondack’s web site accessible at www.trailwaysny.com (the “Adirondack Site”). All the rights and obligations laid out in this Policy are subject to the limitations, requirements and conditions of any applicable law.

2. WHAT IS PERSONAL INFORMATION?

Personal information is any information which relates to a natural person and allows that person to be identified, such as a person’s name, address, telephone number, payment information or other contact information and personally identifiable data.

3. HOW DOES ADIRONDACK USE PERSONAL INFORMATION?

Adirondack may use your personal information for any of the following purposes:

• To bill you for tickets you purchase from us.
• To respond to your inquiries.
• To develop marketing strategies and enhance its product line.
• To perform quality control on our customer service.
• To detect and protect us against error, negligence, breach of contract, fraud and other illegal activity and to comply with all laws applicable to our operations.
• To any other purpose for which we have your consent.

Except as described at item 4 or as you may otherwise consent to from time to time, Adirondack will not use, and will not disclose or provide any of your personal information to any other person. We do not sell, trade, or rent your personal information to others for marketing purposes.

Adirondack may enter into discussions or negotiations with a third party (anywhere in the world) regarding the sale of all (or substantially all) of Adirondack’s business or the acquisition of a controlling interest in Adirondack’s share capital. Since customer information and data would normally be a part of such a transaction, Adirondack reserves the right to transfer any information you submit and we retain to that third party as part of due diligence activities or to complete the transaction.

4.  MIGHT ADIRONDACK DISCLOSE PERSONAL INFORMATION WITHOUT CONSENT?

Yes, in two limited circumstances:

As required or permitted by law: We may be required to release information by a court of law or other legal or regulatory authority. Applicable law may also provide that in some specific situations, no consent is necessary to disclose personal information (for example, to our legal counsel).

To protect ourselves: In certain circumstances, Adirondack may have to collect, use or release information without consent for its protection. For example, we may do so to detect, investigate or prevent fraud or ensure compliance with our internal policies, including this Policy.

5.  WHAT PERSONAL INFORMATION DOES ADIRONDACK COLLECT?

Adirondack collects and uses your personal information as necessary to fulfil the purposes listed in item 3 above. The type of information we collect will depend on the information or service requested. Different information and services require different types of information. Your information may be collected actively or passively.

A. Active Information Collection

You may choose to actively provide Adirondack certain kinds of personally identifiable information, such as your full name, address, phone number, e-mail address and other personal details, the exact nature of which will vary from case to case. If you choose to purchase tickets from the Adirondack Site, you must provide us with your name, address, e-mail address, telephone and fax numbers and credit card number. You may provide this information by submitting or posting it to the Adirondack Site, or to an Adirondack representative by telephone. All information that you actively provide to Adirondack is provided at your option.

B. Passive Information Collection

The Adirondack Site may passively collect information from you while you are visiting. Like any website, the Adirondack Site may collect a range of information, including your Internet Protocol (IP) address (a unique identifier automatically assigned to your computer when logging onto the Internet), the type of Web browser and operating system you use, the date and time you visit the Adirondack Site, the specific pages you visit on the Adirondack Site, and the address of the Web site you visited before coming to the Adirondack Site.

Adirondack typically uses such passively collected information for a variety of purposes, such as to administer the Adirondack Site, customize the Adirondack Site to your preferences, and compile aggregated statistics for marketing and research purposes.

The “passive information collection” technologies that we use may include "cookies." Cookies are small text files that store information about your interactions with a particular Web site, either temporarily (known as a "temporary" or "session" cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a "permanent" or "persistent cookie"). Adirondack does not currently use cookies but we reserve the right to do so in the future.  Cookies can make it easier to use a Web site by allowing servers to access certain information quickly:

• "Session" cookies can be used to help a user's browser navigate a website more smoothly and may show up if the user comes from a website with which the subsequent website has some relationship (e.g., the website of an affiliated company) and can give helpful information.
• "Persistent" cookies can be used to customize a Web site for a user, such as by storing passwords, preferences, and registration and account information so that users do not have to re-enter them each time they visit a Web site.

If you are concerned about cookies, you may modify your browser settings to notify you when you receive a cookie. If you do not know how to modify your browser settings please consult your browser documentation or the supplier web site. You may visit the Adirondack Site with cookies turned off. However, you may not be able to access some of its portions, which may require cookies for customization and personalization.

6. WHAT DOES ADIRONDACK CONSIDER TO BE VALID CONSENT?

There are many ways you can give your consent to our use of the personal information which you provide us. Your express consent may be given in writing, verbally or through electronic means. Alternatively, where permitted by law, your consent may be implied through an action you've taken or when you continue to use a product or service after we've notified you of a change.

Examples of consent:
Written - Signing a form that states "I agree to the terms," or which contains similar language.
Electronic - Clicking on an "I agree" or "I accept" or similar button online.
Verbal - Responding to a direct question from an Adirondack representative by telephone.
By using the Adirondack website, you consent to the passive collection of information as described above.

7.  CHILDREN

Adirondack does not knowingly collect personal information from children under the age of 18. Adirondack will immediately delete any such information in its possession upon becoming aware thereof.

8.  HOW LONG DOES ADIRONDACK RETAIN PERSONAL INFORMATION?

Adirondack will keep your personal information only for as long as it is reasonably needed to fulfill the purposes for which it was collected, unless and to the extent a longer retention is permitted or required by law. Your information is destroyed when it is no longer needed or it is converted to an aggregated and anonymous form. The length of time we keep your information varies depending on the reason it was collected and the nature of the personal information. For legal reasons, we may keep personal information beyond the end of your relationship with us.

9.   HOW CAN YOU VERIFY AND CORRECT PERSONAL INFORMATION?

You may access your personal information at no charge. Transcription, reproduction or transmission of such information may entail a minimal fee. You will be informed of any such fee in advance.

Adirondack takes reasonable steps to ensure your personal information is accurate, complete, and up-to-date. However, in certain circumstances, we must rely upon you to advise us if your personal information changes. If you notify us that your personal information is inaccurate or incomplete, we will take steps to correct, delete, or add to it, as appropriate.

You can contact Adirondack in writing to ask what information Adirondack may have collected and retained about you and how that information is being used. In some instances, you may be able to log into your account profile or preferences on the Adirondack Site to view and/or modify your information, as appropriate.

We protect other people's privacy when we make information about you available to you. It may not be appropriate for us to release certain information directly to you, for example because a file in which your personal information is stored also includes that of other customers, or it has information confidential to Adirondack or that is Adirondack’s property. Because we must protect everyone's confidentiality and legal rights, we cannot make these records available to you in full. We will, however, provide you with all the relevant excerpts from such records. If we are unable to disclose information to you, we'll explain why, subject to any legal restrictions. If you wish to challenge our decision, we will tell you how to do so.

10.  HOW CAN YOU WITHDRAW YOUR CONSENT?

Subject to legal and contractual requirements, you may change or withdraw your consent at any time (which includes electing not to receive further communications or other services from us) by: (1) changing your preferences on the Adirondack Site, if applicable; (2) using the unsubscribe feature, in the case of e-mail distributions, if applicable; or (3) contacting Adirondack, using the information provided below.

Withdrawing your consent will generally not affect your relationship with Adirondack or eligibility to receive Adirondack offers. However, if you don't consent or if you withdraw your consent, we may not be able to provide you with a particular service or provide you with requested information. In particular, you will be unable to purchase tickets from the Adirondack Site if you do not provide us with adequate billing information.

11.  WHAT CONFIDENTIALITY SAFEGUARDS DOES ADIRONDACK USE?

We use reasonable efforts to protect your personal information. Only authorized Adirondack personnel have access to your personal information, which is stored electronically on Adirondack’s servers or on-site at Adirondack’s offices, as applicable.

Adirondack protects personal information by security safeguards appropriate to the information’s sensitivity, but cannot guarantee that your personal information is completely secure from individuals who might attempt to deliberately evade security measures, including by intercepting transmissions over the Internet. You provide Adirondack with your information at your own risk. To protect the security and confidentiality of your personal information, you must safeguard all means of access such as passwords.

The Adirondack Site may link to other websites outside Adirondack’s control and which are not subject to this Policy. If you choose to visit them, Adirondack will be in no way responsible for how they may use, collect and transmit your personal information.

12.  HOW CAN YOU CONTACT ADIRONDACK?

Adirondack’s Manager of Customer Technology is responsible for supervising this Policy and Adirondack’s compliance with applicable privacy laws, including the Act respecting the protection of personal information in the private sector (Quebec) and the Personal Information Protection and Electronic Documents Act (Canada).

If you have any questions, comments or complaints about this Policy or our handling of your personal information, or if you wish to withdraw your consent to our use of your personal information (subject to reasonable notice, any legal requirements and similar limitations) or to request access to or update any information we have on file, you may contact Adirondack at:

Adirondack will use reasonable efforts to respond promptly to all questions, inquiries and complaints received, and will respond to you within a maximum of 30 days of receiving your request.

13.  WHAT ABOUT CHANGES TO THIS POLICY?

Adirondack reserves the right to modify this Policy at any time. If you have provided Adirondack with an e-mail address, we will notify you at that address whenever any such modification is made.