By accessing the Yorkville Website (the “Site”) you accept this Privacy Policy. If you do not agree to this Statement, do not proceed to further web pages of the Site.

Yorkville Asset Management Inc. and its affiliates/subsidiaries (collectively “Yorkville”) are committed to maintaining the confidentiality of your personal information. The purpose of this Privacy Policy is to explain how Yorkville collects, uses and discloses your personal information, the choices you have regarding such use and disclosure, and how you may correct that information. Yorkville demonstrates its commitment to client privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act (PIPEDA). From time to time, Yorkville may make changes to this Privacy Policy, We therefore ask you to consult it on a regular basis. The last line of this Statement indicates when the Statement was last updated. This Privacy Policy applies to any information Yorkville collects or receives about you from any source.

Our Privacy Policy consists of the following 10 Principles

Consent – Yorkville will obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. Consent may either be provided orally or in writing.

Limited Use – Yorkville will limit the collection and use of your personal information to what is required to serve you and to administer business, e.g. Yorkville will collect, use and disclose your personal information in order to verify your identity, open accounts, process transactions, analyze financial needs and activities, provide you with various services with respect to your account, help manage and assess your risks, operations and relationships, and to comply with applicable laws and requirements of regulators, including self regulatory organizations.

Collection Of Information – Yorkville will collect your personal information by fair and lawful means (e.g., account opening application form).

Third Party Disclosure Of Information – At the time your personal information is collected, Yorkville will identify if the information will be disclosed to any third parties, and the purposes for the disclosure. Yorkville may disclose your personal information:

(a) to transact on your accounts;
(b) to communicate to third party service providers with whom Yorkville has a contractual agreement for the purpose of:

• mailing information materials;
• disclosing information to custodian; and/or
• data processing, database services, recordkeeping or information technology support on Yorkville’s behalf;

(c) for such other disclosures of your personal information to such persons for which the you provide consent; and
(d) as otherwise permitted or required by law.

Recordkeeping – Yorkville will keep a record of your personal information, correspondence or comments, in a file specific for you. Yorkville will utilize, disclose or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. Your personal information will be retained for a period of seven years following the end of the relationship.

Accessing Your Personal Information – Generally Yorkville will make any personal information that has been collected available to you upon your written request, to the extent permitted by law. Access may be withheld where providing access would reveal confidential corporate information, threaten the security of another individual, or the information was generated in the course of a formal dispute resolutions process. This information will be made available to you in a form that is generally understandable, including explaining any abbreviations or codes.

Yorkville will attempt to provide you with access to your personal information not later than thirty (30) days after receipt of such request. Yorkville will advise in writing if it cannot meet your requests within this time limit and include the reasons for the extension.

Costs to Requesting Information – The costs associated with access requests, if any, will be paid by you, but may be waived at Yorkville’s sole discretion. As such, prior to proceeding with such access request, Yorkville will inform you of the approximate cost of the access request and will obtain approval to proceed.

Accuracy – Yorkville will ensure that your personal information is kept as accurate, complete and up-to-date as reasonably possible, however, Yorkville will not routinely update your personal information, unless such a process is necessary.

Inaccurate Information – You may, at any time, challenge the accuracy or completeness of your personal information. If you can successfully demonstrate that the information on file is inaccurate or incomplete, Yorkville will make amendments, as required. Where appropriate, Yorkville will transmit the amended information to third parties who have access to your personal information.

Safeguards to Protect Your Personal Information – Yorkville have implemented physical, organizational, contractual and technological security measures to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your personal information, are those with a business ‘need-to-know’ or whose duties reasonably require such information. Some examples of the safeguards used to protect your personal information include:

• Physical Measures i.e. locking filing cabinets in which your personal information is stored;
• Organizational Measures i.e. access to your personal information is restricted to personnel who need to know the information to provide a service; and
• Technological Measures i.e. in addition to passwords for computer terminals, Yorkville’s Information Technology Department or supplier of such services provides individual access to the drives to appropriate personnel.

Yorkville collects you personal information for the following purposes:

• assessing your eligibility to open an account;
• providing you with services connected with your investments;
• complying with statutory and regulatory requirements (such as establishing the identity of each client);
• providing you with the best possible service and protecting against error and fraud; and
• for any other purpose related to Yorkville’s products and services or that of our affiliates to which you may consent, including marketing purposes.

How can you access or review your personal data?

Should you have a request regarding the processing of your personal data please send a letter to the following address:

220 Bay Street, Suite 802
Toronto, ON
M5J 2W4
Office: 647-776-7480
Fax: 647-776-7490
info@yorkvilleasset.com

Last update in February 2012.