Privacy Protection in Canada

This privacy policy has been developed to meet the compliance standards established by Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), the CSA Model for the Protection of Personal Privacy and the Province of British Columbia's Personal Information Protection Act (PIPA). The Personal Information Protection and Electronic Documents Act, formerly referred to as Bill C-6 and the Personal Information Protection Act Bill 38 are essentially about balance. On one hand, they respect an individual's right to privacy while on the other, they recognize the need for industry and organizations to collect, use and disclose personal information.

The Acts are based on the Ten Principles established by the Canadian Standards Association's Model Code for the Protection of Personal Information. These principles address the ways in which organizations should collect, use and disclose personal information. They also address an individual's right to access his/her personal information in addition to his/her right to have it amended where appropriate.

In order to govern the commercial information-handling practices within provincial jurisdictions, each province has been encouraged to enact legislation that is substantially similar to the federal law. As the provinces enact similar legislation, organizations conducting commercial activity within a province will be subject to the provisions of their provincial laws rather than the Federal Act. However, the Personal Information Protection and Electronic Documents Act will continue to regulate cross-border, inter-provincial and international trade and commerce. On January 1, 2004, most organizations, regardless of their size, which collect, use or disclose personal information in the course of commercial activity will become subject to the provisions of this Act. For more information regarding these legislations, please visit the official web site of the Privacy Commissioner of Canada at http://www.privcom.gc.ca/ or the Office of the Privacy Commissioner in your Province.

Overview

At Condo Bargain Club an important part of our commitment to provide you with service excellence is our respect for your right to privacy. Since our inception, we have been committed to keeping your information safe and the business you do with us in the strictest confidence. In any business, keeping personal information private is important; in financial services, it is critical. Our ongoing commitment to respect and protect the privacy and confidentiality of our clients' personal information, including that of sole proprietors and individuals carrying on business in a partnership, is addressed here in our Privacy Statement. We want you to know, in plain terms, why we ask for your personal information, how we use your personal information in establishing and maintaining your relationship with us, how we keep your personal information confidential, and how you can inquire about the personal information we hold about you.

Keeping our clients' information and affairs in strict confidence is a cornerstone of our business. We offer our clients a broad range of investment opportunities. Our range of products and services continues to expand, and the technology we use continues to change. However, no matter how our business changes, we will always protect your privacy. Our policies and the procedures that we practice in order to protect your privacy are in place across Condo Bargain Club.

Information that is essential for fulfilling most requests typically includes your name, a physical and mailing address, phone number(s), financial information, bank name, social insurance number and email address. We use your personal and financial information to communicate with you, process applications and effectively provide the services you have requested. The better we know you, the better we can help you achieve your goals. By sharing information with us about you, we can begin identifying your service requirements, for now and for the future. When you become a Condo Bargain Club client, we make every effort to establish and maintain a positive relationship with you. To help us do this, we use the personal information you have provided to us to communicate with you and to safeguard your interests.

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. For example, when you call us, visit our offices, or email us, our designated employees will access your information to verify that you are our client and to assist you in fulfilling your requests. The majority of information we retain about you is in the form of transaction records that reflect your business dealings with us. We are required by law to update and maintain this information on an ongoing basis and we will communicate this information back to you in the form of regular statements or through trade confirmations. We will keep you informed about your account activities, authenticate your identity, send you important notices, and respond to any special needs or enquiries you may have. With your consent, we may also send you information about other products and services in which we believe you would be interested. We also collect and analyze information from other sources for the same purposes. In other words, we collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

At Condo Bargain Club, we routinely collect anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit our web sites. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected is used for research and analytical purposes. For example, we are able to determine how many times our online privacy policy has been visited but we do not know any specific information about those visitors.

To help us better understand our markets, we may also gather information for analytical purposes by conducting anonymous client surveys, or by extracting demographic information from existing files and from Statistics Canada.

We Ask For Your Consent Before Sharing Information With Other People

We do not share information about you to anyone outside of the Condo Bargain Club without your consent. For example, we give information to a credit bureau only with your consent. There are some exceptions to the above rules. For example, we may collect, use or disclose information without your consent if we:

Use an outside company to process information

At times we may use the expertise of an outside company to do work for us involving some of your information - for example, the printing of month end statements or the processing of a mutual fund transaction. When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. Must disclose information for legal reasons

We may be compelled to release certain information to a court of law or other legal or regulatory authority. If so, our policy is to release only the information specifically requested and we take precautions to satisfy ourselves that the authorities who are making the request have legitimate grounds to do so.

Have to protect the interests of Condo Bargain Club.

In certain circumstances, we may have to collect, use or release information for its protection. For example, we may do so when collecting an overdue account, when realizing on security pledged for a margin account, or to detect or prevent fraud.

We correct your information whenever possible, we will correct any information which we may have given to an outside organization. If a third party, such as a credit bureau, has given us information which you tell us is wrong, we will give you the name and address of that party so that you can correct the information.

We protect your information from error, loss and unauthorized access each and every one of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility and governing their actions, even if they leave or retire from Condo Bargain Club. We keep our employees informed about our policies and procedures for protecting personal information and reinforce the importance of complying with them. All employees are also required as a condition of employment to conform to these policies and procedures.

Condo Bargain Club has a designated Privacy Officer who oversees privacy governance including policy, dispute resolution, education, and communications. Findings are reported to our Board of Directors and Senior Management. The Privacy Officer can be contacted at Condo Bargain Club, Suite 180A, 13040 No. 2 Road, Richmond, British Columbia. Telephone: 604.275.2170, Fax: 604.275.8745, Toll Free: 888.806.6099.

Electronic client files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked fire-resistant filing cabinets. Access is also highly restricted. Our computer security specialists build security into all our computer systems. Through these and other measures, we endeavour to protect your information at all times; whether it is stored in data files or handled by our employees. We manage our server environment appropriately, and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

To safeguard against unauthorized access to your accounts, you are required to "sign-on" using an encrypted password to certain secured areas of Condo Bargain Club web sites. If you are unable to provide the correct password, you will not be able to access these sections. Your password information is encrypted which is presently the most effective way to secure data. To protect your Online Account Information, the systems are designed to automatically terminate if extended inactivity is detected. If your session is terminated, you will be required to sign-on again to continue.

A cookie is a small text file containing a unique identification number that a web site sends to your computer's web browser. While you visit a particular site, a cookie may be used to track the activities of your browser as well as provide you with a consistent, more efficient experience. Cookies may be used by Condo Bargain Club web sites to improve functionality and in some cases, to provide visitors with a customized online experience.

How You Can Protect Your Information

At Condo Bargain Club, we do our utmost to protect and safeguard your personal and financial information. We believe there are measures you should take as well. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.

Passwords - Passwords are necessary to identify you and authenticate your permission to access your accounts. When you enrol in online services such as our client login area the passwords you use are encrypted. Encryption is presently the most effective way to achieve data security. Just as it is important for us to employ strict procedures to safeguard your information, you also should take precautions in handling your passwords. When selecting a password, we suggest that you use a combination of letters and numbers and do not use words that can be easily associated with you such as the name of a family member, a pet or the street on which you live. We also suggest that you change your password regularly.

Personal Information - You should not share personal or financial information such as your personal identification number, social insurance number or credit card number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

Suspicious Solicitation - From time to time, Condo Bargain Club will engage in promotional campaigns via telephone, mail and email. If you are unsure of the information you receive from us, please call us atTelephone: 604.275.2170, Fax: 604.275.8745, Toll Free: 888.806.6099.

Your Information Is Destroyed When It Is No Longer Needed

We keep your information only as long as we need it for the products and services you are using, to offer you products and services when you are a client and for a reasonable time thereafter, or to meet any legal requirements. We have industry regulated retention standards, which we must also meet. We destroy your information when it is no longer needed, or we remove your name from the information.

We Protect Other People's Privacy When We Make Information Available to You

There may be files that include information about you and other clients or that have information confidential to Condo Bargain Club or are the property of Condo Bargain Club. As we must protect everyone's confidentiality and legal rights, we cannot make these files available to persons outside of our group. However, we will make available to you any factual information about you contained in such files.

Client Complaints - We Respond to Your Request Promptly

We will deal quickly with your request to see your information, and always respond to you within 30 days. If we need to extend the time, or we have to refuse your request, we will tell you why, subject to any legal restrictions, and we will notify you of the new deadline, the reasons for the extension, and your rights under applicable legislation respecting the extension.

We Are Committed to Upholding the Condo Bargain Club Privacy Policies

If you have any questions or complaints about our privacy policies or about how we are living up to them, let us know right away. Resolving your concerns is important to us; Forum is committed to treating you with the greatest respect and consideration, and providing the highest level of service. Even so, from time to time, something may go wrong. There may be a misunderstanding or you may feel you have been dealt with unjustly. Whatever the circumstances, resolving the problem for you is our primary concern.

Questions, Concerns, Complaints

How to Resolve Concerns and Complaints at Condo Bargain Club:

Talk to us! In most cases, simply telling us about it and discussing it with us resolves a complaint.

If a problem is not resolved to your satisfaction, you can contact our Privacy Officer at Condo Bargain Club Headquarters, Suite 180A, 13040 No. 2 Road, Richmond, British Columbia. Telephone: 604.275.2170, Fax: 604.275.8745, Toll Free: 888.806.6099.

If after following the procedures your concerns have not been resolved to your satisfaction, feel free to contact your Provincial Privacy Commissioner directly by telephone or in writing. For example in British Columbia you may call the Office of the Provincial Ombudsman at: 1-800-308-6859, or in Victoria at (250) 861-3313. Fax the Office of the Provincial Ombudsman at: 1-800-308-6861, or in Victoria at (250) 980-3754. Email inquiries to http://www.OIPC@gems5.gov.bc.ca/ or write to: Information and Privacy Commissioner for British Columbia, P.O. Box 9038, Stn. Prov. Govt., Victoria, BC V8W 9A4.

The Provincial Ombudsman's office will acknowledge your complaint; then, providing legal action has not been taken on the matter, the Provincial Ombudsman immediately goes to work. In most cases, you will receive a response within five working days. Should you not be able to accept the conclusion of the Provincial Ombudsman, you may contact the Ombudsman for Banking Services and Investments for a further independent review. Email inquiries to http://www.obsi.ca/ or write to Ombudsman for Banking Services and Investments, P.O. Box 896, Station Adelaide, Toronto, ON, M5C 2K3. Call: 1-888-451-4519 (in Toronto (416) 287-2877) Or Fax: 1-888-422-2865 (in Toronto (416) 225-4722)

If the above steps fail to resolve your concern to your satisfaction, you may contact the Privacy Commissioner of Canada by writing to: The Privacy Commissioner of Canada, Place de Ville Tower B, 3rd Floor, 112 Kent Street, Ottawa, ON, K1A 1H3 or call: 1-800-282-1376 or fax: (613) 947-6850