Disclaimer and Privacy Policy

Disclaimer
The materials on the Knightsbridge Capital Group (“Knightsbridge”) website and contained in the Knightsbridge newsletter “finance inFOCUS” are provided for informational purposes only. The information provided does not constitute professional advice or an opinion and is not intended to replace or serve as a substitute for any professional advice, consultation or service.

As content on our website is copyrighted, any unauthorized use of any materials on our website may violate copyright, trademark and other laws. However, you may display on your computer, download and print a copy of the material on our website for non-commercial, personal or educational purposes only, provided that the content is not modified and that each copy of such materials identifies the source, bears any copyright, trademark or other similar notices contained in the original materials and the terms of this limited license. No part of any document on our website may be reproduced or transmitted for any other purpose without the prior written permission of Knightsbridge.

Third-party links are provided as a convenience to our users. Knightsbridge does not control and is not responsible for any of these websites or their content. Knightsbridge is obligated to protect its reputation and trademarks and Knightsbridge reserves the right to request removal of any link to our website. Please direct enquiries to Director, Legal Affairs through the Contact Us page.

Privacy
At Knightsbridge, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.

While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Personal Information Protection and Electronic Documents Act (Canada), associated regulations thereunder and other provincial and federal privacy and consumer protection legislation (collectively, the “Privacy Laws”). The Privacy Laws set out the ground rules for how businesses and other organizations may collect, use and disclose personal information.

We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

Our Personal Information Protection Policy, in compliance with the Privacy Laws, outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our client to request access to, and correction of, their personal information.

Definitions:
Personal information –means information about an identifiable individual, e.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or the Privacy Laws.

Director, Legal Affairs – means the individual designated responsibility for ensuring that Knightsbridge complies with this policy and the Privacy Laws.

Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client information that is necessary to fulfill the following purposes:

• To verify identity;
• To verify creditworthiness;
• To identify client preferences;
• To understand the financial needs of our clients;
• To provide financial services to our clients;
• To open and manage an account;
• To deliver requested products and services
• To enrol the client in a program;
• To ensure a high standard of service to our clients; or
• To meet regulatory requirements.

1.3 The only personal information which we collect about our users when they use our website is what our users tell us about themselves, for example, by completing an online form when a Knightsbridge publication is requested, or information you provide to us through the "Contact Us" section or when a user sends us an e-mail. As most websites do, however, we do track usage patterns on our website on an anonymous basis. A user’s identity cannot reasonably be ascertained from this information. Each time a user visits our website, our server records the user’s Internet Service Provider, the date and time of the visit, the pages visited and the documents downloaded, the searches performed, and the referring URL’s of the user. We use this non-personal information to optimize our website service. For our users’ convenience, we may offer links from our website to other websites. However, Knightsbridge is not responsible for, nor do we accept any liability for, the personal information collection, use and disclosure practices of other entities to which our website may link. Our users should consult the privacy policies of these other entities before providing any personal information on their websites.

Policy 2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for Knightsbridge to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.

2.5 We may collect personal information without the client’s knowledge or consent in the following limited circumstances:

• If it is clearly in the client’s interests and consent is not available in a timely way; or
• When the personal information is available from a public source (e.g., a telephone directory); or
• If knowledge and consent would compromise the availability or accuracy of the information and collection is required to investigate a breach of an agreement or contravention of law.

2.6 We may use personal information without the client’s knowledge or consent in the following limited circumstances:
• If we have reasonable grounds to believe the information could be useful when investigating a contravention of law and the information is used for that investigation;
• In an emergency that threatens an individual's life, health or security;
• When the personal information is available from a public source (e.g., a telephone directory);
• If the use is clearly in the client’s interest and consent is not available in a timely way; or
• If knowledge and consent would compromise the availability or accuracy of the information and collection was required to investigate a breach of an agreement or contravention of law.

2.7 We may disclose personal information without the client’s knowledge or consent in limited circumstances as set out in the Privacy Laws, including as follows:

• When the disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual's life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud; or
• To a government institution or an investigative body that is governed by law when we have reasonable grounds to believe that the information concerns a breach of an agreement, or a contravention of law, or suspects the information relates to national security, the defence of Canada or the conduct of international affairs

Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To conduct client surveys in order to enhance the provision of our services; and
• To contact our clients directly about products and services that may be of interest;

3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client lists or personal information to other parties.

Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.

5.2 Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Director, Legal Affairs.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.

Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client personal information is appropriately protected:

• The use of locked filing cabinets;
• Physically securing offices where personal information is held;
• The use of user IDs, passwords, encryption, firewalls; and
• Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access)

6.3 We will use appropriate security measures when destroying client’s personal information such as shredding documents and deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions (e.g. solicitor-client privilege, where disclosure would reveal personal information about another individual and health and safety concerns).

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Director, Legal Affairs.

7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Director, Legal Affairs, is responsible for ensuring Knightsbridge’s compliance with this policy and the Privacy Laws.

8.2 Clients should direct any complaints, concerns or questions regarding Knightsbridge’s compliance in writing to the Director, Legal Affairs. If the Director, Legal Affairs is unable to resolve the concern, the client may also write to the Privacy Commissioner of Canada.

Contact information for Knightsbridge’s Director, Legal Affairs:

Knightsbridge Capital Group
Director, Legal Affairs
#300, 1055 West Hastings Street
Vancouver BC V6E 2E9
Tel: 604-684-7070
Fax: 866-684-7726

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