At BloombergSen Investment Partners ("BloombergSen") we recognize that all personal information is private and confidential. BloombergSen's Privacy Policy ("Privacy Policy") governs BloombergSen's collection, use and disclosure of personal information. It is the intention of BloombergSen, by way of this Privacy Policy, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Document Act (PIPEDA).

BloombergSen recognizes the following key principles of PIPEDA.

Accountability:
BloombergSen acknowledges the importantance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all BloombergSen employees of the need to use the utmost discretion when dealing with client information. BloombergSen's Privacy Officer has the responsibility to carefully analyze and alter collection procedures both on a preliminary basis and ongoing basis to assure maximum privacy protection.

Purpose:
BloombergSen will only use client information for the purposes identified either before or at the time of collection. It is our policy that we will not sell your information.

Consent:
BloombergSen will only use information for identified purposes and if the information is required for any new use, BloombergSen will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by the client or a client authorized representative.

Collection:
BloombergSen will only collect information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation such as, the Money Laundering (Terrorist Financing ) Act. BloombergSen's employees will do their best to explain why collection of information is necessary in a clear and informative fashion.

Use, Disclosure and Retention:
BloombergSen will only retain personal information as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individuals' personal information is no longer required, BloombergSen will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that information cannot be found or used by an authorized party.

Accuracy:
BloombergSen strives to maintain accurate client information which not only help us provide better client service but also minimizes the potential misuse of personal information.

Safeguards:
BloombergSen understands the importance of protecting personal information and therefore, implements a number of safeguards against unauthorized access or improper disclosure. For example, BloombergSen's computer network, employee computers, laptops, and phone message centres are all password protected. In addition, filling cabinet units and storage rooms containing personal information are locked and can only be accessed by authorized individuals. General entry to our office is secured and cannot be accessed by unauthorized personnel without permission.

Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continual maintenance and periodic overview of our Privacy Policy and procedures. BloombergSen employees are subject to a strict code of conduct when it comes to personal information.

Directness:
At BloombergSen we make our best effort to inform clients of our policies and procedures and to explain how we manage personal information. Our Privacy Policy can be found on our website or can be requested via email or phone. If you have additional questions or concerns, our Privacy Policy will do her best to help you understand our procedures and policies.

Access:
When requested and supported by sufficient indentity information, BloombergSen will provide clients with their personal information as maintained in client files. We recognize a client's right to their own information, how the information is used and to whom it is disclosed.

If an error or discrepancy is found in your personal information, we will act efficiently to correct the mistake in less than thirty days. An extension will only be applied if the request will unreasonably interfere with our business affaires.

Complaints and Recourse:
BloombergSen's Privacy Officer will deal with any complaints or conflicts arising in regard to the collection, use and disclosure of personal information. In order to adequately address the complaint, all details will be recorded and a file will be created. All individuals involved will be notified of an enquiry into the complaint. BloombergSen's Privacy Officer can provide clients with a more complete description of the recourse process. Individual's who are not satisfied with BloombergSen's recourse procedure can bring the complaint to the attention of the federal Privacy Commissioner.

The measures outlined in this Privacy Policy in order to abide by PIPEDA's key principles are intended to provide clients with comfort that BloombergSen's staff regards personal information with the utmost importance. The Privacy Policy is also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their information.

Website:
Personal information collected by BloombergSen may be used to determine how many people visit the website and which sections of the website are visited the most frequently. When you visit the website, move from page to page, or download content, the following information may be recorded: the address you are connecting from; which pages are visited; and what content is downloaded.

Certain BloombergSen employees will be provided with information about the website visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products. BloombergSen employees are instructed to use strict standards of acre in handling the personal, confidential information.

Information obtained by registering on this website or attending a BloombergSen event will reside in an internal database at BloombergSen. If you wish to have your information removed from the BloombergSen database at any time, please email your request to jbloomberg@bloombergsen.com or call BloombergSen Privacy Officer, Jonathan Bloomberg at (416) 594-9090 for more information.

A complete version of PIPEDA can be found on the Department of Justice website.