Protection of, and respect for customers? and potential customers? confidential information is critical to our continued success and we understand the sensitive nature of stock plan information. Therefore, data are always handled appropriately and respectfully.

StockVantage maintains appropriate physical, electronic and administrative security standards and procedures to safeguard customer data. StockVantage employees are educated in the importance of insuring the privacy and confidentiality of this information and are required to sign the StockVantage Confidentiality and Non-Disclosure Agreement and the StockVantage Privacy Policy Agreement at the time they join the company.

Privacy, Confidentiality, and Non-Disclosure of Information for StockVantage Users

StockVantage's privacy policy complies with the federal government's Personal Information Protection and Electronic Documents Act (PIPEDA) and the provincial government's Personal Information Protection Act (PIPA). PIPEDA incorporates the ten privacy protection principles that form the Canadian Standards Act (CSA), which has been entitled the Model Code for the Protection of Personal Information. The CSA deals with the rights of individuals to have access to their personal information and to have it corrected if necessary, as well as the ways in which an organization collects, uses and discloses personal information.

This privacy policy supplements the Terms and Conditions governing your account with StockVantage.

StockVantage's Ten Privacy Protection Principles

1. Accountability - All employees of StockVantage are required to follow the standards set out in this Privacy olicy, and are required to sign a confidentiality and non-disclosure agreement as a condition of their employment. Oly employees who have been authorized and have a legitimate business purpose can access confidential personal information.
2. Purpose of Collection Personal Information - The personal information we collect and use is limited to what is required to provide the entitlement plan administration services offered by StockVantage.
3. Consent - Consent for collection, use and disclosure of your personal information is obtained when an account is opened with StockVantage and you signify acceptance of StockVantage's Terms and Conditions.
4. Limiting Collection - Personal Information collected is strictly limited to what is required to administer employee entitlement plans.
5. Limiting Use, Disclosure and Retention - The use of personal information we collect is limited to what is required to provide the employee entitlement plan administration services as outlined by StockVantage, and shall not be used or disclosed for any other purpose. The collection of a Government issued identification number is only mandatory in instances where law requires it, such as for tax reporting purposes. All personal information collected is maintained in a highly secure environment and is kept strictly confidential and would only be disclosed to outside parties when authorized by you, when required by Law, or when permitted by Law. Your personal information is retained only as long as necessary for record keeping obligations for the administration of employee entitlement plans.
6. Accuracy - StockVantage makes every effort possible to maintain complete, accurate and up to date information by the collection of information provided the plan provider.
7. Safeguards - StockVantage has implemented strict procedures to protect the data stored within our infrastructure. Our data is housed at a secure offsite location with tight physical and electronic security access. All access and collection of personal information within our site requires a 128-bit encrypted browser, to ensure the highest commercial level of security for your Internet transactions.
8. Openness - Our Privacy Policy is available to view on our site at any time or you may request information from us regarding our policies and practices that relates to the management of your personal information.
9. Client Access - All personal information is readily accessed through your account with StockVantage. You may access this information through our website or by contacting us directly. You may verify the accuracy and completeness of your information, and request amendments to this information if required.
10. Client Complaints and Suggestions - You may direct any inquiries regarding the above privacy principles or our practices by contacting us and speaking to the Privacy Officer who is accountable for our Privacy and Practices at StockVantage.

Physical Security of Information for StockVantage Users

StockVantage has placed all of the information and mission critical servers off site at a Tier 1 secure co-location facility. Access is restricted to individuals who require pass card and photo identification. Physical Security includes the following:

• 24 hour on-site security staff
• Card key biometric access
• Surveillance Cameras (exterior & interior)
• Published security policy
• Reinforced building structure (bomb resistance)
• Alarm and Monitoring system
• Fire proof & bullet resistant, high, shatterproof glass
• Battery backups for locking entry access system
• Motion detectors

Encryption - Transmission of Data

To login or view any personal or financial information from the StockVantage application, StockVantage users must have web browsers that support 256 bit encryption. Encryption prevents malicious and curious users from viewing information that is private by scrambling the data into an unreadable format to travel over the Internet.

StockVantage Network Security

Malicious Internet users may try to gain access to servers on the Internet by exploiting weaknesses in their set-up. To minimize this risk, StockVantage has erected a firewall to close typical weaknesses and prevent unauthorized users from accessing the system.

Passwords

Assigned passwords are protected in storage by using an encryption algorithm specifically designed for this purpose to ensure that only the individual user knows their password.

Hardware Redundancy

StockVantage redundant hardware at critical points including:

• Hard drives
• Power supplies
• Database server processor

StockVantage Data Backup Process

StockVantage has the following backup schedule:

• Daily on-site full electronic backups.
• Weekly off-site optic backups.

Privacy for Website Users

This website privacy policy describes how StockVantage handles information we collect from you when you visit our website. If, at any time, you have questions on how your privacy is protected, please contact us.

1. Visiting our Site - When you visit StockVantage.com and move from page to page, read pages, or download content onto your computer, StockVantage learns which pages are visited, what content is chosen for use, and the address of websites that you visited immediately before coming to our site. This information is not associated with you as an individual, but is used in aggregate to monitor our site's performance. We record these statistics to help us understand what type of information is most useful to our audiences, and to make it easy for users to find this information.
2. Email Subscriptions and Interaction - When you sign up for a StockVantage electronic communication service, send us email, or ask us to respond to you via email, StockVantage learns your exact email address and any information you have included in your electronic submission. We use your email address to acknowledge your comments and/or reply to your requests and we will store your communication and our reply in case we correspond further. We will not communicate or sell your email address to anyone outside of StockVantage Capital and our immediate partners. We may use the email address to send you information about our business and services that may be of interest to you. If you do not wish to receive this type of material you may unsubscribe at any time by following the instructions provided in the communication. If you have subscribed to receive information about StockVantage on a regular basis, you may also unsubscribe for this service using the instructions in the regular email submission.
3. Confidential Transmission - Email sent over the Internet is generally unencrypted. If StockVantage requests that you transmit confidential information to us over the Internet, we ensure that such transmission is encrypted. If you wish to provide us information electronically through email on our website and would like to ensure its confidentiality, please contact us.
4. Responding to Surveys - When you respond to a survey question, StockVantage may use your submission for the purpose of processing survey results, and we may publish those result aggregates on our website. We may use your response to improve our website or other products or services of StockVantage. Based on your response, we may also follow up with you to provide information about our products and services that may be of interest to you.
5. Information Collected. As a visitor to our site, you can browse our pages without having any personally identifiable information revealed about you. Information we automatically collect via industry standard web log files and other tools includes the URL from which you visited, the page you are visiting, your computer browser information and your IP address. We may also track the effectiveness of various promotions through the use of data collection devices known as "cookies." Cookies contain specific pieces of information on your computer hard drive, and can be set to store information during a visit or for a longer period of time. Our cookies are not tied to personally identifiable information. Third party vendors, including Google, show our ads on sites on the internet. Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to our website. Users may opt out of Google's use of cookies by visiting the Google advertising opt-out page.