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TACITA CAPITAL INC. PRIVACY POLICY AND PRINCIPLES

The privacy of our investors is very important to us. Tacita Capital Inc. (“Tacita”) is committed to protecting your privacy and maintaining confidentiality of your personal information. Tacita has put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect. To meet our obligations, we closely follow the ten fundamental principles set out under the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).

What is Personal Information?

The term “personal information” refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number, birth date, assets and/or income information, employment history and credit information.

Why we need the information?

Generally, we need to collect personal information to:
a) understand your needs, goals, objectives, risk capacity and tolerance and circumstances;
b) develop appropriate wealth management and investment plans;
c) manage your investments;
d) provide ongoing financial advice and service;
e) meet regulatory and contractual requirements relating to the advice and service provided to you.

How do we collect your Personal Information?

We collect and maintain personal information about you when you open an account with us. We collect your personal information to meet legal and regulatory requirements directly from you, members of your family, and other professional advisors or individuals to whom you give consent, that provide you with advice, service and products in connection with your investment needs. Your personal information may be collected from a variety of sources, including but not necessarily limited to the following:

a) subscription agreements, applications, questionnaires or other forms that you submit to us
or contracts that you enter into with us;
b) account statements, tax returns, insurance policies, employment and stock option
agreements, pension and other financial documents supplied to us by you or your other
professional advisors;
c) your transactions with us;
d) meetings and telephone conversations with you; and
e) emails and correspondence with you.

We have professional and legal requirements to update certain Personal Information no less than once a year or whenever a material change occurs in your circumstances.

How do we use your Personal Information?

We collect and maintain your personal information in order to manage your investments, give you advice and service, recommend products and allow us to establish your identity, protect from error and fraud, and comply with the law. In addition, we may use your personal information for:

a) assessing your suitability for particular investments;
b) executing transactions on your behalf;
c) liaising with your other professional advisors;
d) verifying and correction your personal information; and
e) providing you and/or your other professional advisors with investment statements,
confirmations, tax receipts and other financial information in order to service and administer
your account.

Who do we share your Personal Information with?

We may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the services we provide related to your account, but they will not share this information with others. Such information is only used for the purposes identified above. Tacita will use contractual or other means to provide a comparable level of protection while the information is being handled by a third party service provider or agent. The following is a list of such third party service providers and agents:

a) financial service providers, such as investment dealers, custodians, banks and others used
to finance or facilitate transactions or operations of your account;
b) transfer agents, portfolio managers, brokerage firms and similar service providers that may
be involved in the planning or execution of your investment strategy;
c) other service providers such as accounting, legal, or tax preparation services.

We may also share your information with your other professional advisors to whom you consent to such sharing.

We may also be required by law to disclose information to government regulatory authorities (for example, we may be required to report your income to taxation authorities).

We do not sell, lease, barter or otherwise deal with your personal information with third parties.

Tacita may be involved in the sale, transfer or reorganization of some or all of its business or the acquisition of investment businesses at some time in the future. As part of that sale, transfer, reorganization or acquisition, Tacita may disclose your personal information to the organization involved in the sale, transfer, reorganization or acquisition, but will require that organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

How do we obtain your consent to the collection, use and disclosure of your personal information?

By signing an investment counseling agreement with Tacita and continuing to do business with us, you are consenting to the collection, use and disclosure of your personal information for the purposes identified in this Privacy Policy. Tacita will not, as a condition of the supply of advice, services or products, require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfill those purposes.

Can you withdraw your consent?

You may withdraw all or part of your consent for us to collect, use or disclose your personal information subject to legal restrictions and reasonable notice. Tacita will inform you of the implications of such withdrawal of consent for the continued provision of advice and services.

How do we safeguard personal information?

We carefully safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. Tacita’s employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of Tacita’s employees is required to sign an acknowledgement confirming their adherence to Tacita’s policies and procedures including the Privacy Policy and Principles.

What are your rights?

You have the right to ask whether we hold any personal information about you and to see that information, as provided by law. If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it and we will make the necessary changes. If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.

How to obtain more information or register a complaint?

You may register a privacy-related complaint by contacting Tacita’s Privacy Officer at Suite 700 – 90 Adelaide Street West, Toronto, Ontario, M5H 3V9 or by email to: info@tacitacapital.com – Attention: Privacy Officer.

Tacita’s Privacy Principles

Principle 1 – Accountability
Each employee of Tacita is responsible for personal information under his or her control and is accountable for the prudent and proper use of this information. Tacita has designated a Privacy Officer who is accountable for our compliance in accordance with our Privacy Policy and Principles.

Principle 2 – Identifying Purposes
The purposes for which personal information is collected shall be discussed with you before or at the time the information is collected.

Principle 3 – Consent
The knowledge and consent of our clients is required for the collection, use or disclosure of personal information, except for legal or security reasons.

Principle 4 – Limiting Collection
Only such information as is necessary for Tacita’s services will be collected from you. Personal information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the consent of the individual, or as permitted or required by law.

Principle 6 – Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.

Principle 7 – Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness
Tacita will be open about its policies and procedures with respect to the management of personal information. Tacita will ensure that individuals are able to acquire information about Tacita’s policies and procedures without unreasonable effort. Tacita will make this information available in a form that is generally understandable.

Principle 9 – Individual Access
Upon written request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it, except where the law requires Tacita to deny access. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Handling Customer Complaints and Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Privacy Officer. This Policy may be updated from time to time without notice.

TERMS OF USE

Using this website constitutes your agreement to be bound by the terms of use set out below, as amended from time to time. You should read these terms before using this website. Tacita Capital Inc. reserves the right to revise these terms at any time with-out notice. You should therefore review these terms periodically.

1. This website is for informational purposes only. Nothing on this website is intended to constitute investment, tax or legal advice.

2. Nothing on this website constitutes an offer to buy or sell any security.

3. Tacita Capital Inc. has made every effort to ensure the accuracy of the information on this website; however, Tacita Captial Inc. does not warrant in any way the accuracy or completeness of the information contained on this website, and expressly disclaims liability for any damages that may arise from any errors or omissions contained in this website.

4. Tacita Capital Inc. does not warrant the accuracy of information contained on any websites of third parties that are accessible through this website though hyperlink, not does it warrant that such sites are free of any viruses or other problems. Tacita Capital Inc. disclaims liability for any damages that may arise from any loss or damage arising from accessing or linking to such sites.

5. This website is for personal non-commercial use only. No materials from this website may be copied, posted, published or distributed for public or commercial use with-out Tacita Capital Inc.’s prior written permission, and no materials contained herein may be modified in any way.

6. This website is operated by Tacita Capital Inc. in Toronto, Ontario, Canada. The information on this website may not be appropriate or permitted for use by users in other jurisdictions. Users who choose to access this website in such other jurisdictions do so entirely at their own risk. Tacita Captial Inc.s services are available only in those jusrisdictions in which it is registered to provide such services. The contents of this website is not and should not be construed to be an offer of securities or services to residents of the United States of America.

7. Additional Disclaimers:

i) Research:
Tacita Capital Inc.’s research has been prepared without regard to the individual financial circumstances and objectives of persons who receive it and is not intended to replace individually tailored investment advice. The asset classes/securities/instruments/strategies discussed may not be suitable for all investors and certain investors may not be eligible to purchase or participate in some or all of them. The appropriateness of a particular investment or strategy will depend on an investor’s individual circumstances and objectives. Tacita Capital Inc. recommends that investors independently evaluate particular investments and strategies, and encourages them to seek the advice of a financial advisor.

Tacita Capital Inc. research is prepared for informational purposes only. Neither the information nor any opinion expressed constitutes a solicitation by Tacita Capital Inc. for the purchase or sale of any securities or financial products. This research is not intended to provide tax, legal, or accounting advice and readers are advised to seek out qualified professionals who can provide advice on these issues for readers’ individual circumstances.

Tacita Capital Inc. research is based on public information. We make every effort to use reliable, comprehensive information, but make no representation that it is accurate or complete. We have no obligation to inform any parties when opinions, estimates or information in Tacita Capital Inc. research changes.

ii) Investments:
All investments involve risk including loss of principal. The value and income from investments may vary because of changes in interest rates or foreign exchange rates, securities prices or market indexes, operational or financial conditions or other factors. There may be time limitations on the exercise of options or other rights in an investor’s securities transactions. Past performance is not necessarily a guide to future performance. Estimates of future performance are based on assumptions that may not be realized. Management fees and expenses are associated with investing.

Email communications:

Tacita Capital Inc. is not liable for any loss or damage arising from the use of email to communicate with us.

Tax and Legal Services:

Tacita Capital Inc. does not provide corporate tax advice or corporate legal services.

(c) Copyright 2012 Tacita Capital Inc. All rights reserved.