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Privacy Policy

Effective January 1,2004

For Investors (“Clients”)

Collection and use of Personal information

We do collect from time to time a wide range of personal information about identifiable individuals for the purpose of providing services to our Clients. When we collect personal information from you, our Client, every member of our company has the ability to access that personal information both physically and electronically. We have spent an inordinate amount of time selecting and training the members of our company to ensure that they understand and respect the very private and discrete nature of our work. Every member of our company has been carefully briefed on the fact that no personal information about our Clients can be disclosed to any third party without your prior consent.

Protection of Personal information

Your personal information is kept under lock and key with restricted access to the floor on which our offices are located in off-hour times. If your personal information is kept electronically, it is password protected with only those who “need to know” having access to such password.

Disclosure of Personal information

Our computer technology consultants do have access to all electronically held documents and has signed a confidentiality agreement that prevent them from disclosing any personal or other information to any other person without our prior written consent which we will not provide without your prior consent.

As a private mortgage lender and in respect of the administration of the loan portfolios, we do collect personal information about our Clients. When providing our services, we will often interact with; lawyers hired to place the mortgages and collect the indebtedness on a loan; the Client; and his or her advisors including any financial and legal advisors and in those interactions, personal information collected and used by this company will be disclosed and exchanged between the company and those advisors. We confirm our understanding that you will take the necessary steps to ensure that the privacy policies of such other advisors is acceptable to you and we confirm that you have waived the necessity for us to enter into a specific written agreement with such other advisors in order to ensure that their privacy policy is similar to ours or is otherwise satisfactory to you.

For Borrowers

Collection and use of Personal information

We do collect from time to time a wide range of personal information about identifiable individuals for the purpose of providing services to our Borrower. When we collect personal information from you, the Borrower, every member of our company has the ability to access that personal information both physically and electronically. Every member of our company has been carefully briefed on the fact that no personal information about our Borrowers can be disclosed to any third party without your prior consent.

Protection of Personal information

Your personal information is kept under lock and key with restricted access to the floor on which our offices are located in off-hour times. If your personal information is kept electronically, it is password protected with only those who “need to know” having access to such password.

Disclosure of Personal information

Our computer consultants do have access to all electronically held documents and has signed a confidentiality agreement that prevent them from disclosing any personal or other information to any other person without our prior written consent which we will not provide without your prior consent.

As a private mortgage lender, we often find ourselves working alongside other credit agencies, investors, potential investors, legal advisors and the Borrowers’ advisors including but not limited to financial planners, legal advisors and accounting advisors. When carrying out our business our client’s personal information is regularly exchanged among this company and those additional advisors for the purposes of securing your credit history, assessing the value of the collateral being tendered, substantiating representations made to us, obtaining personal references and the like. We confirm that when you apply to our company for credit, you are implicitly instructing and consenting to our collection, use and disclosure of your personal information for the purpose of allowing us to be engaged in the activities and to provide the services in respect of seeking financing for you. We confirm our understanding that you will take the necessary steps to ensure that the privacy policies of such other advisors is acceptable to you and we confirm that you have waived the necessity for us to enter into a specific written agreement with such other advisors in order to ensure that their privacy policy is similar to ours or is otherwise satisfactory to you.

Retention and destruction of Personal information

Various laws require that we retain our files for minimum periods of time. We will keep your files for at least those minimum periods prescribed by law. Your closed file will be kept either on site or in off-site storage where disclosure of its contents is limited to our company alone. When we destroy your file, we will undertake such destruction in a manner that will eliminate or at least minimize the risk of any personal information being disclosed to any unauthorized third party .

Right to access and correct

You can review your personal information on reasonable notice, during regular business hours by making that request of the Privacy Policy Coordinator. You have the right to request a correction be made to your personal information. The partners of the company will determine whether that correction should be made or how it should be dealt with within 45 days of the request for correction having been first made to the Privacy Policy Coordinator.

You can make an inquiry or complaint about anything having to do with this privacy policy directly to the Privacy Policy Coordinator at any time, in writing. Our Privacy Policy Coordinator, Mrs. Gay Andrews can be contacted at (780) 702–9236 or by mail at Suite 1000, 8215 112 Street, Edmonton, Alberta T6G 2C8 Fax (780) 439–9472 or by-mail at gay@caplink.ca.

Appeal Process

As of January 2004, you are able to make a request under the Personal Information Protection Act (PIPA)to an organization for access to your own personal information. You may also request a correction to your own persona information. The organization must respond to your request within 45 days.

If you are not satisfied with the response you receive, you may request a review of the organization’s decision by the Information and Privacy Commissioner. The Commissioner may instruct an individual to discuss the decision with the organization prior to accepting the initial request for review. If a resolution cannot be reached between the parties, the Commissioner may decide to authorize a review into the matter.

For a copy of PIPEDA, please access the Privacy Commissioner of Canada website at: www.privcom.gc.ca

For a copy of PIPA, please access the Information Management, Access and Privacy website: www.psp.gov.ab.ca

Changes to Privacy Policy

Our privacy policy may change from time to time and those changes will be recorded in this document and be published on our website.