// Versant Partners Inc. //

This VERSANT PARTNERS Privacy Policy describes the minimum requirements for the protection of personal information as prescribed by the Privacy Act of Canada and Provincial status. This Policy applies to all personal information. Business contact information such as the name, title, business address, email address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information. Policies and practices may vary, depending upon whether the personal information relates to clients, employees or other individuals. Versant Partners applies its principles from legislative acts both federally and provincially.

GENERAL

The ten principles that make up this Policy are in agreement with PIPEDA Personal Information and Electronic Documents Act. VERSANT PARTNERS has adopted this Policy and shall adhere to the ten principles as a whole.

PRINCIPLES

Principle 1 - Accountability

VERSANT PARTNERS is responsible for personal information under its control and has designated a Chief Privacy Officer who is accountable for VERSANT PARTNERS compliance with the following principles.

Accountability for VERSANT PARTNERS compliance with the principles rests with a Chief Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of the Chief Privacy Officer.

The identity of the Chief Privacy Officer designated by VERSANT PARTNERS to oversee its compliance with the principles is posted on VERSANT PARTNERS website (www.versantpartners.com) it shall also be made known upon request. VERSANT PARTNERS is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. VERSANT PARTNERS uses contractual or other means to provide a comparable level of protection while the information is being processed by a third party.

Principle 2 - Identifying Purposes

The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

Identifying the purposes for which personal information is collected at or before the time of collection will allow VERSANT PARTNERS on a continuing basis to determine the information it needs to collect to fulfill these purposes.

The identified purposes should be specified at or before the time of collection to the individual from whom the personal information is collected. Depending upon the way in which the information is collected, this can be done orally or in writing or through electronic communications. The application form, for example, may give notice of the purposes.

When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is required by law, the consent of the individual is required before information can be used for that purpose.

Persons collecting personal information will be able at all times to explain to individuals the purposes for which the information is being collected.

Principle 3 - Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or mentally incapacitated.

Consent is required for the collection of personal information and the subsequent use or disclosure of this information. VERSANT PARTNERS will seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when VERSANT PARTNERS needs to use information for a purpose not previously identified).

The principle requires "knowledge and consent''. VERSANT PARTNERS will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes must be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.

The form of the consent sought by VERSANT PARTNERS may vary, depending upon the circumstances and the type of information. In determining the form of consent to use, VERSANT PARTNERS shall take into account the sensitivity of the information. Although some information is almost always considered to be sensitive, any information can be sensitive, depending on the context.

In obtaining consent, the reasonable expectations of the individual are also relevant. Consent shall not be obtained through deception. For example, an individual contacting VERSANT PARTNERS for information on their services should reasonably expect that VERSANT PARTNERS, in addition to using the individual's name and address for mailing purposes, would also contact the person to invite them to various company events. In this case, VERSANT PARTNERS will assume that the individual's original consent constitutes consent for such purpose.

Consent can also be given by an authorized representative (such as a legal guardian or a person having power of attorney). Individuals can give consent in many ways. For example:

1. an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses;

2. except where transfer of the information is required in order to supply appropriate services to the individual, a check off box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;

3. consent may be given orally when information is collected over the telephone;

4. consent may be given through electronic communications;

5. consent may be given at the time that individuals use a service.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Upon receiving a withdrawal notice, VERSANT PARTNERS will inform the individual of the implications of such withdrawal.

VERSANT PARTNERS may refuse to provide its services to an individual if that individual refuses to provide personal information that is required or related to the product or service.

Principle 4 - Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by VERSANT PARTNERS. Information shall be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure, and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

VERSANT PARTNERS, when using personal information for a new purpose, shall document this purpose. VERSANT PARTNERS has developed guidelines and implemented procedures with respect to the retention of personal information. These guidelines include minimum and maximum retention periods. Personal information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made. An organization may be subject to legislative requirements with respect to retention periods.

Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous. VERSANT PARTNERS has developed guidelines and implemented procedures to govern the destruction of personal information.

Principle 6 - Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. The extent to which personal information shall be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. The information shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.

VERSANT PARTNERS will complete routine updating of personal information only when such a process is necessary to fulfill the purposes for which the information was collected. Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.

Principle 7 - Safeguards

Personal information is protected by security safeguards appropriate to the sensitivity of the information. The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. VERSANT PARTNERS will protect personal information regardless of the format in which it is held. The nature of the safeguards may vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. More sensitive information is safeguarded by a higher level of protection.

The methods of protection include:

1. physical measures, for example, locked filing cabinets and restricted access to offices;

2. organizational measures, for example, security clearances and limiting access on a "need-to-know'' basis; and

3. technological measures, for example, firewalls, the use of passwords, etc.

VERSANT PARTNERS commits to make its employees aware of the importance of maintaining the confidentiality of personal information. Care is used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.

Principle 8 - Openness

VERSANT PARTNERS shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. VERSANT PARTNERS is open about its policies and practices with respect to the management of personal information. Individuals can acquire information about VERSANT PARTNERS's policies and practices simply by consulting its web site (www.versantpartners.com) or speaking to any member of its organization.

The information made available includes:

1. the name, title and address of the person who is accountable for the VERSANT PARTNERS's policies and practices and to whom complaints or inquiries can be forwarded;

2. the means of gaining access to personal information held by VERSANT PARTNERS;

3. a description of the type of personal information held by VERSANT PARTNERS, including a general account of its use; and

4. what personal information is made available to related parties (eg, Head or Branch office; carrying broker and any third party supplier that VERSANT PARTNERS engages).

VERSANT PARTNERS makes information on its policies and practices available in a variety of ways. For example, VERSANT PARTNERS makes paper copies available in its place of business on appointment; according to the inquirer's choice, information may be mailed; online access is also provided (www.Versant Partners.com); and finally, its toll-free telephone number may be used to request the information (1-800-465-5616).

Principle 9 - Individual Access

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Note: In certain situations, VERSANT PARTNERS may not be able to provide access to all the personal information it holds about an individual. Exceptions to the access requirement are limited and specific. The reasons for denying access will be provided to the individual upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, information that is prohibitively costly to provide and information that is subject to solicitor-client or litigation privilege.

Upon request, VERSANT PARTNERS shall inform an individual whether or not it holds personal information about the individual. VERSANT PARTNERS will indicate the source of this information as long as that is documented. VERSANT PARTNERS shall allow the individual access to this information. In addition, VERSANT PARTNERS will provide an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed.

An individual may be required to provide sufficient information to permit VERSANT PARTNERS to provide an account of the existence, use, and disclosure of personal information. The information provided shall only be used for this purpose. In providing an account of third parties to which it has disclosed personal information about an individual, VERSANT PARTNERS will attempt to be as specific as possible. When it is not possible to provide a list of the third parties to which it has actually disclosed information about an individual, VERSANT PARTNERS will provide a list of organizations to which it may have disclosed information about the individual.

VERSANT PARTNERS will respond to an individual's request within a reasonable time and at minimal or no cost to the individual. The requested information shall be provided or made available in a form that is generally understandable. For example, if VERSANT PARTNERS uses abbreviations or policies to record information, an explanation shall be provided.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, VERSANT PARTNERS shall amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question. When a challenge is not resolved to the satisfaction of the individual, the substance of the unresolved challenge should be recorded by the organization. When appropriate, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.

Principle 10 - Challenging Compliance

The Chief Privacy Officer appointed by VERSANT PARTNERS can be reached by telephone, by facsimile and by email.

The Chief Privacy officer is responsible for accepting and investigating inquires and complaints. Procedures are in place to receive and respond to complaints and inquiries.

INTERNET PRIVACY POLICY

By accessing this web site and any pages thereof, you agree to be bound by the terms of the Legal Notices set out below. If you do not agree with the terms of these Legal Notices, do not access this web site or any pages thereof.

Legal Notices
References on this web site to "Versant Partners" are to the corporate entity Versant Partners Inc. or Partenaires Versant Inc., and may include its subsidiaries and or affiliates, depending upon the context.

Confidentiality
Absent the use of encryption, the Internet is not a secure medium and privacy cannot be ensured. Internet e-mail is vulnerable to interception and forging. Versant Partners cannot ensure the privacy and authenticity of any information or instructions you send to us or that we send to you over the Internet. Versant Partners will not be responsible for any damages you may incur if you communicate confidential information to us over the Internet or if we communicate such information to you at your request.

No Advice
The financial market data, including quotes, charts and news are provided by various information suppliers that are independent of Versant Partners Inc.. The information provided on this web site is intended for informational purposes only and is not intended to constitute financial, accounting, legal or tax advice. Many factors unknown to us may affect the applicability of any statement or comment that we make on our web site to your particular circumstances. You should consult directly with a Versant Partners professional or your other advisers before acting on any information on this web site.

Accuracy and Changes
Facts and information provided on this web site are believed to be accurate at the time they are posted. However, this web site could include inaccuracies, typographical errors, or out-of-date information. Changes may be made at any time to the information on this web site without prior notice. Please consult any branch of Versant Partners in your jurisdiction for complete and up-to-date information on products and services.

Calculators
Calculators or projections are provided for general illustrative purposes only and are not warranted to be accurate or complete.

Disclaimer of Warranty and Limitation of Liability
Versant Partners DOES NOT WARRANT THE ACCURACY, COMPLETENESS, QUALITY, ADEQUACY OR CONTENT OF ANY INFORMATION OR TOOL ON THIS WEB SITE NOR DOES IT MAKE ANY WARRANTY AS TO THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE.

SUCH INFORMATION OR TOOL IS PROVIDED "AS IS" WITHOUT WARRANTY OR CONDITION OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, THE IMPLIED CONDITIONS AND WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE MAY NOT APPLY TO YOU.

Versant Partners WILL NOT BE RESPONSIBLE OR LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES, OR ANY OTHER DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, LOST REVENUES, LOST PROFITS OR LOSS OF PROSPECTIVE ECONOMIC ADVANTAGE, RESULTING FROM THE USE OR MISUSE OF THIS WEB SITE, OR THE INFORMATION, DOCUMENTS, SOFTWARE OR CONTENT THEREOF, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR SUCH DAMAGES ARE REASONABLY FORESEEABLE.

No Solicitation
Nothing on this web site constitutes a solicitation or offer by Versant Partners Inc. to buy or sell products or services of any kind whatsoever including without limitation securities or any other financial instrument of any issuer.

Applicable Agreements
All products and services of Versant Partners are offered for sale subject to the terms of the applicable agreements. Please consult any branch of Versant Partners in your jurisdiction for complete and up-to-date information on products and services.

Applicable Jurisdiction
The information on this web site is intended for use by persons resident in Canada only. Any products or services mentioned on this web site are made available only in accordance with local law (including applicable securities laws) and only where they may be lawfully offered for sale.

US Residents
The information is not intended to be construed as an offer to sell or a solicitation to buy or sell any products or services of any kind whatsoever including without limitation securities or any other financial instrument in the United States of America or the territories or possessions thereof.

Software Back-up
While every effort is made to ensure that any software provided on this web site is suitable for use on a wide variety of computer systems, you should take reasonable and appropriate precautions to scan for computer viruses and ensure compatibility of the software with your specific computer system.

Hyperlinks Are Not Endorsements
Links to other web sites or references to products, services or publications other than those of Versant Partners on this web site do not imply the endorsement or approval of such web sites, products, services or publications by Versant Partners. Linking to any other web site is at your sole risk.

Trade Marks Belonging to Versant Partners or Other Entities
All product and service marks mentioned on our web site are the trade-marks of their respective owners.

Copyright Versant Partners 2010
Versant Partners either owns the intellectual property rights in the underlying HTML, text, images, audio clips, video clips, software and other content that is made available to you on this web site (the "Content"), or has obtained the permission of the owner of the intellectual property in such content to use the content on this web site.

Versant Partners grants to you a limited license to display the Content on your computer and print the Content on your printer solely for your own personal non-commercial use provided that you do not modify the Content and that you do not delete any of the proprietary notices.