Privacy Policy

Conifer Fund Services Ltd. and its affiliates are committed to the proper management of the personal information of clients and others, and of all visitors to our website (the "Site") that we collect, use and disclose in the course of business.

The practices set out in this privacy policy (the "Policy") seek to balance the individual's right to the privacy of his or her personal information and Conifer's need to collect, use or disclose personal information for legitimate business purposes.

Controlling the collection, use and disclosure of personal information is an ongoing process. We will continue to review our personal information management practices and improve them as necessary to better protect the privacy of individuals. This Policy was last amended on the date shown at the end of the Policy.

Personal Information
Personal information is any information that can be used to identify you as an individual, including your name, personal telephone number and address, email address, information in your résumé or about your employment, the matter about which you retained or contacted Conifer, your account with us and any other information that you choose to provide to Conifer. Personal information does not include corporate information or so called business card information such as your business address or telephone number in your capacity as an employee of an organization.

Your Consent
By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.

We will not, as a condition of supplying a product or service, require you to consent to the collection, use or disclosure of your personal information beyond that required to enable us to provide the products or services requested. The form of the consent that we will seek before collecting, using or disclosing personal information may vary depending upon the circumstances and the type of information, and includes express oral or written consent, implied consent and opt-out consent. We will consider the sensitivity of the information and the individual's reasonable expectations in determining how consent must be given.

You may refuse to give personal information and may, subject to legal or contractual restrictions and reasonable notice, withdraw consent at any time to the continued use and disclosure of personal information previously collected. The period of reasonable notice will vary depending on the nature of the information and its purpose to Conifer. Conifer will inform you of the implications of refusing or withdrawing consent, which may have legal consequences or preclude Conifer from providing legal or other services.

Collection of Personal Information
We will not collect personal information indiscriminately. We will limit the amount and the type of information we collect to that necessary to fulfil the purposes we have identified to you, or as otherwise permitted or required by law. We may also collect information about your business and business interests or your personal interests to better serve you and foster our relationship.

When possible, we will collect personal information from you directly. However, for legal, administrative, marketing or management purposes, we may also collect personal information through outside sources such as credit bureaus, government agencies or institutions or through other third parties such as employment and other references, employers and service providers.

Internet Server Provider
Certain other information may be collected on the Site through various technologies, described below, without your actively providing the information.

Our website is hosted on servers shared with an Internet service provider ("ISP"). Any personal information collected on our behalf by the ISP, such as server log data (see below), is managed in accordance with this Policy and is protected by applicable law.

Certain information about Internet users' traffic patterns is passively and automatically collected and linked to users' Internet Protocol ("IP") addresses. These unique IP addresses are assigned to all Web users by their ISPs, and are automatically logged by Internet servers. While the IP address itself does not identify an individual, it may, in appropriate circumstances such as an investigation of a security breach, be used with the cooperation of the ISP to locate and identify an individual using the website.

Server Logs
In the normal course of establishing and maintaining Internet connections, our servers automatically log information about visits to our website. Server logs record statistical information, such as a visitor's IP address and type of operating system, the time and duration of visit and Web pages requested. The server logs also identify categories of visitors by items such as domain and browser type. These statistics are reported in aggregate form to us and are used to improve our website and ensure that it provides the optimal online experience for visitors.

We do not link server log information to any other data in a way that would enable us to identify individual visitors, except for security purposes, as discussed above.

Cookies
Like many other websites, our Site makes use of "per session" cookie technology. Per session cookies are small text files that contain a unique identification number that is automatically deposited on a visitor's computer. These cookies track information during an open session and are stored only temporarily in your computer's memory. This information helps us determine the total number of visitors to the Site on an ongoing basis and the types of Internet browsers (e.g., Firefox or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that our visitors use. We use this information to facilitate and enhance your online visits. We do not cross-reference this information with any type of personal information that is voluntarily offered through the Site.

The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically. If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser's cookie options, please refer to the instruction documentation of your particular browser or seek online assistance.

Use of Personal Information
We use personal information only as described in this Policy or as otherwise permitted or required by law. Before your personal information is used or disclosed for a new purpose, we will ask for your consent unless use or disclosure without your consent in the circumstances is otherwise permitted or required by law.

Conifer generally uses personal information about clients for the provision of fund services, including obtaining and carrying out client instructions, reporting and communicating with clients, billing and accounting, and protecting against fraud, illegal activities or error. Conifer may also use your personal information to send you newsletters about our services or about certain developments that we think would interest you. To establish or enhance our relationship, we may invite you to client functions, seminars and sporting or cultural events.

We regularly distribute client memos, practice group bulletins, articles and other legal updates and publications to people on our mailing lists, who can elect to receive materials on one or more subject matters. At any time, you may change your preferences and mailing option (regular mail or email), or unsubscribe from our mailing lists.

If you send personal information through our Site, we will use it to assess website use and traffic, and to respond to your feedback, questions and comments.

Disclosure of Personal Information
We disclose personal information only as described in this Policy or as otherwise permitted or required by law. To provide legal services, we may sometimes disclose our clients' personal information to Conifer's affiliates, foreign agents and government or regulatory agencies. At times we may also disclose personal information to service providers, inside or outside Canada, that assist us with marketing or other services, including technical support and mailing. We limit the service provider's right to use the personal information only for the services it provides to us, and we require the service provider to maintain the confidentiality of the personal information and to take steps to protect the security of the personal information we give it.

Our offices may share your personal information to perform legal services or for marketing purposes.

Your personal information may be accessed or stored in the USA or the BVI or another jurisdiction, and may be subject to the laws of that jurisdiction.

Retention of Personal Information
Conifer will retain information, including personal information, for as long as it is needed for the purposes for which it was collected. For example, if you send us personal information electronically to apply for employment with Conifer, we will retain your personal information for a reasonable period to permit future consideration for employment. Conifer may also be subject to legislative requirements regarding the retention of certain types of information.

Protection of Personal Information
We use the standard safeguards of the legal profession to protect the security of personal information in our possession, including physical, organizational and technological measures.

Links to Other Websites
The Site may contain links to other websites. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the content or privacy practices of other websites. We strongly encourage all Site visitors to review the privacy statements and policies of all external websites.

December 2006