Privacy Statement: September 2008

Privacy and confidentiality are fundamental to our business’s success. We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act. Ridgewood Capital Asset Management Inc. (as follows, “MCM”, “we” or “us”) has therefore, established a Privacy Policy and this Privacy Statement to ensure compliance with these regulations.

The purpose of this Privacy Statement is to inform you about the types of personal information MCM collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding this use and disclosure, and how you may correct that information.

We will treat personal information in a manner consistent with the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect, use or disclose, or receive about you, from any source.

We will address the following questions in this Privacy Statement.

  1. To which companies does this Privacy Statement apply?

    This Privacy Statement applies to the collections, uses and disclosures of personal information by Ridgewood Capital and its affiliates.

  2. What is “personal information”?

    Personal information” is any information that is identifiable with you. This information may include but is not limited to your name, mailing address, phone numbers, email address, business fax, social insurance number, household income, banking information, and creditor information. Personal information, however, does not include your name, business title or business address and business telephone number in your capacity as an employee of an organization.

  3. How do we collect your personal information?

    We will collect your personal information fairly and lawfully (for example, when you complete an investment application form or speak to a Ridgewood Capital representative). After we have obtained your consent to do so or as otherwise permitted by law, we will collect personal information from you and from third party service providers.

  4. How do we use your personal information?

    Either before or when we collect information about you we will obtain your consent to do so and explain how we intend to use it. One of the primary reasons we collect your personal information is to setup investment accounts, evaluate your investment objectives and provide financial advice. For example, we will use your personal information to help evaluate your financial situation and needs in terms of investment objectives, time horizons, income requirements, liquidity, tax efficiency and asset mix.

  5. To whom do we provide your personal information?

    At the time we collect your personal information from you we will explain how we intend to use it and to whom it may be disclosed.

    For example, we may disclose your personal information:

    1. to third party service providers with whom we have a contractual agreement to:
      1. assist us in managing and calculating the value of your investments;
      2. perform functions such as data processing, database services or information technology support; and
      3. market or providing any of our products;
    2. to persons for whom you have provided your consent; and
    3. as otherwise permitted or required by law.
  6. When and how do we obtain your consent?

    Before collecting, using or disclosing your personal information for any reason, we will obtain your consent.

    You can provide your consent to us either orally or in writing. For example, when you submit an application form to a Ridgewood Capital representative, you give your consent to allow us to disclose information such as your name, address, or social insurance number to third parties, such as financial institutions and other service providers, in order to assist in the management of your financial assets.

    From time to time, we may also collect, utilize or disclose your personal information based on your consent and as permitted or required by law.

  7. How do we ensure the privacy of your personal information when dealing with our affiliates and other third parties?

    Our affiliates and other third parties, which are engaged to perform services on our behalf and are provided with personal information, are bound by contract to meet the requirements of this Privacy Statement and our Privacy Policy and practices and may not use the information for any unauthorized purposes.

  8. How long will we utilize, disclose or retain your Personal Information?

    We keep a record of your personal information, correspondence or comments, in a file specific to you. We will use, disclose or retain your personal information only as long as it is necessary to meet the purposes for which it was collected and as permitted or required by law. Ridgewood Capital has a Record Retention policy, which establishes the retention periods for maintaining client documentation.

  9. How can you review your Personal Information that we have collected, utilized or disclosed?

    You can access any specific personal information on you, that we have collected, utilized or disclosed, upon your written request, and to the extent permitted by law.

  10. How do you know that the personal information we have on you is accurate?

    We will make every reasonable effort to keep your information as accurate, complete and up-to-date as possible. We do not routinely update your personal information, unless such a process is necessary. You can help by keeping us informed of any changes or if you find any errors in our information about you.

  11. What if the personal information we have on you is inaccurate?

    At any time, you can question the accuracy or completeness of the personal information we have about you. If the information we have is inaccurate or incomplete, we will update it accordingly. Where appropriate, we will transmit the updated information to third parties that require access to your personal information.

  12. How fast will we respond to your written requests?

    We will make every reasonable effort to respond to your written request within thirty-days (30) after receiving it or we will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner if we are unable to respond to you within the thirty-day (30) time limit.

  13. Are there any costs to you for requesting information on your personal information or on our Privacy Policy?

    If you would like to access the information we have about you, simply forward a written request to Ridgewood Capital's Chief Privacy Officer. We will advise you in advance if a minimal charge will be required for obtaining this information or any information about our Privacy Policy.

    You can withdraw your request for access to your information by notifying us within a thirty-day (30) notice period disclosed on the estimate we provide to you. Please notify us if you still require the information and accept the cost estimate or if you want to withdraw your request.

  14. How do we know that it is really you requesting your personal information?

    We will ask for specific details that will help us assess who is requesting the information. Any information collected, used or disclosed to make the assessment will only be used for this purpose.

  15. What safeguards have we implemented to protect your personal information?

    We will protect your information with appropriate safeguards and security measures such as physical, organizational, contractual and technological means. The only employees who have access to your personal information are those with a business 'need-to-know' or whose duties reasonably require this information.

  16. How do you contact us regarding access to your personal information or our Privacy Policy?

    All comments, questions, concerns or complaints regarding your personal information or our Privacy Policy, should be forwarded to our Chief Privacy Officer as follows.

    In writing:

    Attn: John H. Simpson
    Privacy Officer
    Ridgewood Capital Asset Management
    55 University Avenue, Suite 904
    Toronto, Ontario M5J 2H7

    Telephone: (416) 842-0227