PRIVACY POLICY

Steingarten & Company LLP is entrusted with personal information about its clients and employees that the firm collects, uses and discloses to the extent required to fulfill its professional responsibilities and operate its business. The firm is committed to maintaining the privacy of personal information provided its clients and protecting all personal information in its possession and control.

The firm's Privacy Policy sets out the principles and procedures that the firm follows to adhere to the ten principles of privacy based on the Canadian Standards Association's Privacy Principles.

Principle 1 - Accountability - The firm is accountable for all personal information in its possession and control. This includes any personal information received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities and not-for-profit organizations).

The firm has appointed a Privacy Officer to oversee privacy issues for Steingarten & Company LLP The firm's privacy officer can be reached at:

1301-220 Portage Ave.
Winnipeg, Manitoba
R3C 0A5

(204-956-1011 Ext.202) or by email at lsteingarten@sscca.com.

Principle 2 - Identifying Purposes - The purposes, for which personal information is collected, shall be identified by the firm at or before the time the information is 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, or where required or permitted by law.

Principle 4 - Limiting Collection - The collection of personal information shall be limited to that which is necessary for the purposes identified by the firm. 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 must be retained only as long as necessary for the fulfillment of those purposes.

Principle 6 - Accuracy - Personal information shall be accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7 - Safeguards - Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness - The firm shall make readily available to its clients and employees specific information about its policies and practices relating to the management of their information.

Principle 9 - Individual Access - Upon request, an individual shall be informed of the existence, use and disclosure of their personal information and shall be given access to that information. An individual may verify the accuracy and completeness of their information and have it amended as appropriate.

Principle 10 - Challenging Compliance - An individual with questions or complaints with respect to privacy and the firm's privacy policy or practices may direct their concerns to our Privacy Officer.