Granville Capital Inc Privacy Policy

An organization entrusted with personal information about its customers, dealers and employees has a responsibility to protect the privacy of that information. Granville Capital Inc takes this responsibility very seriously. Customers, dealers and employees of the company should expect nothing less.

To that end, Granville Capital Inc has established a Privacy Policy to protect the privacy rights of its customers, dealers, employees and others. This policy relates to the collection, use and disclosure of personal information by the company, its shareholders and employees ("Granville Capital"). Personal information includes any information about an identifiable individual, but does not include the name, title or business address or business telephone number of an individual.

Granville Capital Inc's privacy policy is to adhere to ten principles of privacy based on the Canadian Standards Association's Privacy Principles. Each of the principles is interrelated, and more detailed guidelines have been produced to assist in the application of these principles.

Principle #1: Accountability

Granville Capital Inc is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions.

Granville Capital Inc has designated a Chief Privacy Officer to be accountable for overall privacy protection and compliance. Granville Capital Inc's Chief Privacy Officer can be reached by e-mail at vwright@granvillecapital.ca.

Principle #2: Identifying Purposes

Granville Capital Inc shall identify the purposes for which personal information is collected either before or at 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

Collection of personal information shall be limited to that which is necessary for the purposes identified by Granville Capital Inc, and 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 or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Principle #6: Accuracy

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

Principle #7: Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity level of the information.

Principle #8: Openness

Granville Capital Inc shall make information available to its customers, dealers and employees about the policies and practices that apply 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 information, and shall be given access to it. An individual may verify the accuracy and completeness of their information, and may request that it be amended if appropriate.

Principle #10: Challenging Compliance

Questions or complaints with respect to privacy and Granville Capital Inc's privacy policy or practices may be directed to designated people within Granville Capital.