Privacy Policy

YOUR PERSONAL AND FINANCIAL INFORMATION IS PROTECTED WITH US
Nordexe is extremely dedicated to your right to privacy and takes your privacy very seriously.
Our company has very strict privacy policies and we make every effort to keep your personal and
financial information safe and protected at all times.

PRIVACY POLICIES

1. Nordexe is accountable for the protection of clients` personal information. While senior
management is ultimately accountable for the protection of personal information, the day-to-day
monitoring for compliance may be delegated to other staff.

2. Nordexe is committed to ensuring that the appropriate security measures are employed in
the transfer of sensitive information. However, when using e-mail or wireless communication,
Nordexe advises clients that complete confidentiality and security are not assured.

3. Nordexe is not accountable for any damages suffered when a client transmits personal
information through e-mail or wireless communication or when Nordexe transmits information
at the request of the client.

4. Nordexe has developed policies and procedures to: protect personal information; receive
and respond to complaints and inquiries; train staff regarding the policies and procedures;
communicate the policies and procedures to our clients.

5. Nordexe collects client personal information for the following reasons only:

• To provide financial services;

• To understand their clients` financial needs;

• To broker and administer loan agreements;

• To develop, manage and deliver products and services to clients;

• To develop and deliver marketing and promotional offers to clients;

• To determine client eligibility for different products and services;

• To ensure that clients receive a high standard of service;

• To meet regulatory requirements;

• To manage and transfer the assets and liabilities of Nordexe and those assets under its
administration; and

• To verify client`s identity.

Nordexe will only collect personal information for the purposes identified. Nordexe will use
methods that are lawful and will not collect information indiscriminately. Nordexe will not use
personal information for any additional purpose unless Nordexe seeks client consent to do so.

6. Nordexe will obtain client consent to collect, use or disclose any personal information

except where detailed in this policy. Nordexe will make reasonable efforts to ensure that clients
understand how their personal information will be used and disclosed.

7. A client`s consent can be express, implied, or given through an authorized representative
such as a lawyer, agent or broker. Consent may be given orally, in writing, or electronically.
For example, depending on the sensitivity of the information, consent can be expressed over the
telephone when information is being collected; electronically when submitting an agreement,
application, or other information; in writing when signing an agreement or application form.
Implied consent exists when Nordexe can reasonably infer consent based upon the action or
inaction of the client.

8. Nordexe, however, may collect, use or disclose personal information without the client`s
knowledge or consent in exceptional circumstances:

• When such collection, use or disclosure is permitted or required by law

• When certain information is publicly available

• When we require legal advice from a lawyer

• When we need to collect a debt from a client

• When we need to deal with an anticipated breach of law

• When potential investors/stakeholders wish to ensure the quality and characteristics of an
investment.

9. Subject to contractual or legal arrangements, clients may withdraw or refuse consent provided
that Nordexe is given reasonable notice. Nordexe may decline to deal with a client or person
who will not consent to the use of such information.

10. Nordexe may periodically use client personal information to conduct client surveys in order
to enhance our provision of services or products. If an outside body is employed to conduct
research on behalf of Nordexe, or provide other services that require access to client information,
Nordexe will ensure that appropriate security undertakings, such as confidentiality clauses in
contractual arrangements, are employed to protect the transfer and use of personal information.

11. Nordexe will retain client personal information only as long as necessary or expected to be
necessary for the identified purposes, or as required by legislation.

12. Nordexe may disclose personal information related to a financial asset of Nordexe along with
transfer of the financial asset.

13. Nordexe will make reasonable efforts to ensure that client personal information is as
accurate. In some cases, Nordexe relies on its clients to ensure that certain information, such as
the client`s address or telephone number, is current, complete, and accurate.

14. Nordexe will not routinely update information unless it is necessary to fulfill the purposes for
which it was collected or if it is required to maintain an active account.

15. Nordexe is committed to the safekeeping of client personal information in order to prevent its
loss, theft, unauthorized access, disclosure, duplication, use, or modification, and will employ
appropriate security measures to protect the information. The measures may include, for
example, the physical security of offices and data, and electronic security measures such as
passwords and encryption where appropriate.

16. Nordexe will use appropriate security measures when disposing of client personal
information.

17. The development of Nordexe`s policies and procedures for the protection of personal
information is an ongoing process. Changes in technology necessitate that Nordexe continually
develops, updates, and reviews information protection guidelines and controls to ensure ongoing
information security.

18. Nordexe will make the following information available:

• The name, title and address of the person accountable for the policies and procedures and
to whom complaints or inquiries can be forwarded;

• A description of the type of personal information held by Nordexe, including a general
account of its use;

• A copy of any brochures or other information that explain the policies and procedures;
and

• An explanation of what personal information is made available to affiliated companies or
investors.

19. Clients have a right to access their personal information held by Nordexe. Upon request,
Nordexe will, within a reasonable time period, tell the client what personal information it has,
what it is being used for, and to whom it has been disclosed if applicable and within the time
period for which records are available.

20. Clients may be asked to be specific about the information they would like to access and to
submit their request in writing to Nordexe.

21. Clients will be required to provide personal information to identify themselves to enable
Nordexe to provide an account of the existence, use, and disclosure of personal information.

22. Nordexe will make the information available within 30 days, or provide written notice of
extension where additional time is required to fulfill the request. When information is not
provided within 30 days of the request, Nordexe will, no later than 30 days after the date of the
request, send a notice of extension to the client, advising of the new time limit, the reasons for
extending the time limit and of the right of the client to make a complaint regarding the
extension.

23. If a request is refused, Nordexe will notify the client in writing, documenting the reasons for
refusal and resources for redress available to the client.

24. The information will be made available at a cost that will vary with the type and amount of
information requested. Where the client will incur a cost, Nordexe will inform the client of the
cost and request further direction from the client on whether or not Nordexe should proceed with
the request.

25. In certain situations, Nordexe may not be able to provide access to any or all personal
information about a client. In such cases, Nordexe will explain the reasons it will not provide the
requested information, and identify resources for recourse available to the client. The reasons for
not providing information may include that it is unreasonably costly to provide, information that
would threaten the life or security of another individual, information generated in a formal
dispute resolution process, information that contains references to other individuals, information
that cannot be disclosed for legal, security, or commercial proprietary reasons, and information
that is subject to solicitor-client or litigation privilege.

26. If the information is demonstrated to be inaccurate or incomplete, Nordexe will amend the
information as required. Where appropriate, Nordexe will transmit the amended information to
Third Parties having access to the information in question.

27. Clients are to direct any complaints, concerns or questions regarding this privacy policy in
writing to the Compliance Officer.

28. Clients may withdraw consent at any time, subject to legal or contractual restrictions,
provided that reasonable notice of withdrawal of consent is given to the Nordexe. On receipt of
notice of withdrawal of consent, Nordexe will inform the individual of the likely consequences
of the withdrawal of consent, which may include the inability of Nordexe to provide certain
products or services, if the information is necessary to provide the products and services.

29. To improve the usability of our website at www.topcanadianmortgage.com, we capture
information about how users interact with our site and what pages they visit. No personal
information is collected as part of this process. The data we collect is used internally to better
understand and support our users.