Privacy Policy and Compliance Procedures

The policies and procedures that Global practices in order to protect your privacy are summarized in this Privacy Policy. For purposes of this policy, "personal information" means information about an identifiable individual, but does not include the name or business contact information of that individual.

Global is responsible for all personal information in its possession or custody. While Global has procedures in place to assist our employees in the practice of the Global Privacy Policies, the overall responsibility for the protection of personal information and compliance with this policy rests with Global's Privacy Officer.

Global uses various third parties to process and store information. It is Global's responsibility to ensure that the written contract with the outside party will afford a comparable level of protection while such third party is processing the personal information. This will usually mean providing a copy of this Privacy Policy to the third party and obtaining a written acknowledgement from the third party that it will be bound by the policy. Further provisions include the return of all personal information to Global upon completion, the destruction of any remaining records in the possession of the third party and an agreement not to use such information except for the purposes of Global. Finally the third party must agree to advise Global immediately of any concerns or objections expressed directly to the third party by Global clients.

Global is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, in relation to e-mail or wireless communication, complete confidentiality and security cannot be assured. Remember that e-mail sent over the Internet is generally unencrypted. We recommend that you use caution when forwarding free-format e-mail messages to us and that you do not include confidential information (such as account numbers) in those messages, as they are not encrypted.

Global is not accountable for any damages suffered when a customer transmits personal information through e-mail or wireless communication to Global or when Global transmits personal information via e-mail or wireless communication to a client on request.

There are certain specific reasons why Global needs to collect information about you:

Besides your name, address and telephone number, we need information to:

• Understand your needs and eligibility for products and services;
• Recommend particular products and services that are suitable to you;
• Maintain appropriate levels of ongoing service;
• Comply with legal and regulatory requirements;
• Establish your identity and provide contact information for you; and
• Protect you and us from error and fraud.

When opening an interest bearing or investment account, the Income Tax Act and other obligations require us to obtain your Social Insurance Number or other tax identification number.

When opening an account that may hold U.S. securities or has U.S. beneficial owners, Global has contractual obligations with the U.S. Internal Revenue Service to obtain U.S. Taxpayer Identification Numbers and/or other citizenship or residential identification information.

When opening a margin account, in order to assess your creditworthiness we ask you for certain financial information (for this reason, we may contact other lenders or credit bureaus to give us information on your credit history).

To ensure the accuracy of your instructions and to monitor the quality of service, Global may record its telephone calls. If you have concerns about the recording of your telephone conversations, you should contact us or forward your instructions to us by e-mail or by regular mail.

Global collects, uses and discloses personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

Your knowledge and consent are required before we may collect, use or release your personal information to anyone outside of Global, except in special circumstances. These special circumstances include times when your consent is deemed given by law or not required by law. These circumstances may include during a fraud investigation, an investigation by police, where the collection, use or disclosure are reasonable for an investigation or proceeding resulting from a breach of an agreement, or in situations set out more specifically below.

For example, Global may collect, use or disclose information without your consent if we:

Use an outside company to process or store information

At times Global uses the services of an outside company to do work for us involving some of your information ­ for example, processing your account information or the mailing of shareholder information.

Must disclose information for legal or contractual reasons

Global may be compelled to release your information by a court of law, or by another legal authority, regulatory authority (including self regulatory authority), or governmental body. In all cases, our policy is to release information only to the extent that we are required to do so.

For regulatory purposes, Canadian self regulatory organizations including Market Regulation Services Inc., the Investment Dealers Association of Canada, Bourse de Montreal Inc., the Toronto Stock Exchange, the TSX Venture Exchange, and the Canadian Investor Protection Fund (collectively, "SROs") require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by persons or firms under their jurisdiction ("Regulated Persons"). SROs collect, use or disclose such personal information obtained from such Regulated Persons for regulatory purposes, including:

• surveillance of trading-related activity;
• sales, financial compliance, trade desk review and other regulatory audits;
• investigation of potential regulatory and statutory violations;
• regulatory databases;
• enforcement or disciplinary proceedings;
• reporting to securities regulators; and
• information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing. We are also required under contractual agreement with the U.S. Internal Revenue Service to disclose certain account information for accounts that hold U.S. securities or have U.S. beneficial owners.

Must protect the interests of Global

In certain circumstances, Global may have to collect, use or release information for its protection. For example, Global may do so when collecting an overdue account, when defending a legal action, to detect or prevent fraud, or to detect or prevent any other illegal or improper activity.

Are acting in a personal emergency

In certain circumstances, Global may be required to collect, use or release information where there is an emergency that threatens an individual's life, health or personal security.

Your consent can be express or implied

Express consent can be verbal or written. For example, when applying for a margin account you give us your written consent for us to obtain a credit report.

You imply consent when Global can reasonably conclude that you have consented to the use of your information, through your action or inaction. For example, in the course of your using your investment account, we employ an outside company to maintain your account data, and can conclude that you have consented to our providing your information to the outside company.

You can withdraw your consent after you have given it

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. To withdraw your consent you must contact our Privacy Officer, in writing, using the contact information listed in SECTION 10 of this Policy.

If you don't consent to certain uses of information, or if you withdraw your consent, Global may not be able to provide you with a particular product or service or we may not be able to provide service to you at all.

Personal information shall not be collected indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified.

The information is only used for specific purposes

Personal information will only be used or disclosed for the purpose(s) for which it is collected. Global will not use personal information for any additional purpose unless we obtain your consent to do so.

Global will not sell personal information to any third party without first obtaining your consent.

Your information is destroyed when it is no longer needed

Global keeps your information only for as long as we need it, for the products and services you are using, to offer you products and services when you are a customer, to protect the interests of Global, or to meet any legal requirements. Please note that Global retains your information for a significant period of time in order to assist you and Global in reviewing your historical account information when necessary.

Global will make reasonable efforts to ensure that personal information is as accurate, complete and current as required for the purposes for which it was collected. In some cases, Global relies on its clients to ensure that certain information, such as their address or telephone number, is current, complete and accurate.

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

You can check your information to verify, update and correct it, and to have any obsolete information removed. Please make your request in writing to our Privacy Officer as set out in SECTION 10 of this Policy. Global will charge a reasonable fee for accessing your information.

You can check much of your personal information routinely, for example, by carefully examining your account statements and confirmation slips.

Security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The safeguards may include, for example, the physical security of offices and storage facilities or electronic security measures such as passwords, encryption and personal identification numbers. Our systems also protect your information when it is transmitting data, for example, between Global and our third party data processors. The nature of the safeguards will vary according to the sensitivity of the information. Global will monitor security developments and re-assess the risks at regular intervals.

As also set out more fully in SECTION 1 of this Policy, Global is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, in relation to e-mail or wireless communication, complete confidentiality and security cannot be assured.

Global is not accountable for any damages suffered when a customer transmits personal information through e-mail or wireless communication to Global or when Global transmits personal information via e-mail or wireless communication to a client on request.

Care shall be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.

Global is open about the policies and procedures it uses to protect personal information. Information about those policies and procedures will be made available either electronically or in written format in plain language. However, to ensure the integrity of our security procedures and business methods, Global may refuse to publicly disclose certain information.

Global will make the following information available

The name, title, and address of the Privacy Officer, and how an individual may contact the Privacy Officer with respect to complaints or inquiries

A description of the type of personal information held by Global including a general explanation of its use

Information on how an individual can gain access to the personal information held by Global by contacting the Privacy Officer, confirming their identity, and requesting specified information

A copy of any brochures or other information that explain Global's policies and procedures

An explanation of what personal information is made available to related organizations

You have the right to access the personal information held by Global. Please make any requests for access in writing, stating as specifically as possible the personal information you are requesting. Upon request, Global will, within a reasonable time period, tell you what personal information it has, what it is being used for, and to whom it has been disclosed, if applicable, within the time period for which records are available. Before providing any information to the requestor, Global must verify the individual's identity.

Global may also not provide access where it would reveal personal information about, or the identity of, a third party that cannot be severed from the information about the individual making the request, and in certain other circumstances there needs to be notification of governmental institutions before release. Access may also be refused where the information is protected by solicitor-client privilege; where revealing the information would also reveal information confidential to Global; where revealing the information could reasonably be expected to threaten the life, health or security of an individual; if the information was collected during an investigation of a breach of an agreement or a contravention of the laws of Canada or a province on the expectation that the knowledge or consent of the individual would compromise the availability or accuracy of the information; or where the information was generated in the course of a formal dispute resolution process. In such cases, Global will explain the reasons it will not provide the requested information.

We will respond to your request promptly

Global will deal quickly with your request for access, and will almost always respond to you within 30 days. If we need to extend the time, or we must refuse your request, we will tell you why, subject to any legal restrictions and we will notify you of the new deadline, the reasons for the extension, and of your right to make a complaint to the relevant privacy commissioner regarding the extension.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Global must amend the information as required. Depending upon the nature of the information challenged, amendment could involve the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

When a challenge is not resolved to the satisfaction of the customer, the substance of the unresolved challenge shall be recorded by Global. When appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question.

Global will charge you a reasonable fee for providing access to your personal information.

If you have any questions or complaints about our privacy policies, or about how Global is living up to them, let us know right away.

Global is committed to treating you with the greatest respect and consideration, and providing the highest level of service. Even so, from time to time something may go wrong. There may be a misunderstanding, or you may feel you have been dealt with unjustly. In most cases, simply telling us about it and discussing it with us will resolve a complaint. Whatever the circumstances, resolving the problem for you is our primary concern.

How to resolve concerns and complaints at Global

Please contact our Privacy Officer to discuss any privacy issues or concerns you might have, or to lodge a complaint. Our Privacy Officer can be contacted in the following ways:

If you are not satisfied with the Global's decision regarding your complaint

Should you not be able to accept Global's conclusion of your complaint, or at any time in the complaint process, you may also write to the relevant provincial Privacy Commissioner, or if applicable, the Privacy Commissioner of Canada. Global will provide you with this contact information upon request.

We have a separate Privacy Policy For Employees, which contains certain additional provisions.

Changes

From time to time Global may make changes to this policy to adapt to changing business conditions and for other reasons. In the event that in the opinion of Global acting reasonably such changes will allow Global to make materially greater use and/or disclosure of any personal information, the individuals affected by the changes will be clearly and concisely notified of the changes and their proposed effect, and provided with an opportunity to withdraw their consent to the collection, use and/or disclosure of their personal information.