PRIVACY POLICY

EFFECTIVE DATE: August 28, 2007

This privacy policy (this "Policy") describes the manner in which Seniors Money Limited ("Seniors Money") collects, uses and/or discloses personal information, including on our website at the following URL/domain name: http://www.seniorsmoney.ca.

Modification of Website

Seniors Money may change this Policy, or change, modify or withdraw access to, or the content on the website, at any time, with or without notice, so you should check this Policy regularly. Seniors Money has posted above the effective date of this version of the Policy for your reference.

Linking to the Website

Links to the website without the express written permission of Seniors Money are strictly prohibited. Seniors Money does not endorse and has no responsibility, liability or control over any other websites or their collection, use or disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect, use or disclose your personal information.

General Privacy Principles

At Seniors Money, we are committed to providing our customers with exceptional service. Part of providing this service involves the collection, use and disclosure of some personal information about our customers. We respect the privacy of our customers and are committed to the protection of the personal information of individuals who visit the website. "Personal information" is any factual or subjective personal information, recorded or not, about an identifiable individual. Seniors Money does not engage in the practice of selling or trading personal information to third parties for promotional purposes.

Accountability

Seniors Money will be responsible for personal information in its possession, including information that has been transferred to a third party for processing. Seniors Money has designated a Privacy Officer who is accountable for Seniors Money's privacy compliance. Please refer to the Comments and Questions heading below for information on contacting our Privacy Officer.

Identifying Purposes

Seniors Money may collect, use and/or disclose personal information about you from time to time (including through the website). You are not required to provide your details or complete any registration process before you can use this website. We may use your information to administer any prize draws or competitions you may enter. When you use certain products and services, you may be required to provide your details, for example, in completing a loan application. Any time Seniors Money collects personal information about you, it will notify you of the specific purposes for such collection, at or before the time of collection, and obtain the appropriate consent from you. When you provide us with your information, the specific privacy statement for any product or service will explain to you how we may use information to select products or services which we think will interest you. We may keep you informed of such products and services (including special offers, discounts, offers, competitions and so on by any of the following methods: e-mail, telephone, SMS text message, post, or otherwise (including products and services of other companies and organizations) which we consider may be of interest to you. If you do not wish to receive such information you will be provided with the means to indicate this when you use the particular products or services on this website.

In addition to the personal information you may provide us, the website uses technology that allows Seniors Money to collect certain technical information. This information includes your Internet protocol address, your computer's operating system, your browser type and the address of any referring web sites. From time to time, Seniors Money may place information on your computer to allow Seniors Money to identify you. This information is commonly known as "cookies". By showing how and when Seniors Money visitors use the website, this information can help Seniors Money continue to improve the website. The use of cookies is an industry standard and many websites use them. If you do not wish to receive cookies, or want to be notified of when they are placed, you may set your web browser to do so, if your browser so permits. Please understand, however, that if cookies are turned off, you may not be able to view certain parts of the website that may enhance your visit.

Affiliates, Third Parties and Related Organizations

By using the website, you accept that your personal information, gained through registration or otherwise in connection with your use of the website and its services, may be transferred across international borders to server locations supporting the website (including but not limited to transfers from those locations back to the country of your registration) for operating and developing the website and its services (e.g., administering contest and promotions), including transfers to Seniors Money's affiliates, related organizations, subcontractors or agents who perform tasks related to the website and its services, or for the purposes of storing the data in the relevant database which may be located in countries other than your country of work or residence. Seniors Money will not disclose your personal information to any other third party without your permission.

Limiting Collection, Use, Disclosure and Retention

Seniors Money will limit its collection of personal information to that information which is necessary for the purposes identified in this Policy (or otherwise identified by Seniors Money at the time of collection of the personal information) and will only use such information for the purposes identified. Seniors Money will only disclose your personal information as previously identified and consented to by you. Seniors Money retains your personal information only for so long as is necessary to fulfill the purposes identified.

Seniors Money has the right, but not the obligation, to retain and use personal information stored in Seniors Money's databases and other information obtained from you and/or obtained from your current or previous activities on the website for a reasonable period of time, not to exceed any legal requirements or limitations, to resolve disputes, troubleshoot problems and enforce Seniors Money's rights and the terms and conditions of this Policy and other terms governing use of the website. Seniors Money may evaluate your information to track users with multiple user ID's or aliases for legal and/or security purposes. Please also note that if Seniors Money is compelled by law, court order or other judicial process to disclose any of your personal information to a court, administrative body, government agency or other third party, Seniors Money will attempt to give you prior notice using the contact information you provided. You hereby authorize Seniors Money to disclose any information about you for any of the above stated purposes.

Security Safeguards

We take security issues seriously and will endeavor to take all reasonable steps to protect your personal information. We use 128-bit secure encryption through a secure socket layer. This is currently the Internet standard for the secure transmission of data. Seniors Money Limited employs reasonable security safeguards appropriate to the sensitivity of the personal information in our possession or under our control in order to protect that information from unauthorized access, collection, use, disclosure, modification or similar risks. Where personal information is stored or accessed outside Canada, it is subject to the personal information protection and other laws, if any, of that other jurisdiction.

Openness

Through this Policy, Seniors Money has made readily available specific information about its policies and practices relating to the management of personal information. You are welcome to print this Policy for your reference. Please contact our Privacy Officer if you are unable to print a copy and wish to receive a printed copy by mail.

Sale, Transfer, Reorganization

Seniors Money may be involved in the sale, transfer or reorganization of some or all of our business at some time in the future, including by securitizing your mortgage (an agreement with other lenders to share the credit risk and security). As part of any such arrangements, Seniors Money may disclose your personal information received from time to time to other persons considering participating in such transaction and their advisors or agents, subject to reasonable confidentiality provisions.

Access, Accuracy and Challenging Compliance

You may request access to your personal information and information about Seniors Money collection, use and disclosure of that information by sending your request to our Privacy Officer. Please refer to the Comments and Questions heading below for information on contacting our Privacy Officer. Subject to certain exceptions and limitations prescribed by law, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. You can help Seniors Money maintain the accuracy of your information by notifying us of any changes.

Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information at any time on reasonable notice, subject to legal or contractual restrictions (such as where we have extended credit to you and are required to collect or disclose your personal information on an ongoing basis from or to third parties). If you withdraw your consent, Seniors Money may not be able to provide certain products and services to you.

Comments and Questions

Seniors Money takes privacy seriously and welcomes questions and feedback on its management of personal information. Any comments or questions about this Policy or about the information we have gathered about you may be directed to Seniors Money's Privacy Officer at:

Seniors Money
Attention: Privacy Officer
Email: info@seniorsmoney.ca