JayCap Financial Ltd / JayCap Trust Privacy Policy and Procedures

At JayCap Financial Ltd / JayCap Trust (JayCap) we believe in building relationships with our customers. These relationships are built on trust and respect. Part of the process of establishing trust and respect is to inform you of our information handling practices, the reasons for these practices, security steps in place to protect your information and your role in controlling your own personal information.

We acknowledge that your personal information is a valued asset and we want you to know we will treat it that way.

 Collecting Personal Information

JayCap accepts personal information from both potential borrowers and investors. This information may come from individuals, partnerships, proprietorships or companies, or from a related party.

In order to provide you with our services, we may collect the following information about you:

* Contact and mailing information such as your name, address, telephone numbers, fax number and email addresses;

* Your date of birth, Social Insurance Number

* Employment information

* Credit information (incl. Personal Net Worth statement)

* Financial and Non-Financial Asset and Liability Listing

* Personal References

* Information about the nature and financial situation of any company where you are a significant shareholder

* Insurance information

* Any other relevant information which is necessary to provide you with our services.

In the case that we receive your information from a mortgage broker or other similar professionals our Privacy Policy and Procedures will apply the same as if we collected the information ourselves. Furthermore, your knowledge and consent is required for the collection, use or disclosure of your information, except where required or permitted by law.

Upon written request, you will be informed of the existence, use and disclosure of your information, and be given access to it. You may verify the accuracy and completeness of your information, and have it amended at any time, if appropriate.

Purposes of Collection

We will only collect the personal information we require to fulfill the following purposes:

* To secure a mortgage on the clients behalf;

* To prepare security documents;

* To verify identity;

* To cross reference residential and business addresses;

* To establish credit worthiness and ability to repay;

* To assess clients present and future needs;

* To establish character regarding history of completing contracts;

* To protect our security interests;

* To negotiate or sell our security interests; and,

* Any other purpose that may be required or permitted by law.

 Information Disclosure to Third Parties

JayCap may disclose your information to third parties that may include but are not limited to:

* Accountants, Auditors, Lawyers, Employees, Internal Loan Committee, and company Directors;

* Banks, Lenders and Creditors;

* Credit representative agencies;

* Home Insurance and Mortgage Insurance and Title Insurance Corporations;

 Obtaining Consent

We believe that part of establishing trust and integrity comes from allowing you to decide whether you wish to provide your personal information to us at the time we ask for it.

Accordingly, we will advise you of the personal information we require, and the purposes for which that information is being collected.

* When we are dealing with each other over the telephone, we will obtain your verbal consent.

JayCap will use a number of methods to obtain permission for the collection of personal information:

* Client signs and dates a Know Your Client (KYC) Form, Relationship Disclosure Document, Personal New Worth Statement or credit application with privacy policy disclosure.

* Client signs the commitment letter authorizing collection, use and disclosure.

* When a client authorizes an intermediary third party to release information to JayCap on their behalf.

Safeguarding your Personal Information

Like you, JayCap value your personal information.

Part of valuing your personal information is ensuring it is protected and kept confidential. The following procedures are enforced to ensure your information is secure:

* Filing cabinets and areas where files are stored are in a safe and secure environment;

* Only employees who need access to the storage areas or filing cabinets have access to them;

* Shredding of papers containing personal information rather than placing them in a garbage can or recycling bin;

* Training our employees so they know our privacy policies for protecting personal information and the consequences of not following them;

* Having employees that understand trust and confidentiality;

* Using firewalls and anti-virus programs on our computers;

* Using passwords to make sure that only certain employees have access to information on computers and changing the passwords often;

* Erasing computer hard-drives before we sell or otherwise dispose of them;

* Continuous review and update of files;

* An off site back up system specialized encrypting system is used to protect your online information from being hacked or exposed to outside sources without your prior consent.

Updating and Retention of your Personal Information

JayCap will do its best to ensure that your personal information is accurate, complete and kept current.

We will accomplish this by:

* A JayCap employee will contact you to verify your personal information before any decisions are made or action is taken.

* Public databases, credit bureaus and reporting agencies are utilized to confirm the information is accurate.

* Due diligence on the part of the client to inform us of the change or error in any personal information.

 Retention of Information

We retain information as long as is necessary to continue to meet your needs and any legal requirements we may have.

However, once your personal information is no longer needed and there is no longer legal or other issues that prevent a file from being destroyed we will destroy the information based on the suggested timetable:

* For clients who invest money and clients who borrow funds, the personal information will be retained for a minimum of 7 years from payout but not longer than 8 years subject to any laws which may require a longer retention period.

* For clients and investors who have been declined or have withdrawn their applications, their personal information will be destroyed between a minimum 1 year and maximum 2 years from date of decline or withdrawal subject to any laws which may require a longer retention period.

Destruction of Information

To ensure that information is properly destroyed, all files are reviewed annually as part of our Compliance process. It is JayCap’s Privacy Officer’s responsibility to review all investor and borrowers files (paper and electronic); destroying documents and files older than 7 years.

As well as to destroy any and all personal and financial information older than two years for declined or withdrawn clients and investors subject to any laws which may require a longer retention period.

Access, Complaints and Inquiries

Should you wish to access your personal information or have any complaints or questions about JayCap’s Privacy Policy please contact our Privacy Officer.

Phone: 1.780.641.0555

Fax: 1.780.643-3043

Email: info@jaycap.ca

All issues will be referred to the President and the Privacy Officer of JayCap Financial Ltd.

The Privacy Officer shall make an initial response to all inquiries and complaints within 48 hours. If the request cannot be handled immediately a reasonable time estimate will be made for the response.