In the Sarbit Privacy Code, the words "we", "us" and "our" means Sarbit and the words "you" and "your" means a client of Sarbit.  Sarbit includes Sarbit Asset Management Inc. and its affiliates which provide investment, securities, advisory, insurance and other financial products and services from time to time, including Sarbit Advisory Services Inc.   

Sarbit is committed to protecting your privacy.
At Sarbit, respecting privacy is an important part of our commitment to our clients.  That is why we have developed the Sarbit Privacy Code.  The Sarbit Privacy Code is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information by Sarbit.  The objective of the Sarbit Privacy Code is to promote responsible and transparent personal information management practices.

The following principles guide us in the collection, use, retention and disclosure of personal information.

We are responsible for your personal information
We have appointed a Chief Privacy Officer, being the Chief Financial Officer of Sarbit Asset Management Inc. that is responsible for overseeing the collection, use, retention and disclosure of personal information within Sarbit.

We will inform you of the purpose for collecting your personal information
We identify the purposes for which personal information is collected at or before the time it is collected.

We obtain consent for the collection, use or disclosure of your personal information
An individual's knowledge and consent is required for the collection, use or disclosure of personal information, except where inappropriate.

We limit the collection of personal information
We limit the collection of personal information to that which is necessary for the purposes identified.  We collect personal information by fair and lawful means.

We only use or disclose personal information for identified purposes and retain it only as necessary
We use or disclose personal information only for identified purposes, except with the consent of the individual or as required or permitted by law.   We retain personal information only as long as necessary for the fulfillment of the identified purposes.

We maintain the accuracy of your personal information
Personal information maintained is as accurate, complete, and up-to-date as is necessary for the identified purposes.  We amend our records and, where appropriate, advise third parties regarding any changes to maintain the accuracy and completeness of personal information.

We are sensitive to your privacy and will protect your personal information
  We protect personal information through safeguards appropriate to the sensitivity of the information.

We are open about our privacy policies and procedures
We will make readily available to the individual specific information about our policies and procedures relating to our management of personal information. In the Sarbit Privacy Code, the words "we", "us" and "our" means Sarbit and the words "you" and "your" means a client of Sarbit.  Sarbit includes Sarbit Asset Management Inc. and its affiliates which provide investment, securities, advisory, insurance and other financial products and services from time to time, including Sarbit Advisory Services Inc.  

We allow you access to your personal information
We inform an individual of the existence, use and disclosure of his or her personal information upon request and provide the individual access to that information.  An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

We provide you with the answer
An individual is able to address a challenge concerning compliance with the above principles to Sarbit's Chief Privacy Officer.

Sarbit will inform clients of its Commitment to Privacy statement, which explains why personal information is collected and which identifies how personal information is used and disclosed.

For more information regarding the Sarbit Privacy Code and our Commitment to Privacy Statement, please contact our Chief Privacy Officer toll-free at 1-877-272-7248 or via email at support@sarbit.com.  Access requests, inquiries or complaints should be addressed in writing to:  Sarbit Asset Management Inc, 100 – One Evergreen Place, Winnipeg, Manitoba.