Privacy and Security
Privacy Principles
By sharing our Privacy Principles, we trust that our individual clients will better understand how we keep client information private and secure while using it to provide services and products. Other privacy principles or policies may apply to clients of certain Kingswell Investment Inc. businesses in certain jurisdictions, such as individual clients in Hong Kong and China. Similarly, Kingswell Investment Inc. clients who receive information from or transact business with Kingswell Investment Inc. through the Internet are covered by the terms and conditions and any privacy notices posted on the Web sites they visit.

We may disclose and transfer any information that is provided through this Web site to: any company within the Kingswell Investment Inc ., its affiliates, agents or information providers; to any other person or entity with a client's consent; or if we have a right or duty to disclose or are permitted or compelled to so disclose such information by law. We may also transmit, transfer or process such information to, or through, any country in the world, as we deem necessary or appropriate (including to countries outside the EEA).

• We protect client information.
  We take our responsibility to protect the privacy and confidentiality of any client information very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal standards to store and secure client information from unauthorized access and use, alteration and destruction. Our own policies and procedures have been developed to protect the confidentiality of client information and to help achieve compliance with relevant rules and regulations. We hold our employees accountable for complying with those policies, procedures, rules and regulations.
• We endeavor to collect, use and maintain client information only for appropriate purposes.?We limit the collection, use and retention of client information to what we reasonably believe will help us deliver superior service, to administer our business, manage our risks, market our services and products, and to meet applicable laws and regulations.
• We share client information with affiliates and with others when we believe it will enhance the services and products we can provide to clients or for legal and routine business reasons.
  • We share client information among our affiliates and business units when we believe it will enhance the services we can provide to clients, but only in circumstances where such sharing conforms to law, any applicable confidentiality agreements, our policies and practices, or where a client has consented to such sharing.
  • We may disclose information we have about clients as permitted by law. For example, we may share information with regulatory authorities and law enforcement officials who have jurisdiction over us or if we are required to do so by applicable law and to provide information to protect against fraud.
  • From time to time, we enter into agreements with other companies to provide services to us or make services and products available to clients. Under these agreements, the companies may receive information about clients, but they must safeguard this information and they may only use it for those purposes that we specify.
    
• We provide clients with relevant and appropriate choices regarding the sharing of information with our affiliates and others.
  We will give clients choices regarding the sharing of information with affiliates and third parties in accordance with applicable law and their agreements with us.
• We comply with the USA Patriot Act, Section 326. Please read this important information about procedures for opening a new account.
  • To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
  • What this means for you: When you open an account, we will ask for your name, address, date of birth (for individuals), and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents.

Online Security Tips
While Kingswell Investment Inc. is committed to ensure the highest standard of security on our systems, you as the end-user also play an important role to ensure that you are adequately protected when you use the Internet. The following security best practices are recommended:

• Install anti-virus, anti-spyware and other internet security software on your PC. Use it regularly and keep it up-to-date.
• Take advantage of your PC's security features. Make sure your browser uses the strongest encryption available and be aware of the encryption levels of the sites and applications you use.
• Regularly update your PC's operating system and Web browser software with the vendor's software patches and updates to protect your PC against known vulnerabilities.
• Do what you can to prevent unauthorized people from using your PC.
• Change your passwords often. Be sure to choose passwords that are hard for others to guess.
• If you notice suspicious activity in your accounts, report it immediately to the appropriate parties.
• Do not download or open any attachments sent to you by unsolicited email. Once opened, these programs may contain malicious programs that can compromise your PC's security.
• Be on the alert for phishing scams.? Access Web sites by typing the Web addresses directly into your Web browser or by using Web addresses you have bookmarked, instead of via embedded links in unsolicited emails.

© Kingswell Investments, Inc. 2007. All right reserved.