1. Accountability: Morningstar CPMS is responsible for personal information under its control and has designated individuals who are accountable for our compliance with the following principles. These individuals are primarily the Senior Vice-President and Operations Manager.

2. Identifying Purposes: Morningstar CPMS shall identify the purpose for which personal information is collected at the time of collection or, when appropriate, at or before the time the personal information is used for a new purpose. The personal information collected is the minimum of information needed to be able to:

a) Process and fulfill your order;

b) Establish and maintain a business relationship with our clients;

c) Identify and appreciate the preferences of our clients when determining upcoming developments and enhancements to our current line of products and/or services.

3. Consent: Consent for collection, use or disclosure of your personal information is obtained when a product and/or service account is established. In obtaining consent, Morningstar CPMS shall use reasonable efforts to ensure that you are advised of the intended purpose for which the personal information is collected, will be used and/or disclosed. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

4. Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purpose of establishing a product and/or service account; the payment, fulfillment, and support of that account; and to conduct our business efficiently.

Cookies

"Cookies" are small text files transferred to the user's browser by a Web server and stored on the user's hard drive. Cookies are only readable by the server that originally places them; they do not run programs and do not contain viruses.

Cookies are used to set users’ preferences, gather basic tracking information (such as login and password), date, time of visit and preferences, and to monitor the presentation of our site. The use of cookies allows Morningstar CPMS to personalize your experience when using our online products and services. Information collected through the use of cookies does not identify you personally. You remain anonymous unless you have otherwise provided Morningstar CPMS with personal information. For additional information, please refer to the remainder of Morningstar CPMS's Privacy Policy.

Please be aware that most web browsers automatically accept cookies. If you do not want to receive cookies, please adjust the options in your web browser to alert you when cookies are issued. You will then be able to specify whether or not to accept the cookie. Please consult your browser's manufacturer for additional information.

When you disable the use of cookies, some Morningstar CPMS’s product features may not work properly, preventing you from taking full advantage of Morningstar's many services and resources.

5. Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required by the law.

6. Accuracy: We will strive to keep personal information as accurate, complete, and up-to-date as is necessary for its intended use.

7. Safeguards: Morningstar CPMS ensures your personal information is protected by security safeguards appropriate to the sensitivity of the information.

8. Openness: If you require further information than that available through this Privacy Policy, please contact our Morningstar Client Relations department at 1 800 531-4725 or (416) 489-7074, option #1.

9. Individual Access: Upon request, you shall be informed of the existence, use and disclosure of your personal information and shall be given access to that information. You shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

10. Challenging Compliance: As a consumer, you can address any issues concerning compliance with the above principles to our designated individuals mentioned above under principle 1: Accountability.

If you have questions regarding our privacy practices or this Privacy Policy, please contact us at: caprivacypolicy@morningstar.com.

For additional information regarding Morningstar Research Inc.’s privacy practices and Morningstar products, please visit http://www.morningstar.ca.

Last revised: July 8^th, 2009