Privacy Policy

Introduction  |  Personal Information  |  Privacy Principles
Identified Purposes for the Collection, Use and Disclosure of Personal Information
Privacy and our Websites  |  Changes to this Privacy Policy  |  Further Information

1. Introduction
Noranda Income Fund is committed to maintaining the accuracy, security and privacy of personal information in accordance with applicable laws. This Privacy Policy is a statement of principles and guidelines for the protection of personal information of our website visitors, customers, personnel, service providers and other individuals. The objective of the Noranda Income Fund Privacy Policy is to ensure responsible practices in the collection, use and disclosure of personal information, in accordance with applicable legislation.

This Privacy Policy applies to Noranda Income Fund its affiliates and its personnel and agents. Noranda Income Fund does not include resellers or distributors of Noranda Income Fund products and services. For the purposes of this Privacy Policy, "affiliates" means the parent company, subsidiaries and affiliated companies of Noranda Income Fund, as they may exist from time to time.

In addition to this Privacy Policy, Noranda Income Fund may also be subject to the requirements of applicable legislation and regulations and the orders of any court, regulatory body or other lawful authority.

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2. Personal Information
Personal information is information about an identifiable individual. Personal information does not include aggregated information that does not allow an individual to be identified. An individual's business contact information, such as his or her name, title, business address, business telephone and business facsimile numbers, are not considered to be personal information.

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3. Privacy Principles
The following are the ten privacy principles forming this Privacy Policy.

Principle 1 – Accountability
Noranda Income Fund is responsible for personal information under its control and will designate one or more persons who are accountable for Noranda Income Fund's compliance with the following principles. Noranda Income Fund has established a Chief Privacy Officer to oversee compliance with this Privacy Policy. Contact information for the Noranda Income Fund Chief Privacy Officer is provided below.

Principle 2 – Identifying Purposes for Collection of Personal Information
Noranda Income Fund will identify the purposes for which personal information is collected at or before the time the personal information is collected. Some of the identified purposes for which Noranda Income Fund collects, uses or discloses of personal information are described in Section 4 below.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
Noranda Income Fund will use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Noranda Income Fund will take into account the sensitivity of the personal information and the reasonable expectations of a reasonable person. Consent will not be obtained through deception. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Noranda Income Fund will advise the individual of the implications of such withdrawal.

Principle 4 – Limiting Collection of Personal Information
Noranda Income Fund will limit the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by Noranda Income Fund. Personal information will be collected by fair and lawful means, and not by misleading or deceiving individuals about the purpose for which information is being collected.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
Noranda Income Fund will not use or disclose personal information for purposes other than the identified purposes for which it was collected, except with the consent of the individual or as required or permitted by law. Noranda Income Fund will retain personal information only as long as necessary to fulfill the identified purposes.

Principle 6 – Accuracy of Personal Information
Noranda Income Fund will use reasonable efforts to keep personal information accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Noranda Income Fund may, from time to time, contact you to update your personal information as may be necessary to fulfill the identified purposes; however, you acknowledge that if you fail to update your personal information with Noranda Income Fund, this may affect Noranda Income Fund's ability to provide you with products, services or information which may be of value to you.

Principle 7 – Security Safeguards
Noranda Income Fund will protect personal information by security safeguards appropriate to the sensitivity of the information. Noranda Income Fund will use reasonable efforts and security measures to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, disposal or destruction. Noranda Income Fund will protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the limited purposes for which it is to be used.

Principle 8 – Openness Concerning Policies and Practices
Noranda Income Fund will make readily available to individuals specific information about its policies and practices relating to the management of personal information. Noranda Income Fund will make information about its personal information policies and practices available on the Noranda Income Fund website at www.norandaincomefund.com and upon request to the Chief Privacy Officer via the contact information provided below.

Principle 9 – Individual Access to Personal Information
Upon written request from an individual pursuant to Principle 8, Noranda Income Fund will inform the individual of the existence, use, and disclosure of his or her personal information and, subject to certain exceptions, will give the individual access to that information. If access is denied, Noranda Income Fund will notify the requesting individual in writing, give reasons for the denial, and inform the individual of the recourses open to him or her. If access is granted, Noranda Income Fund will give the requesting individual a reasonable opportunity to consult the personal information collected by Noranda Income Fund. Personal information will be provided in an understandable form within a reasonable time, generally within 30 days, and at minimal cost to the individual. Noranda Income Fund may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Noranda Income Fund or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Challenging Compliance
An individual will be able to address a challenge concerning compliance with this Privacy Policy to the Noranda Income Fund Chief Privacy Officer.

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4. Identified Purposes for the Collection, Use and Disclosure of Personal Information
Noranda Income Fund and its agents, affiliates and service providers may collect, use or disclose your personal information for the following purposes:
  1. to understand and respond to website visitor and customer needs and preferences, including to communicate with website visitors and customers and to conduct surveys, contests and promotions;
  2. to develop, publish and distribute our newsletters, press releases, marketing and advertising media, and other Noranda Income Fund branded products and services, in any format or media;
  3. to develop, enhance, market, sell, provide and inform you of Noranda Income Fund's products and services;
  4. to manage and develop Noranda Income Fund's and its affiliates' businesses and operations;
  5. to detect and protect Noranda Income Fund, its affiliates, and other third parties against error and fraud and other illegal activity, and to audit compliance with Noranda Income Fund's corporate policies and contractual obligations;
  6. as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
  7. for any other purpose to which you consent.
Noranda Income Fund may collect and use your personal information received from an organization (or its affiliate) or an individual who, in the reasonable judgment of Noranda Income Fund, is providing the information as your agent, where you consent, or previously consented, to such collection or as required or permitted by law.

Noranda Income Fund may disclose your personal information to an organization (or its affiliate) or an individual who, in the reasonable judgment of Noranda Income Fund, is receiving the information as your agent, where you consent, or previously consented, to such disclosure, or as required or permitted by law, and may also disclose your personal information to an organization (or its affiliate) or an individual who has been retained by Noranda Income Fund to perform functions on its behalf or to provide services to Noranda Income Fund, provided such organization or individual does not collect, use or disclose the personal information for any purpose other than to perform such functions or provide services to Noranda Income Fund, all where you consent, or previously consented, to such collection or as required or permitted by law.

Noranda Income Fund, or its third party services providers, may be located outside of Canada. Your personal information may be transferred, stored and/or processed outside of Canada and in that case, your personal information would be subject to the laws of the country to which it is transferred. That country may have laws that require that your personal information be disclosed to the government under different circumstances than would Canada.

In the event of a sale, amalgamation, re-organization, transfer or financing of parts of some or all of Noranda Income Fund, your personal information may be disclosed to an acquiring organization, either as part of due diligence and/or on completion of the transaction. If your personal information is ever disclosed to an unaffiliated third party in this context, Noranda Income Fund will require that all third parties agree to protect your personal information in accordance with this Privacy Policy.

Consent
BY SUBMITTING PERSONAL INFORMATION TO NORANDA INCOME FUND OR ITS AFFILIATES, SERVICE PROVIDERS AND AGENTS, YOU AGREE TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH PERSONAL INFORMATION FOR THE IDENTIFIED PURPOSES DESCRIBED IN THIS PRIVACY POLICY OR DESCRIBED AT THE TIME SUCH PERSONAL INFORMATION WAS COLLECTED, PROVIDED THAT SUCH COLLECTION, USE AND DISCLOSURE IS IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Subject to legal and contractual requirements, you may refuse or withdraw your consent to any one or all of the purposes described in Section 4(a), at any time with reasonable notice by contacting the Noranda Income Fund Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to establish or maintain a commercial relationship or provide you or continue to provide you with some products, services or information which may be of value to you. To the extent that you provide Noranda Income Fund with personal information of another person, you represent that you have the authority or have obtained all necessary consents from such person to enable Noranda Income Fund to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.


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5. Privacy and our Websites
Cookies – When you access the Noranda Income Fund websites, we may use a browser feature called a 'cookie' to collect information (such as the type of Internet browser and operating system you use, the domain name of the website from which you came, number of visits, average time spent on our website, and pages viewed). A cookie is a small text file that is stored by your web browser on your computer's hard drive. Cookies enable Noranda Income Fund to facilitate access to different aspects of the Noranda Income Fund websites, and to enhance your experience on the Noranda Income Fund websites. In addition to the identified purposes described in this Privacy Policy, Noranda Income Fund may use this cookie information and share it with our affiliates and other organizations with whom we have a commercial relationship to measure the use of our websites and to improve the functionality and content of the websites. If you wish, you can reset your browser either to notify you when you have received a cookie or refuse to accept cookies; however, if you refuse to accept cookies, you may not be able to use certain features on our websites.

Online Communications – In order to provide you with a product, service or information, you may be asked to submit personal information to us for purposes such as registering for our services, obtaining information, corresponding with us, and participating in surveys. We may use and/or combine this additionally submitted personal information with other personal information we have collected for the identified purposes described in this Privacy Policy

E-Mail Communications – Occasionally, Noranda Income Fund may send you e-mail communications with information that may be useful to you, including information about the products and services of Noranda Income Fund, its affiliates and other third parties with whom we have a commercial relationship as well as other important information about the products and services that you have purchased or subscribed to with us. We will include instructions on how to unsubscribe and inform us of your preferences if you decide you do not want to receive any future marketing or promotional e-mails from Noranda Income Fund. You acknowledge that if you choose to unsubscribe to these email communications we may not be able to provide you or continue to provide you with some products, services or information which may be of value to you.

Links – Our website may contain links to other websites, which are provided to you as a convenience only. You are advised that other third party websites may have different privacy practices than Noranda Income Fund, and Noranda Income Fund has no responsibility for such third party websites.

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6. Changes to this Privacy Policy
Noranda Income Fund reserves the right to modify or supplement this Privacy Policy at any time. If we make any change to this Privacy Policy, we will post such changes on our website and they will be available upon request to the Noranda Income Fund Chief Privacy Officer. However, Noranda Income Fund will seek an individual's consent if it seeks to collect, use or disclose his or her personal information for purposes other than those to which the individual has consented unless otherwise required or permitted by law.

Changes to our Privacy Policy will be noted here so that you can be fully informed about our privacy policies and practices.

Date last revised: April 23, 2012
Description of Revision: Entire new replacement document

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7. Further Information
For more information on Noranda Income Fund's privacy practices or if you have questions or concerns about your privacy, you can contact us through the Noranda Income Fund website at www.norandaincomefund.com or by contacting the Chief Privacy Officer at:
Noranda Income Fund Chief Privacy Officer:
Michael Boone
Tel: 416-775-1561
info@norandaincomefund.com

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