We at Ritchies Inc. ("Ritchies", "we" or "us") value the trust that you have shown in our business and, in turn, we are committed to maintaining the accuracy, confidentiality, and security of your personal information. To that end, we have adopted this privacy policy.

By providing personal information to us, you signify your consent to Ritchies' collection, use and disclosure of your personal information in accordance with this privacy policy.

For purposes of this privacy policy, "personal information" shall mean any information that can identify an individual directly or through other reasonably available means.

As part of our commitment to treat your personal information with respect, we operate in accordance with the following ten principles (the "Principles"):

1. Accountability
2. Identifying Purposes
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguarding Customer Information
8. Openness
9. Customer Access
10. Handling Customer Complaints and Suggestions

Principle 1 - Accountability
We will maintain and protect the personal information under our control. To that end, we have designated Stephen Ranger as accountable for compliance with the Principles. Please see Principle 10 to obtain the contact information for our Privacy Officer.

Principle 2 - Identifying Purposes
The purposes for which personal information is collected by us will be identified to you before or at the time the information is collected.

At Ritchies, we gather and use personal information to effect your purchase with us, to send you mailing, to develop, maintain and operate "Your Account", to process service and information requests, to process feedback and comments, and to personalize the delivery of content and information to you. Ritchies may also use your order information to invite you to upcoming events in the collecting area in which you have made a purchase and also to send you notices and information on other products and services that we believe may be of interest to you. You may request that Ritchies does not send any such notices or invitations by contacting our Privacy Officer, as noted below.

We only use personal information for the purposes that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will obtain your consent before we proceed.

Principle 3 - Consent
Except where required or permitted by law, your informed consent is required for our collection, use or disclosure of your personal information. By providing personal information to us, you signify your consent to Ritchies' collection, use and disclosure of your personal information in accordance with this privacy policy.

Principle 4 - Limiting Collection
The type of personal information we may ask for depends on and is related to the reason (or purpose) such personal information was provided to us. For instance, you have purchased an item at one of our auctions and would like your purchase delivered to you at home. In this instance, we would require your home address. In addition to the foregoing, the following is a description of the type of personal information that we may ask for:

• your first and last name
• your home telephone number
• home address
• payment information (e.g. credit card)
• email address

The choice to provide us with your personal information is always yours. However, your decision to withhold particular information may result in limiting our ability to provide you with the services or products you requested.

Principle 5 - Limiting Use, Disclosure and Retention
We will only use or disclose your personal information in accordance with the purposes for which it was originally collected unless you have otherwise consented, or when it is required or permitted by law. We will retain your personal information only for so long as is required to fulfill the purpose for which it was collected or as required by law.

The following are the limited instances where we may disclose your personal information to third parties:

• to our partners, which include the LCBO and Sotheby's and other organizations with whom we have entered into a joint venturing agreements, to prepare for, notify you of, and send your invitations to upcoming auctions and to follow up with you on past auctions. In addition, we share this information with such partner so that we may inform you of the widest possible number of items and events of interest to you, including without limitation the sale of new wine releases and to alert you to upcoming lectures and events in connection with vintage wines.
• to investigate potentially fraudulent or questionable activities regarding your merchant account(s) or the use of our services;
• to offer you related products and services that might benefit you;
• in anticipation of and in the course of an actual or potential sale, reorganization, consolidation, merger or amalgamation of our business; and
• when required or permitted by law.

The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to enforce our rights or to investigate suspicion of illegal activities.

Principle 6 - Accuracy
We shall make every reasonable effort to ensure your personal information is maintained in an accurate, complete and up-to-date form.

Principle 7 - Safeguarding Customer Information
We shall utilize no less than industry standards security safeguards to protect your personal information.

Principle 8 - Openness
If you would like a copy of our privacy policies we would be more than happy to provide one to you and if you have any questions regarding same, we are more than happy to discuss the merits with you.

Principle 9 - Customer Access
Upon your request, we shall inform you of: (i) the type of personal information we have collected; (ii) how we have used your personal information in the past, and how we may in the future; and (iii) whether or not we have disclosed your personal information to any third parties (and, if so, to whom). Individuals may verify the accuracy and completeness of their personal information, and may request that it be amended, if appropriate.

To help us keep your personal information up-to-date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us. Please note that before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and provide other details to help us to respond to your request.

You may access and verify any of your information by calling our customer contact centre toll free at 1.800.364.3210.

Principle 10 - Handling Customer Complaints and Suggestions
Customers may direct any questions, complaints or enquiries with respect to the Principles, this Privacy Policy or about our information handling practices by contacting:

Ritchies Inc.
288 King Street East
Phone: 416.364-1864 or toll free at 1.800.364.3210
Fax: 416.364.0704
Email: sranger@ritchies.com

How We Collect Such Personal Information

We may gather such personal information from you in person, over the telephone or by corresponding with you via mail, facsimile or the Internet. Through the use of website cookies (a very small text file that is added to your hard drive from a web page), we monitor the ads you see and the number of times these ads are seen. Through the use of these cookies, we are able to capture standard web traffic information such as time, date, IP address and browser, but in no circumstance do we (or the cookies) capture any information that can identify you as an individual.

Our Employees and your Personal Information:

In the course of daily operations, access to private, sensitive and confidential information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it. For example, when you call us, our designated employees will access your information to verify who you are and to assist you in fulfilling your requests.

As a condition of their employment, all employees of Ritchies are required to abide by the privacy standards we have established. Employees are informed about the importance of privacy and they are required to agree to a code of conduct that prohibits the disclosure of any customer information to unauthorized individuals or parties.

Unauthorized access to and/or disclosure of personal information by an employee of Ritchies is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

How We Safeguard Your Information:

We use industry standard technologies and maintain current security standards to ensure that your personal information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. Electronic customer files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked filing cabinets. Access is also restricted. We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

When you call us you may be required to verify your identity by providing some personally identifying information.

Web Sites Governed by this Privacy Policy:

The web site that is governed by the provisions and practices stated in this privacy policy is: www.ritchies.com.

The Ritchies web site may contain links to other third party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave the Ritchies web site. Additionally, we are not responsible for the privacy practices employed by other third party web sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

Updating this Privacy Policy:

Any changes to our privacy policy and information handling practices will be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this privacy policy.