PRIVACY POLICY

Current as at November 15, 2017

The privacy of your personal information is a top priority at Vestcap Investment Management Inc. (“Vestcap”). This Privacy Policy is in effect to protect the privacy of our current and potential clients, employees and business partners. In accordance with applicable privacy legislation, Vestcap follows the following ten privacy principles when collecting, using, disclosing and protecting your personal information:

  1. Accountability. We are accountable for personal information under our control. There is a designated Chief Privacy Officer who ensures our compliance with these principles.
  2. Identifying the Purpose for Collection. The purpose for collecting your personal information is identified at or before the time it is collected.
  3. Consent. We obtain your consent before or at the time of collecting, using or disclosing your personal information, except where legally required or permitted.
  4. Limiting Collection. We limit the personal information that we collect to what is necessary for us to conduct business.
  5. Limiting Use, Disclosure and Retention. The personal information we collect is used or disclosed only for the purposes for which it was originally collected, unless we have your consent or the information is required by law. We retain your personal information for as long as necessary for those purposes.
  6. Accuracy. We take care to update your personal information and its accuracy.
  7. Safeguards. We protect your personal information by using safeguards that are proportionate to the sensitivity of your personal information.
  8. Openness. We are open with you about our policies and practices related to managing your personal information.
  9. Individual Access. We can provide you access to your personal information upon your request. You can also ask us how your information is being used, ensure your records are accurate and complete, and update information if necessary.
  10. Addressing Your Concerns. If you have questions or concerns regarding your privacy, please contact our Chief Privacy Officer using the contact information provided in the section “Contacting Our Chief Privacy Officer.”

Collection, Use and Disclosure of Personal Information

“Personal information” is defined as information about you as an individual. This may include details such as your age, residence, marital status, education, employment history, identification numbers, citizenship and financial information. Vestcap will not sell its client lists or other personal information about clients. We recognize the importance of keeping personal information confidential. We will only collect, use and disclose personal information to

the extent necessary for purposes including:

  •  to provide portfolio management services;
  • in accordance with a written direction by you (for example, if you wish for your spouse to be able to access your financial information, written instructions to the effect should be provided to us);
  • to keep you aware of investment and economic trends and financial products which we think may be of interest to you;
  • to identify and respond to age, marital status, residence, education and citizenship related regulations;
  • to provide you with our newsletter;
  • to send you birthday or holiday greetings; and
  • to apprise you of events hosted or recommended by Vestcap.

We may also ask you for additional information, as required.

We obtain most of your personal information directly from you. We will let you know how your information will be used when we ask for it. With your consent, some information may be obtained from other sources (such as your custodian).

There are many ways that you can give your consent

Your express consent may be given in writing, verbally, or through electronic means.

Examples of express consent:

Written: If you sign an agreement that states: “I agree to the terms on the reverse.”

Verbal: Responding to a question from an employee of Vestcap.

There are exceptions where we may collect, use or disclose information without your prior consent

  1. If we use an outside service provider. At times, your personal information may be provided to a custodian or other outside service provider. We will only release information to the extent that we are required to.
  2. If we are required by law. We may be compelled to release information by a court of law or other legal or regulatory authority. We will only release information to the extent that we are required to.
  3. In the event of fraud or criminal activity.
  4. Should litigation arise.

 

You can withdraw your consent

At any time, you may decline or revoke your consent to our use of your personal information. This may be done by communicating those preferences in a meeting with us, or by contacting our Chief Privacy Officer at the address identified in the section “Contacting our Chief Privacy Officer.”

We protect your information from loss and unauthorized access

We limit access to your personal information to securely store your information. Depending on the nature of the information, it may be stored in the offices of Vestcap or in secure computer systems. Access to your personal information is restricted to those who require it to provide services to you.

Employees who have access to your information are made aware of how to keep it confidential. Each employee is required to sign an agreement stating that maintaining confidentiality is a condition of employment with Vestcap.

When you open an account with a custodian in connection with your Vestcap account, your privacy rights are addressed by that custodian. Other outside service providers retained by Vestcap are required to sign contracts to maintain the confidentiality and security of your personal information, and not to use it for any

unauthorized purpose.

We use a combination of security measures to protect your personal information

In addition to the physical and electronic security devices we use to protect your information, we also have security standards to protect our computer systems and your information from unauthorized use or access.

This protects your information when it is stored in data files or handled by our employees. Our systems also protect your information when it is electronically transmitted.

When your information is no longer needed

The length of time that we keep your information will vary depending on the services that we have provided to you and the nature of the information. We secure or destroy your information in a manner that complies with applicable laws and regulations.

We monitor our compliance with the Vestcap Privacy Policy

We have procedures in place to assist our employees in the application of the Vestcap Privacy Policy. We monitor the practice of these policies and report our findings to our Chief Privacy Officer.

We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as other applicable privacy legislation. Our Chief Compliance Officer is accountable for overseeing our compliance.

We work with you to keep your information accurate

It is important to ensure your personal information at Vestcap is accurate and complete. We make every effort to ensure the information in our records is correct and up to date. However, we also rely on you to tell us when your personal information changes. To update your address and other personal information, please contact your portfolio manager.

You have the right to access, verify, rectify and update your personal information

Upon request, your personal information may be made available to you. A Vestcap employee can help you check your information, update it, and remove any obsolete information.

You can find out where we have collected your information from You can ask us for the source of your personal information if we have obtained it externally.

You can find out to whom we have given information about you

We will provide you with the names of outside companies or organizations to whom we have given your personal information upon your request and where legally permitted. However, we will not advise in respect of ordinary course reports to the Canada Revenue Agency or other legal or regulatory authorities.

Contacting our Chief Privacy Officer

If you have any questions or concerns regarding the Privacy Policy or its application to you, please contact the Chief Privacy Officer at:

Chief Privacy Officer: Roger Glassco

Email: privacyofficer@vestcap.com

Phone: 416-869-0991 or toll-free 1-800-237-0993

Mail: 199 Bay Street, Suite 2902, Toronto, Ontario, M5L 1G5

Upon request, we can also explain the Company’s complaint procedure to you or investigate your complaint. If your complaint is justified, we will take appropriate steps to set the situation right including amending our policies and practices, if necessary. We will also let you know what other complaint procedures may be available to you.

Policy Updates

From time to time, this Policy be amended and updated. The most current version of our privacy policy will be available at www.Vestcap.com or by contacting our Chief Privacy Officer using the contact above.