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The ShareOwner Group of Companies ("ShareOwner") is committed to maintaining the accuracy, confidentiality, and security of your personal and financial information. ShareOwner adheres to Ten Privacy Principles to govern our actions concerning the use of customer information. These principles are derived from the Canadian Standards Association's Model Code for the Protection of Personal Information.
 
Principle 1 - Accountability
ShareOwner is responsible for maintaining and protecting the customer information under its control. Accordingly, ShareOwner is required to designate an individual or individuals that are accountable for the Company's compliance with the Ten Privacy Principles.

Principle 2 - Identifying Purposes
The purposes for which customer information is collected shall be identified before or at the time the information is collected.

Principle 3 - Consent
The knowledge and consent of the customer are required for the collection, use or disclosure of customer information except where required or exempted by law.

Principle 4 - Limiting Collection
The customer information collected must be limited to that which is necessary for the purposes identified by ShareOwner. Information must be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention
Customer information may only be used or disclosed for the purpose for which it was collected unless the customer has otherwise consented, or when it is required or permitted by law. Customer information may only be retained for the period of time required to fulfill the purpose for which it was collected.

Principle 6 - Accuracy
Customer information shall be as accurate, complete and up-to-date as is necessary to fulfill the purposes for which it is to be used.

Principle 7 - Safeguarding Customer Information
Customer information must be protected by security safeguards that are appropriate to the sensitivity level of the information.

Principle 8 - Openness
ShareOwner shall make information available to customers concerning the policies and practices that apply to the management of their information.

Principle 9 - Customer Access
Upon request, a customer shall be informed of the existence, use and disclosure of their information, and shall be given access to it. Customers may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Principle 10 - Handling Customer Complaints and Suggestions
Customers may direct any questions or inquiries with respect to the privacy principles outlined above or about our practices by contacting the designated person(s) accountable for privacy at ShareOwner.


Types of Information We Collect
ShareOwner collects two types of information from our customers and website visitors. With your consent, we collect personal information. We may also collect anonymous/non-personal information.

Personal Information
Personal information is information that refers to you specifically. With your consent, we may gather personal information from you in person, over the telephone and fax or by corresponding with you via mail or the Internet.

The type of information we usually collect and maintain in your customer file may include (but is not limited to):

For Personal Customers:
Name
Mailing Address
E-mail Address
Telephone Number
Social Insurance Number
Date of Birth
Place of Employment
Annual Income
Credit History
Transaction History

For corporate customers, information may include:

Business Numbers
Business Name
Business Address
Business Telephone Number
Name(s) of Owner(s), Officer(s) and Director(s)
Industry Type
Financial Status

The choice to provide us with personal and financial information is always yours. In financial dealings, however, your decision to withhold particular details may limit the services we are able to provide.

Anonymous/Non-Personal Information
ShareOwner routinely collects anonymous/non-personal information. Anonymous/non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit ShareOwner's website. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected may be used for research and analytical purposes. For example, we are able to determine how many times our privacy policy has been visited but we do not know any specific information about those visitors.

To help us better understand our markets, we may also gather information for analytical purposes by conducting anonymous customer surveys.

When Information May be Disclosed to Outside Parties
ShareOwner is obliged to keep your personal and financial information confidential except: 1) when authorized by you; 2) when required by law; and, 3) when permitted by law.

When Authorized by You
The Client Account Agreement outlines the terms and conditions associated with acquiring specific products or services from ShareOwner Investments. In general, it establishes the rights and obligations of both parties as they relate to the provision of that product or service.

With respect to the matter of privacy, the Client Account Agreement authorizes us:
To collect credit and related financial information (including information related to transactions) from: you, from ShareOwner businesses, affiliates and subsidiaries, from credit agencies, from other financial institutions, and from references provided by you. To use personal or business information to determine your financial situation, to provide the services you have requested, to share with other ShareOwner businesses, affiliates and subsidiaries, and to offer additional products and services that might benefit you. To share your information with credit agencies and other financial institutions.

To use your Social Insurance Number for tax reporting and for credit agencies matching purposes only. In some cases, your consent to the use and/or disclosure of your information will be obtained verbally. In other cases, your consent will be obtained electronically.

When Required by Law
The type of information we are legally required to disclose most often relates to 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 who are making the request have legitimate grounds to do so.

When Permitted by Law
There are some situations where we are legally permitted to disclose personal information such as returning a cheque due to insufficient funds, employing reasonable and legal methods to collect a delinquent account or suspicion of illegal activities.

Access to Personal Information of Clients and Others for Regulatory Purposes
For regulatory purposes, Self Regulatory Organizations ("SROs") require access to personal information of current and former clients, employees, agent, directors, officers partners and others that has been collected or used by Regulated Persons, SROs collect, use or disclose such personal information obtained from regulated persons for regulatory purposes, including:

Surveillance of trading-related activity, sales, financial compliance, trade desk review and other regulatory audits, investigation of potential regulatory and statutory violations, regulatory databases, enforcement or disciplinary proceedings, reporting to securities regulators, and, information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

With Whom We May Share Your Information
ShareOwner's businesses, affiliates, and subsidiaries, their employees and service suppliers are all governed by strict standards and policies to ensure your information is secure and treated with the utmost care and respect.

At ShareOwner, customer information is strictly confidential. With your consent we will share information with other ShareOwner businesses or suppliers who perform services on our behalf. Unless you authorize us to release it, or release is required or permitted by law, we never sell, lease or trade information about you or your accounts to other parties.

ShareOwner Businesses, Affiliates and Subsidiaries
To ensure you benefit from our full range of products and services and as permitted by law, client information is sometimes shared with other ShareOwner businesses, affiliates and subsidiaries.

If you would prefer not to receive special offers promoting products and services, or that we not share your information, kindly let us know by following the instructions in our 'Opt-Out' policy.

Our Employees
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 or e-mail us, our designated employees will access your information to verify that you are the account-holder and to assist you in fulfilling your financial requests.

As a condition of their employment, all employees of ShareOwner are required to abide by the privacy standards we have established. They are also required to work within the principles of ethical behavior as set out in our internal Employee Manual and must follow all applicable laws and regulations. Employees are informed about the importance of privacy and they are required to sign a confidentiality agreement that prohibits the disclosure of any client information to unauthorized individuals or parties. To reinforce their understanding and commitment to upholding client privacy and confidentiality, employees periodically receive up-to-date literature about our privacy policies, principles and standards.

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

Outside Service Suppliers
At ShareOwner, we sometimes contract outside organizations to perform specialized services such as statement processing, market research or data processing. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you.

When we contract our suppliers to provide specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide.

Our Opt-Out Policy
In order to provide you with a variety of products, services and advice, ShareOwner will with your consent, share your client information with other ShareOwner businesses, affiliates and subsidiaries. Should you not wish to receive promotional materials from, or have your personal and financial information shared with, these Companies, notify ShareOwner by written requests or by calling 1-866-644-6881 (416-595-7200 in the Greater Toronto Area) or faxing (416) 595-0400.


How You Can Protect Your Information
At ShareOwner, we do our utmost to protect and safeguard your personal and financial information. We believe there are measures you should take as well. The following is a list of things you can do to protect yourself against fraud and uninvited intrusion.

Passwords
Passwords are necessary to identify you and authenticate your permission to access your accounts. When you enroll in online services, the passwords you use are encrypted. Encryption is presently the most effective way to achieve data security. Just as it is important for us to employ strict procedures to safeguard your information, you also should take precautions in handling your passwords. When selecting a password, we suggest that you use a combination of letters and numbers and do not use words that can be easily associated with you such as the name of a family member, a pet or the street on which you live. We also suggest that you change your password regularly.

Personal Information
You should not share personal or financial information such as your Client ID, Account Numbers or Social Insurance Number with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

Online Security
To make sure your connection to the protected areas of ShareOwner website are secured, look for either a 'closed lock' or an 'unbroken key' icon located at the bottom right hand side of your browser's task bar. You may also check the address bar to determine if SSL (Secure Socket Layer) is active by looking at the beginning of the address. If it starts with "https" rather than the standard "http", then SSL is operating.

Suspicious Solicitation
From time to time, ShareOwner will engage in promotional campaigns via telephone, mail and e-mail. If you are unsure of the information you receive from us, please call us at 1-866-644-6881 to verify that the campaign is a legitimate ShareOwner activity.

Accessing and Amending Your Information 
At ShareOwner, decisions are often made based on the information we have. Therefore, it is important that your personal and financial information is accurate and complete. As a customer, you have the right to access, verify and amend the information held in your personal and financial files.

Accessing Your Information
You may access and verify any of your account(s) or transactional information whenever you wish. Most of this information is available in the form of transaction records. Account statements (which can be obtained via the ShareOwner website) are generally the best source for this type of information.

If for some reason, you are refused access to factual information held in your file, you may challenge this refusal by contacting our Chief Compliance Officer.

Amending Your Information
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 best 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 and provide you with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.

To Make a Change
To make a change to the personal contact information contained in your file, please call us at 1-866-644-6881.


Making a Complaint to ShareOwner
Should you have any questions or complaints, please let us know. We are committed to answering your questions and resolving any issues that you may have. You may contact us via email at customercare@ShareOwner.com or telephone at 1-866-644-6881 (or 416-595-7200).

For more details, please review ShareOwner's Complaint Resolution Process at www.ShareOwner.com/pdf/complaintresolution.pdf.

 

 


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© 2016 ShareOwner ® is a registered trademark of CSA Computing Inc. Used under license. All rights reserved. Investing products and services are provided by Canadian ShareOwner Investments Inc. a member of the Investment Industry Regulatory Organization of Canada and the Canadian Investor Protection Fund. Canadian ShareOwner Investments provides Order-Execution Only Accounts and does not provide investment advice or recommendations and investors are responsible for their own investment decisions. By accessing this web site you agree to the Terms of Use in the Legal section. CIPF & IIROC Member