1.     Introduction

Equivesto Canada Inc. (“Equivesto”, “we” or “us”) is committed to maintaining the confidentiality of client information, including unauthorized access to that information.

This Policy describes how we collect, hold, use and disclose your personal information when we do business with you. This Privacy Policy is provided in compliance with the Personal Information Protection and Electronic Documents Act (Canada) and, where applicable, similar provincial privacy legislation. Please contact us through one of the means listed at the end of this Privacy Policy if you have any questions.

2.     Chief Privacy Officer

Equivesto’s Chief Compliance Officer is also our Chief Privacy Officer and is responsible for overall privacy governance. All our employees and Dealing Representatives are responsible for maintaining your privacy and are available to address any questions or concerns you may have. 

3.     What is “personal information”?

The personal information collected about you for the purposes of this Privacy Policy is held in our records. Your “personal information” may include:

·       your name, address, telephone number(s), and e-mail address;

·       social insurance number;

·       birth date;

·       employer, occupation, job title, income, assets, net worth and account holdings;

·       financial services providers;

·       marital status and the name, address, social insurance number and occupation/employer of your spouse;

·       name(s), address(es) and social insurance numbers of any beneficiaries.

If you have a corporate account, it may contain information about your interest in the corporation and the interests of other shareholders.

Depending on the investment products or services you request, additional personal information may be held in our records. Personal information does not include the name, title or business address or telephone number of an employee of an organization.

In some cases, we also collect images of documents that contain information about your financial situation.

4.     How we collect personal information

Most of the personal information we collect comes directly from you. We obtain your personal information from the “Know-Your-Client” Form you complete when you open an account with us, subscription agreements you complete, and the books and records maintained by Equivesto based on our discussions with you. We may also collect financial and other information about you from a variety of sources including transactions you have made with or through us, credit reporting agencies and other financial institutions.

When you open an account or purchase a security, we will ask you to provide only the information that enables us to complete the transaction, provide services required to operate your account and complete transactions, or offer you products and services we believe you might be interested in.

5.     Cookies

A cookie is a small text sent by a server to your browser, which it will send back the next time it connects to servers sharing the same domain name.

If you wish, you can set your browser to notify you when you receive cookies or to refuse them. You do not need to accept non-essential cookies to visit our website. However, if you refuse them, you could be unable to use some of its features.

Types of cookies

Technical cookies: Technical cookies are used throughout the browsing experience to facilitate the use of the Website. For example: a technical cookie may be used to remember your username to facilitate your login, to remember your preferences or options you have chosen.

Analytical cookies: These cookies are anonymous and are used to collect statistics on the use of the website.

Advertising cookies: These cookies may be added by the Website or by other sites serving advertisements. These cookies collect information anonymously and build up your visitor profile. Equivesto does not use advertising cookies but does allow issuers wishing to collect information about their subscribers to add them to their offering pages to track the traffic.

6.     Why we collect personal information

We collect, use and disclose personal information to enable us to provide you with the products and services that will help you to meet your financial goals, communicate effectively with you, and provide you with suitable services and products. Specifically, we collect, use and disclose your personal information to:

·       verify your identity as required under Federal anti-money laundering regulations and Provincial securities regulations;

·       determine your eligibility for Equivesto products and services;

·       analyze the suitability of our products or services for you;

·       manage our risks and operations;

·       provide you with ongoing services;

·       establish and maintain communications with you and respond to your inquiries;

·       communicate with you and send you information in connection with ongoing investment opportunities;

·       determine fees and expenses;

·       investigate and settle complaints;

·       detect and prevent fraud;

·       compile statistics and conduct market research;

·       report to regulatory agencies;

·       investigate specific transactions or patterns of transactions to detect unauthorized or illegal activities;

·       comply with our legal and regulatory requirements;

·       provide tax-related information to the appropriate government agencies;

We will refer to these below as the “Identified Purposes.”

Ppersonal information may be collected, used or disclosed for any of these purposes. However, we do not collect your personal information if it is not needed for one of these purposes, without obtaining additional consent from you.

7.     Disclosure to third parties

If you provide personal information to us or through any of the above sources, you do so with the understanding that your personal information may be disclosed for the Identified Purposes amongst us, the above sources, or third-parties, and that Equivesto may verify such information or obtain additional personal information about you by checking with government agencies, credit bureaus, and other fact collecting and verifying entities, to assist us for the Identified Purposes. 

Equivesto is responsible for your personal information in its possession or custody, including personal information that has been transferred to, or received from, a third-party in the course of commercial activities for processing or other purposes for which you have consented. We will not disclose information about you to third parties other than for the Identified Purposes or as required by law.

8.     Consent

Your knowledge and consent are required before we may collect, use or disclose your personal information, except in special circumstances, such as during a fraud investigation, an investigation by the police, or in situations otherwise permitted by the law. 

We accept any of the following as your consent for Equivesto’s existing use and future collection, use and disclosure of your personal information for the Identified Purposes: 

·       your receipt of this Privacy Policy, unless you advise Equivesto, either orally or in writing, that you do not agree with the terms stated in this Privacy Policy, and that you wish to opt out of all or portions of it;

·       your unrestricted provision of information to Equivesto;

·       your express written or oral consent as obtained through the completion of the “Know-Your-Client” Form; or

·       your consent as provided by your authorized representative, such as a legal guardian or power of attorney.

In some circumstances, your consent may be implied. For instance: 

·       if you obtain products and/or services for your family or anyone else, you represent that you have obtained consent from them to the collection, use and disclosure of their personal information for the Identified Purposes, even though they might not be present during the application process;

·       If you have existing products and services with us and you request amendments to them, it is assumed that the consent which you gave to us when buying the original products and services remains in effect.

You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive. 

 If you wish to withdraw your consent to this information sharing or discuss the implications of such a withdrawal, please contact our Chief Privacy Officer at the address or telephone number listed below. Unless we hear otherwise from you, you are giving us your consent for the collection, use and disclosure of personal information as provided in this Privacy Policy for the Identified Purposes. 

9.     How long do we keep your personal information?

Your personal information is retained only so long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. Equivesto uses care when storing or destroying your personal information to prevent unauthorized access. 

Canadian securities regulations require that we maintain information about you and your transactions for seven years from the closing of your account or the date of the transaction. If you do not maintain an ongoing relationship with Equivesto following a transaction, we consider the date of closing of your account to be the date of the transaction. 

Once provided by you, we are unable under securities regulations to delete your personal information until after the period established by regulation. 

10.  How do we protect your personal information? 

Whether in electronic or paper-based format, Equivesto maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. When we no longer need your personal information, we take as much care to destroy it as we do when storing it.

Equivesto may transfer your personal information for the Identified Purposes to our services providers, such as account statement preparation and mailing companies, courier companies, imaging companies, and document storage companies. When Equivesto transfers personal information to our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. We may use service providers located outside of Canada, and where we do, personal information may be disclosed in accordance with the laws of the jurisdiction in which the service provider is located, including to the government in that jurisdiction and its agencies. 

11.  Your right to access your personal information 

You have a right to access your personal information that we have in possession or control. You also have a right to know which third parties have received your information from Equivesto.

In order to access your personal information, please make your request in writing to Equivesto’s Chief Privacy Officer, stating as specifically as possible which personal information you are requesting. We try to respond to such requests as soon as possible, and will advise you if, for some reason, we cannot respond right away. Equivesto may charge you a reasonable fee for providing access to your personal information, not only after first advising you of the approximate cost. 

In providing you with a list of the organizations to whom we have disclosed any of your information, we will try to be as precise as possible. If it is not possible to provide an exact list of such organizations, Equivesto will provide a list of organizations to which we may have disclosed the information. 

Equivesto has the right to refuse your request for access to personal information if:

·       the information is protected by solicitor-client privilege;

·       granting access would reveal confidential commercial information;

·       doing so would reasonably be expected to threaten the life or security of another individual;

·       the information was collected for purposes related to the detection and prevention of fraud;

·       the information was generated in the course of a formal dispute resolution process; or

·       the information would likely reveal personal information about another individual.

12.  Keeping your information accurate

Equivesto strives to ensure that the personal information we have on file for you is as accurate and up to date as necessary for the Identified Purposes. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. Equivesto will amend personal information that is materially inaccurate or incomplete and, where appropriate, endeavor to advise other parties having access to the information in question. 

13.  Your Rights

You have the following rights:

·       the right to change or withdraw your consent to the collection, use and disclosure of your Personal Information;

·       the right to have access to your personal information.

·       the right to have your personal information corrected if it is inaccurate or misleading and to have it completed if it is incomplete;

·       in certain cases, the right to obtain your personal information in a commonly used digital form;

·       the right to be informed of a confidentiality incident involving your personal information that may cause you serious injury including financial harm;

·       the right to file a complaint with the Office of the Privacy Commissioner of Canada, the Commission d’accès à l’information for Quebec clients or another provincial regulatory agency. Please note that it is possible that these agencies will require to exhaust any remedies directly with Equivesto before making a complaint.

You may exercise these rights, at any time by sending written notice to the Privacy Officer whose contact information can be found at the end of this document. We may require a verification of identity before processing your request.

We will respond to any request within 30 days of receipt, except where the law permits an extension of that period. If we refuse to provide or correct the information, we will provide you with the reasons for the refusal, the applicable sections of the law, and information about your other remedies, all subject to the limitations of the law.

If we refuse to correct your personal information, we will allow you to place comments in your file in respect of the personal information for which collection has been refused. We will also retain the personal information that has been the subject of an access request for as long as necessary to allow you to exhaust any recourse provided by law.

14.  How to contact us 

If you have a complaint related to the Privacy Policy or any of our procedures, contact our Chief Privacy Officer. If your complaint is justified, we will take the steps necessary to resolve the issue, including amending our Privacy Policy and practices, if necessary. 

If we are unable to resolve your concern, or if you have any other concerns about Equivesto’s Privacy Policy and related procedures, you may contact the Office of the Privacy Commissioner of Canada or, if applicable, the provincial privacy commissioner. Equivesto’s Chief Privacy Officer will provide you with this contact information upon request.

For more information, to file a complaint, to make inquiries, or to opt out of all or parts of this Policy, please contact Equivesto’s Chief Privacy Officer: 

Equivesto Canada Inc.

Telephone: 647-204-7076 

E-mail: compliance@equivesto.com

Website: www.equivesto.com

15.  Changes to this policy

Equivessto reserves the right to change the content of this Policy at any time. Any changes will be posted on our Website and brought to your attention when you log in. We recommend that you print a copy of this Policy for your records and review this section of our Website periodically