OVERVIEW

Robert Evans Investment Counsel Limited (REIC) is dedicated to safeguarding your privacy and maintaining confidentiality of your personal information. This Privacy Policy (the policy) is fundamental to the way we do business with you, our client.

This document complies with the requirements of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and any applicable provincial/territorial legislation.

This policy will be reviewed annually and updated on a regular basis.

PERSONAL INFORMATION

Personal information means any information that specifically identifies you as an individual, such as your home address, telephone numbers, social insurance number, birth date, assets and/or income information, employment history and credit history

The policy does not encompass personal information about you that may be accessed in the public domain, for example, your business address that can be found in public documents such as telephone or professional directories.

COLLECTION OF PERSONAL INFORMATION

Personal information is gathered directly from you with your consent in order to:

• understand your investment needs and provide you with related products and services;
• meet legal and regulatory requirements; and
• maintain ongoing two-way communication (newsletters, invitations, etc.).

Personal information is collected from various sources such as:

• applications, agreements, contracts and forms submitted by you to REIC;
• your transactions with REIC; and
• your meetings, e-mail and telephone communications with REIC.

The following personal information may be collected:

• name, address and telephone number;
• email address;
• date of birth and social insurance number;
• employment information;
• personal financial and income information;
• proof of citizenship;
• marital status; and/or
• spousal personal information such as the above.

DISCLOSURE OF PERSONAL INFORMATION

We may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the services we provide related to you; however they will not share this information with others. Such information is only used for the purposes identified above. REIC will use contractual or other means to provide a comparable level of protection while the information is being handled by a third party service provider or agent. The following is a list of such third party providers and agents:

• REIC’s custodian (i.e. National Bank Independent Network) and your custodian, if applicable;
• service providers such as accounting, legal or tax services, as requested by you; and
• government regulatory authorities (i.e. Ontario Securities Commission).

CAN YOU WITHDRAW YOUR CONSENT?

The choice to provide REIC with personal information is always yours. However the decision not to provide personal information may limit the products and services we are able to offer. If REIC is unable to accommodate your request based on the personal information provided, we may ask for additional details in order to identify other alternatives.

SAFEGUARD OF PERSONAL INFORMATION

Electronic client files are kept on a highly secured network with restricted access. The network resides at 150 King Street West, Suite 801, Toronto, ON, M5H 1J9. Other safeguards utilized by REIC include multi-level network security, virus protection and regular secure backup of all relevant electronic data.

We also utilize a portfolio management system that is hosted offsite on a highly secured sever, which is backed by PEER 1 Network Enterprises, Inc. The server is located within a secure building that is a dedicated hosting facility. Only a limited number of authorized users have access to the physical server. Any and all measures are taken to protect the data that is stored on this server.

Paper-based documents are stored in secured areas within the office and may be held at a restricted offsite facility.

Personal information collected from you will only be used for the identified purposes and will be retained for as long as is necessary to fulfill the service or as required by law. We regard confidentiality and privacy as a foundation of our business. Employees of REIC are required to acknowledge and sign the Code of Conduct Policy annually. Unauthorized access to and/or disclosure of clients’ personal information by an employee is strictly prohibited. All employees are expected to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include suspension or dismissal

UPDATING PERSONAL INFORMATION

You may verify the accuracy and completeness of your personal information, and you may request that it be amended as required. Should you identify any incorrect or out-of-date personal information, we will make the appropriate change in accordance with your instructions. Where appropriate, including where required by law, we will communicate these changes to other parties who may have incorrect information about you.

REIC may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons or it has been destroyed. REIC will provide you with a valid explanation if we are unable to fulfill your access request.

QUESTIONS/CONCERNS CONTACT

Upon request, REIC will provide you with access to your personal information. You may also withdraw your consent for the use of your personal information by contacting REIC at any time subject to reasonable notice. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.

You may direct any questions or inquiries you have with respect to the policy or about the way we manage your personal information by contacting us at:

For more general inquiries, contact the Information and Privacy Commissioner of Canada (IPC). IPC oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. Information and the Privacy Commissioner can be reached at: