Howson Tattersall Investment Counsel

COMMITMENT TO PRIVACY

Safeguarding your confidentiality and protecting your personal information is fundamental to the way we do business with you. This Privacy Policy (the “Policy”) describes our current information management practices and confirms our commitment to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and any applicable provincial/territorial legislation, in order to meet your specific needs and expectations as one of our clients.

This Policy applies to the Saxon Financial Group¹. The Policy applies to all personal information that has been and will be collected, used and disclosed by the Saxon Financial Group.

“Personal information” is information that refers to you specifically and that reveals a
distinctive trait or traits about you that may help others identify you, for example your date of birth or social insurance number. This 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.

The purposes for which your personal information is collected shall be identified before or at the time you provide us with such information. The personal information we collect about you must be obtained by fair and lawful means and is limited to personal information that is necessary for the purposes identified.

We gather and use personal information to provide you with the products and
services you request. Providing us with your personal information is always your choice. Most of the information we collect is provided to us directly from you, and only with your consent. When you request products and services we will ask you to provide the personal information that enables us to complete your request or to provide you with better service.

The personal information we may ask you to provide depends on the nature of your
request. Personal information that is essential for us to fulfill your financial
product and service requests typically includes your full name, residential mailing address, e-mail address, phone number(s), financial information, and Social Insurance Number. Some of the information we will ask for is required to satisfy regulatory bodies. For example, the securities regulators require the Saxon Financial Group to obtain comprehensive “Know Your Client” information.

We may also request additional personal information to help us provide you with financial advice and information about other products and services that we believe would interest you. Knowing more about you, your family, and such information as the assets you hold elsewhere, your financial goals, retirement plans, tax situation, trusts, will and estate plans, ensures that we thoroughly understand your goals and objectives. Having this information also enables us to recommend product and service solutions that can help you realize your goals and manage your financial affairs more effectively.

To help us better understand our clients, we may also gather information for analytical purposes by conducting anonymous client surveys and by extracting demographic information from existing files.

We only collect the information we need and we only use it for the purposes disclosed to you.

The choice to provide us with your personal information is always yours. However, your decision not to provide the personal information we request may limit the services we are able to provide you and make it more difficult for us to advise you or suggest appropriate alternatives. If we are unable to accommodate your request based on the personal information you provide, we may ask for additional details in order to identify other ways to be of assistance. In certain circumstances, where personal information is not provided, this may prevent us from fulfilling our commitment to you and, in certain circumstances, it may not be possible for us to continue our client relationship with you..

We only use personal information for the purposes that we have disclosed to you.

We use your personal information to process account applications, communicate with you and effectively provide the products and services you request.

We will keep you informed about your investment account activities, authenticate your identity, send you important notices, and respond to any special needs or inquiries you may have.

To better serve you, your information may be shared among the companies that comprise the Saxon Financial Group. This will help us to serve you better and determine whether any products or services of the Saxon Financial Group are suitable for you so that we can offer them to you. This consent is optional and you can decide to withdraw it at any time. Please refer to Our “Opt-Out” Policy section.

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

Your personal information may only be used or disclosed for the purpose for which it was collected, unless you have otherwise consented, or when it is required or permitted by law.

We do not sell, lease or trade client lists or personal information to others. However, we may release your personal information to parties outside the Saxon Financial Group in certain circumstances, which include:

Your personal information will be protected by security safeguards that are appropriate to the sensitivity level of the information.

We maintain current security standards as described in our Online Privacy Policy to ensure that your personal information is protected against unauthorized access, disclosure, inappropriate alteration or misuse.

Electronic client files are kept in a highly secured environment with restricted access. Access to paper-based files stored in locked file rooms and cabinets is also highly restricted.

All employees, contractors, directors and officers must abide by this Policy which forms part of our Code of Conduct. Each employee is required to annually state that they continue to be aware of our Code of Conduct and will continue to abide by it. 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 dismissal.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain the information varies depending on the product or service and the nature of the personal information.

For more information about online privacy please view our Online Privacy Policy on the saxonfinancial.ca web site (http://www.saxonfinancial.ca/).

We will make your personal information available to you and provide you with a description of our policies and practices that apply to the management of your personal information.

As a client, you have the right to access and verify any of your personal information whenever you wish. Most of this information is available in the form of transaction records. Account statements are generally the best source for this type of information. If you require other information see the ADDRESSING YOUR CONCERNS section of this Policy for a list of contacts.

We will advise you in advance if a nominal charge will be required for conducting the research and we will respond to your request within thirty days.

If we are unable to provide access to certain information, we will inform you of the reasons for the decision if we are permitted to do so by law. If you wish further clarification, you may contact our Chief Privacy Officer.

Your personal information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

You may verify the accuracy and completeness of your personal information, and you may request that it be amended. To help us keep your personal information up-to-date, we encourage you to amend inaccuracies and make corrections as often as you like. 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. We are only able to update an individual’s personal information where we are in direct contact with that person. Therefore, we cannot amend personal information of family members or others unless they contact us directly.

You may make a change to the personal information we maintain about you by
contacting:

If we are unable to change your personal information, or you disagree with our decision, we will note this inability or your disagreement in your account file

You can choose whether we can collect, use or disclose your personal information, except where required or permitted by law

In most cases you may refuse or withdraw your consent at any time. Please refer to the ADDRESSING YOUR CONCERNS section of this Policy for a list of contacts. We will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your choices.

Should you choose not to permit us to share your personal information among the Saxon Financial Group this may prevent us from fulfilling our commitment to you and, in certain circumstances, it may not be possible for us to continue our client relationship with you.

You have the right to be informed of the collection, use and disclosure of your personal information, and you shall be given access to that information.

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


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