CAMBRIDGE CONSULTANTS PRIVACY POLICY

1.0 GENERAL

1.1 Protecting your privacy and maintaining the confidentiality of your personal information is integral to the way we do business.

2.0 OUR TEN PRIVACY PRINCIPLES

2.1 Our ten privacy principles comply with the provisions of Canada’s Personal Information Protection and Electronic Documents Act. These principles are as follows:

Principle 1: Accountability. We are responsible for and will endeavour to maintain and protect the information we have about you.

Principle 2: Identifying Purposes. The purpose for which your information is being collected will be explained to you either before or when it is collected.

Principle 3: Consent. We will obtain your consent to collect, hold, use and disclose your information. This will be done by providing you with a New Account agreement and by your completing an Account Disclosure Document and/or Group Insurance Enrolment Card when you open an account or enrol with us or by providing it to you in a separate communication.

Principle 4: Limiting Collection. We will limit the information we collect to what is needed for those purposes. (See section 3)

Principle 5: Limiting Use, Disclosure and Retention. We will use and disclose your information only for the purposes we have identified, or when it is required or permitted by law. We retain your information only for as long as is necessary for the fulfillment of these purposes.

Principle 6: Accuracy. We keep your information as accurate, complete and up to date as is necessary for these purposes.

Principle 7: Safeguards. We protect your information with appropriate safeguards and security measures.


Principle 8: Openness. Upon your request, we will provide you with specific details about our information handling policies and procedures.

Principle 9: Access. We will give you access to the information we have about you. You may check the accuracy of your information and amend it as appropriate.

Principle 10: Challenging Our Compliance. We will investigate and respond to your concerns about any aspect of our handling of your information.

3.0 COLLECTION OF INFORMATION

3.1 How do we collect information?

The information collected about you is retained in the “client record”. You provided most of this information when you completed a product or service application form, mutual fund application, GIC application, or opened an account with us.

3.2 What information do we collect?

The personal information in your client record may include your name, address, and telephone number, social insurance number, birth date, account holdings, health information, and information regarding your dependents as well as the name, address and social insurance number of your spouse and beneficiary.

Depending on the investment or service you request, additional personal information may be held in your client record.

3.3 How do we use your information?

We may use your information for the following identified purposes:

• Identifying you
• Ensuring the accuracy of information in your client record
• Establishing and administering your account
• To recommend suitable products
• Determining, maintaining, recording and storing account holdings and transaction information in you client record
• Executing transactions
• Providing you with account statements
• Meeting legal and regulatory requirements
• Verifying information you have previously given with another organization when necessary for the identified purposes

3.4 Who else do we collect information from?

There are times when we may collect information about you from a third party. This information is only used for the identified purposes mentioned in section 3.3.
The parties include:

• Financial institutions, mutual fund companies, life insurance companies
• Product suppliers
• Third parties who represent that they have a legal right to disclose the information (for example the executor of an estate)

4.0 DISCLOSURE OF INFORMATION

4.1 Who do we disclose your information to?

There are times when we may disclose your information to others. These agents, suppliers and organizations include:

• Financial institutions, mutual fund companies, life insurance companies
• Product suppliers
• Canadian governments and government agencies
• Canada Post

4.2 Disclosing your information when required or permitted by law

Cambridge Consultants must provide information in response to a valid demand, search warrant or other legally valid enquiry or order. We may disclose information to an investigative body in the case of a breach of an agreement or contravention of laws. We may also disclose information to help us collect a debt owed by you.

5.0 CONSENT

5.1 How do we obtain consent?

We provide you with a New Account Agreement/Account Disclosure Document at the time you complete a product or service application form or otherwise establish an account with us. The New Account Agreement/ Account Disclosure Document may also be sent to you in a separate communication. The new Account Agreement/Account Disclosure Document explains how we collect, hold, use and disclose your information. By signing an application form and/or continuing to do business with us, you are consenting to the use of your information.

5.2 How can you withdraw all or part of your consent?

You can withdraw your consent for use of your information by contacting us.
In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold information may also limit the products or services we are able to provide to you.

6.0 YOUR RIGHTS

6.1 Your rights to access your information

Except in limited circumstances, we can provide you with the information we have about you so you may verify and amend it. Please note that we may not be able to provide you with information in the following circumstances:

• If it contains references to other persons and the references are subject to legal privilege
• If it relates to an investigation of a breach of agreement or contravention of laws
• If it cannot be disclosed for other legal reasons

7.0 KEEPING YOUR INFORMATION

7.1 Keeping your information accurate

Accuracy is essential to providing you with excellent service. Please inform us of any errors in our information about you as soon as you are aware of them so that we may immediately correct your client record. If the accuracy of information is in dispute, we will note it in your client record.

7.2 Where do we keep your information?

Your client record is kept in electronic or paper format at the office of Cambridge Consultants in Winnipeg.

7.3 How do we protect your information against loss and unauthorized access?

Our employees and service providers have access to your information provided the information is required for the identified purposes and access is permitted only to the extent necessary for such purposes.

In addition, we take measures to protect your information, such as restricting physical access to our offices and using computer passwords and file encryption for on-line activities.

7.4 How long do we keep your information?

We retain your information only as long as it is required for the reasons it was collected. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issues that
may arise at a later date.

8.0 RESOLVING YOUR CONCERNS

8.1 If you have any questions, concerns or complaints about the treatment of your information please follow these steps:

STEP 1: In most cases, a concern can be resolved by discussing it with your financial advisor/investment representative.

STEP 2: If after contacting our Privacy Compliance Officer your concerns remain unresolved, you may contact the Privacy Commissioner of Canada:

The Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3
Telephone: (613) 995-8210 or 1-800-282-1376