PRIVACY POLICY

Alitis Investment Counsel Inc. and Alitis Wealth Planning Inc. have created a joint privacy policy that is applies to both firms and as such, you will see references to types of personal information (e.g. health information) that would not normally be required by a Portfolio Manager or Investment Fund Manager. With respect to this Privacy Policy, the term “Alitis” shall refer to both Alitis Investment Counsel Inc. and Alitis Wealth Planning Inc.

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Alitis is committed to protecting your privacy and maintaining the confidentiality of your personal, business and financial information. This commitment is fundamental to the way we do business and is reflected in our privacy policies.

Alitis is responsible for the personal information of its clients that it collects or that is under its control. Alitis has appointed a Privacy Officer who is responsible for overall privacy governance. The Privacy Officer may be contacted at the address set out at the end of this Privacy Policy.

What is personal information?

Personal information means any information about an identifiable individual, including information such as your home address, phone number, date of birth, age, marital status, religious affiliation, employment history, social insurance number and credit history.

What personal information do we collect?

Alitis collects your personal information for the purpose of establishing and servicing your account(s). The majority of your personal information is collected directly from you at the time your account is opened at Alitis. Alitis shall only collect the personal information of its clients that is necessary for the purposes that have been previously identified to the client.

Information essential for fulfilling most financial requests and applications includes:

Information establishing your identity, such as your name, address, phone number, occupation, title, business phone number, email address, date of birth, social insurance number, citizenship, country of residence and account numbers. Alitis is required by law to verify your identity for purposes relating to the prevention of money laundering.
Information related to transactions arising from your relationship with and through us, and from other financial institutions.
Information you provide on an application for the provision of our products and services, such as your annual income, net worth, place of employment, marital status, number of dependents, investments, account balance, financial liabilities, transaction history, and banking information. Alitis is required by law to record your banking information for purposes relating to the prevention of money laundering.
Information about financial behaviour such as your payment history and credit worthiness. In the event that your credit history is obtained, Alitis may collect personal information directly from a credit reporting agency.
Information about your health may be collected for insurance products and services.
Information pertaining to business clients will include your business name, business number, address, phone number, email address, industry type, financial status and detail(s) on the owner(s), operator(s) and director(s).
Additional information may be requested to help us determine your eligibility for products and services that we offer.
Other information may occasionally be collected from a third party or relating to a third party, such as information from the executor of an estate or the name and address of your beneficiary.

Providing us with your information is always your choice. However, in dealings involving insurance and related financial services, your decision to withhold particular details may limit or prevent us from providing the products or services you have asked for. It may also make it difficult or impossible for us to advise you or suggest appropriate alternatives.

How do we use your personal information?

We use your personal and financial information for the purposes communicated to you in your agreement(s) with us, for example to:

Verify your identity.
Understand your financial situation and determine the suitability of products and services we offer.
Provide you with the financial products and services requested.
Execute your transactions.
Establish and administer your account(s), which involves determining, maintaining, recording, and storing account holdings and transaction information in your client record.
Provide you with account statements, financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account(s).
Communicate to you any benefit, feature and other information about products and services you have with us.
Ensuring the information in our records is accurate.
Verifying previously given information when necessary.
Respond to any special needs or inquiries you may have.
Manage our risks and operations.
Meet our regulatory and legal requirements.

Alitis will not sell your personal information. Sensitive information such as health records will never, under any circumstances, be shared or used for a purpose other than that of the original intent. We may use your information internally for general research in an effort to enhance our service and product offerings. We may communicate with you through various channels including telephone, computer or mail using the contact information you have provided. With your consent, we may use your information to promote our products and services and that of third parties we select, which we believe will be of interest to you.
If for any reason your information is required to fulfill a different purpose than that of your original intent, we will ask for your consent before we proceed.

Who is your personal information shared with?

Under certain circumstances, your personal information may be shared among Alitis companies, employees, outside service providers, other third parties, or another firm due to corporate re-organization.

Alitis companies

Sharing your personal and financial information among Alitis companies, will allow us to help you achieve your financial goals. It’s part of building and maintaining a positive relationship with you. We may use this information to better understand your financial needs and to promote products and services we believe may interest you. This would only be done with your consent. However, if you would prefer that we not share your information among our group of companies or if you do not wish to receive information promoting products and services, kindly let us know by following the instructions outlined at the end of this Privacy Policy.

Our employees

All employees of Alitis are bound under the policies and procedures of Alitis to maintain the confidentiality of your personal information and are available to address any questions or concerns you may have. Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. Unauthorized access to and/or disclosure of client information by an employee of Alitis is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times.

Outside service providers

Alitis uses third-party service providers to perform services on our behalf such as custody of client accounts, unitholder recordkeeping, email and electronic document storage. Our service providers may at times be responsible for processing or handling personal information and are provided only the information necessary to perform the services.

At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require the transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third-party’s jurisdiction, including laws with respect to disclosure of such information.

Alitis ensures that all third-party service providers have a comparable level of protection for your personal information, and that the use of the personal information is limited to purposes set out in this policy.

Other third parties

We will only share your information with other third parties as indicated under your account agreement and under the following special circumstances:

As required under the rules and regulations of any regulator of Alitis or self-regulatory authority of which Alitis is a member.
Other financial institutions and securities dealers when necessary to carry out your instructions, such as transferring funds.
To respond to valid and authorized information requests from domestic and international authorities.
As permitted or required by law, to comply with laws, regulations, subpoena or court order.
To help prevent fraud.
To identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) Alitis’ rights or property or anyone else that could be harmed by such activities.
To protect the personal safety of employees, clients or other third parties on Alitis property.

Another firm due to corporate re-organization

We may also disclose your information in connection with:

A corporate re-organization of Alitis in which case the information would only be shared with employees of the organization who have a strict need to know the information to evaluate the re-organization.
A potential merger or amalgamation between Alitis and another third party or a sale of all or a substantial portion of our assets to enable that third party to evaluate the transaction and, in that case, the information would only be shared with members of that organization who have a strict need to know the information to evaluate the transaction.
An actual merger, amalgamation or sale of all or a substantial portion of Alitis’ assets where you would then become a client of a different organization

In all cases above, Alitis will only disclose the information if the third party has agreed to protect the information at least as well as we do under our Privacy Policy, only share it with members of their organization who have a strict need to know the information, and use it only for the purpose of the transaction and for no other purpose.

How do we keep your personal information safe?

Alitis is committed to protecting the personal information of its clients and has implemented the necessary security safeguards that are appropriate to protect the sensitivity of such information. This commitment extends to our online services and any new technologies we employ.

The majority of your personal information is contained on your account documentation. Most account documentation is maintained at Alitis’ head office or branch offices and is safeguarded by using a number of protective methods such as using locked, fire-resistant filing cabinets and restricting access to certain designated areas where your account documentation is stored. Alitis also stores account documentation offsite in a secure location.

Digital copies of your account documentation, along with other documents containing personal information, may be stored on employees’ computers, Alitis’ servers, or on cloud-based servers. Privacy, security and confidentiality are as important online as with all our other business functionality. Alitis has implemented industry standard methods of protecting your personal information that is available electronically or online from unauthorized access, disclosure, copying, use or modification. This includes the use of firewalls, encrypted passwords, anti-virus software, intrusion detection systems, file encryption, authentication and other appropriate means to protect your personal information.

Alitis may from time to time use cookies on its website to improve functionality and in some cases, to provide clients with customized access to our website. Cookies are not used to collect personal information that may reside on your personal computer and are not used to track the websites that you visited before or after you leave the Alitis site.

How long do we keep your personal information?

In order to service your account and to meet regulatory and legal obligations, Alitis may be required to maintain information related to you and your account for a certain period of time. Personal information may be destroyed in a safe and secure manner once it is deemed that the information is no longer necessary for the above-mentioned purposes. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us 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.

How do we keep your personal information accurate?

Alitis is committed to keeping the personal information of its clients accurate, complete and up-to-date at all times. In order to maintain the accuracy and completeness of your personal information, you will need to update your account documentation from time to time. If your personal information changes, please notify us so we can update our records.

How can you access your personal information?

Alitis is committed to providing its clients with information relating to the existence, use and disclosure of their personal information and clients shall be given access to such information where appropriate. You can request access to your personal information by contacting the Privacy Officer in writing at the address indicated at the end of this Privacy Policy. A request to access your personal information will only be accepted if received directly from you; requests received from, received via, or directed by other persons, companies, or organizations will not be accepted.

Alitis may not be able to provide you with full access to your information if it contains references to other persons, if it would have to disclose proprietary information confidential to Alitis or its affiliates, if it has been destroyed, or if it cannot be disclosed for legal or regulatory reasons. If we are unable to provide you with access to your personal information, we will give you an explanation.

Alitis may charge a minimal fee to process requests for personal information. An estimate of the fee will be provided to you before any work is undertaken. As well, a deposit may be required from you before any work is undertaken. Personal information collected by a request to access will only be delivered to you; your personal information will not be delivered to other persons, companies, or organizations.

How do we obtain your consent?

Alitis shall only collect, use or disclose client information with your knowledge and consent except where inappropriate or as otherwise required or permitted by law. By completing our account forms, you are consenting to the collection, use, and disclosure of your personal information for the purposes set out in this Privacy Policy.

How can you withdraw your consent?

You have the right to withdraw your consent to the use of your personal information that is not required for the purpose of establishing and servicing your account(s) and to fulfill our legal, regulatory and self-regulatory obligations in Canada and in some cases, abroad, or as otherwise permitted by law.
If you do not want Alitis to provide you with information relating to products and services that are available through other Alitis companies or other information which may be of interest to you or share your personal information with other Alitis companies so that they can provide you with such information directly, please notify Alitis of your decision in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Policy. Requests to withdraw consent will only be accepted if received directly from you; requests to withdraw consent received from, received via, or directed by other persons, companies, or organizations will not be accepted.

Please be advised that the withdrawal of your consent is not a condition of doing business with Alitis and you are free to withdraw your consent at any time.

Further Consent May Be Required

In the event that Alitis would like to use your personal information in a manner that has not been previously identified, Alitis will notify you in advance and obtain your consent unless otherwise required or permitted by law.

How can I make an inquiry or complaint?

If you have a privacy inquiry or complaint, please direct it in writing to the attention of the Privacy Officer at the address noted below. Telephone calls, faxes, and emails will not be accepted. Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint. Inquiries and complaints will only be accepted if received directly from you; inquiries and complaints received from, received via, or directed by other persons, companies, or organizations will not be accepted. In most instances, the Privacy Officer will investigate and reply to inquiries within 30 days. If the Privacy Officer is unable to respond to your inquiry within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response.

The Privacy Officer can be reached in writing at the following address:

101 – 909 Island Highway
Campbell River, B.C.
V9W 2C2