Privacy Policy

Safeguarding your confidentiality and protecting your personal and financial information is fundamental to the way we do business with you. This Privacy Policy describes our current information management practices and confirms our commitment to comply with the Federal Government's Personal Information Protection and Electronic Documents Act ("PIPEDA") in order to meet your specific needs and expectations as one of our clients.

Our Ten Privacy Principles

We remain committed to maintaining the accuracy, confidentiality, and security of your personal and financial information that you entrust to us. As part of our commitment, we adopted the Ten Privacy Principles of the Canadian Standards Association's Model Code for the Protection of Personal Information to govern our actions as they relate to your personal information. A brief description of these 10 principles follows.

Principle 1 - Accountability

Each Company within the CMA Holdings Group is responsible for maintaining and protecting your personal information under its control. In fulfilling this mandate, the organization has appointed a Chief Privacy Officer accountable for our compliance with PIPEDA and the Ten Privacy Principles.

Principle 2 - Identifying Purposes

The purposes for which your personal information is collected shall be identified before or at the time you provide us with such information.

Principle 3 - Consent

Your knowledge and prior consent is required before we can collect, use or disclose your personal information, except where required or permitted by law.

Principle 4 - Limiting Collection

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 by the respective Company within the CMA Holdings Group.

Principle 5 - Limiting Use, Disclosure and Retention

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. Your personal information may only be retained for the period of time required to fulfil the purpose for which it was collected.

Principle 6 - Accuracy

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.

Principle 7 - Safeguarding Client Information

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

Principle 8 - Openness

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.

Principle 9 - Client Access

You have the right to be informed of the existence, use and disclosure of your personal information, and you shall be given access to that information. You may verify the accuracy and completeness of your personal information, and you may request that it be amended, as required.

Principle 10 - Handling Client Complaints and Suggestions

You may direct any questions or enquires you have with respect to the privacy principles outlined above or about the way we manage your personal and financial information by contacting the organization's Chief Privacy Officer, 1870 Alta Vista Dr., Ottawa, ON, K1G 6R7.

What personal information do we collect?

We gather and use personal information to provide you with the financial products and services you request and, as appropriate, to ensure you are aware of additional products and services we offer, which we believe might interest you.

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 or enroll for a service online, 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 we believe is essential for us to fulfill your financial product and service requests typically includes your full name, mailing address, e-mail address, phone number(s), account number(s), and Social Insurance Number. In the case of insurance products and services, we may also request health information about you, where the law permits. We may also request additional personal information to help us provide you with financial-related advice and information about other products and services that we believe would interest you.

When you visit our Website, we do not collect information that could identify you personally, unless you choose to provide it voluntarily. You are welcome to browse our Website at any time anonymously and privately without revealing any personal or financial information about yourself.

Types of Personal Information We Collect

We collect two types of personal information from you:

• with your prior consent, we collect personal information, described below, and
• we may also collect anonymous/non-personal information, most particularly on our Website.

What is personal information?

Personal information is information that refers to you specifically that reveals a distinctive trait or traits about you that may help others identify you. It does not encompass personal information about you that may be accessed in the public domain, such as your business address that can be found in public documents such as telephone or professional directories. With your prior consent, we may gather personal information from you in person, at one of our branch offices across the country, over the telephone or by corresponding with you via mail or the Internet.

The type of personal information we usually collect and maintain may include some or all of the following:

• Legal name
• Family members' name;

• Mailing address
• E-mail address
• Social Insurance Number
• Date of birth
• Telephone number(s)
• Place of employment
• investment account transaction history
• Annual income
• Health information

The choice to provide us with your personal and financial 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 essential personal information is not provided, it may not be possible for us to continue our client relationship with you.

Your Future Financial Services Needs

As your financial and related needs grow, you may wish to avail yourself of other products and services offered by the CMA Holdings Group of Companies. For example, you may with to purchase insurance, trust services or require investment advice. To provide you with such products and services, we may need to obtain more detailed financial and personal information from you. Some of the information we will ask for is required to satisfy securities regulations. For example, the securities regulators require MD Management obtain comprehensive "Know Your Client" information.

Knowing more about you, your family, the assets you hold elsewhere, your financial goals, retirement plans, tax situation, trusts, Will and estate plans, etc., ensures that we thoroughly understand your financial goals and objectives. It also helps us identify your financial needs and enables us to recommend product and service solutions that can help you realize your goals and manage your financial affairs more effectively.

What is anonymous / non-personal information?

Anonymous / non-personal information is information that cannot be associated with or traced back to a specific individual or business entity. For example, our Web servers collect some anonymous / non-personal information automatically when you visit our Website. Gathered electronically, this information may include the pages you visited, the type of Web browser you use, the level of encryption your browser supports and your Internet Protocol address. The anonymous / non-personal information collected may be used for research and analytical purposes.

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.

How We Use Your Personal Information

We use your personal and financial information to process account applications, communicate with you and effectively provide the products and services you request. The better we know you, the better we can help you achieve your financial goals. By sharing information about you, we can begin identifying your financial planning requirements. 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. We may also send you information about other products and services that we offer, which we believe would interest you.

In certain instances, sensitive personal information such as health records may also be collected for specific reasons relevant to the service being provided. Health-related information will not be shared with others or used for any other purpose.

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.

Transactional information

The majority of information we retain about you is in the form of transaction records that reflect your business dealings with us. We are required by law to update and maintain this information on an ongoing basis and we will communicate this information back to you in the form of regular account statements.

Anonymous / non-personal information

The anonymous / non-personal information gathered from our Website is primarily used for technical research and analytical purposes, such as evaluating the level of usage of various sections of our Website. This information does not include any personal or financial data and it is only retained until its intended purpose is fulfilled.

It is our goal to continuously improve our service offerings to you. Therefore, we use anonymous / non-personal information to better understand the interests, priorities, and satisfaction levels of Canadian physicians, CMA members and clients.

When Information May Be Disclosed To Outside Parties

We are obliged to keep your personal and financial information confidential, except under the following circumstances:

• when authorized by you;
• when required by law; or
• when permitted by law.

When authorized by you

When you first become a client, you will complete and sign, among other documents, our Consent to Share Personal Information form. This provides us with your permission to share your personal information as described on the Consent form. If the Consent form is not signed, it may prevent us from accepting you as a client.

The Consent to Share Personal Information form permits us to:

• collect personal and financial information from you, including information related to transactions in accounts you hold with us;
• use your personal information to assess your financial situation, to provide the services you request, to share with other companies within the CMA Holdings Group and to offer additional products and services that we offer that might benefit you;
• share your personal information with external service providers, as described; and
• use your Social Insurance Number for tax reporting.

In some cases, your consent to use and/or disclose your personal information will be obtained verbally. In other cases, such as when you apply for a product over the Internet, your consent will be obtained electronically.

When required by law

The type of personal information we are legally required to disclose most often relates to government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose certain other personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities making the request have legitimate grounds to do so.

When permitted by law

There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to collect a delinquent account, a medical emergency or even a suspicion of illegal activities.

Safeguards

We use state-of-the-art technologies and maintain current security standards to ensure that your personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration or misuse. All safety and security measures are also appropriate to the sensitivity level of your information.

Client Files

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

Accessing & Amending Your Personal Information

It is important that your personal and financial information is accurate and complete. As a client, you have the right to access, verify and amend the information we maintain about you.

Accessing your personal information

You may access and verify any of your personal information, regular account or transactional 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 are a subscriber to MD Online, you can also obtain much of your account information through this channel.

If you have a question concerning a decision we have made about your personal information, we will inform you of the reasons for the decision if we are permitted to do so by law. If for some reason, you are refused access to your personal information, you may challenge this refusal by contacting our Chief Privacy Officer.

Amending your personal information

To help us keep your personal information up-to-date, we encourage you to amend inaccuracies and make corrections as often as you like. Despite our best efforts, errors may occur. Should you identify any incorrect or out-of-date information about yourself, we will make the appropriate change in accordance with your instructions. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us 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 without talking/communicating with each of them individually.

How do I change my personal information?

You may make a change to the personal information we maintain about you by contacting SWConsulting directly.

Our "OPT-OUT" Policy

In order to ensure that we can service you appropriately and to make sure that you are aware of all products and services available to you, we share, with your consent, your personal information among the companies within the Association's group of subsidiaries.

Should you choose not to permit us to share your personal information, this may prevent us from fulfilling our commitment to you and, in certain circumstances, you may not be able to continue with us as an active client.