PRIVACY POLICY (As it pertains to the information provided to Verecan Capital Management Inc. by our clients.)

Verecan Capital Management Inc.’s Privacy Policy sets out our standards for collecting, using, disclosing and storing your personal information. Our Privacy Policy also explains how we safeguard your personal information and your right to access that information.

1. PERSONAL INFORMATION – Personal Information is any information about a person that identifies the individual, such as financial, lifestyle or health information, but not their name, title or business address, telephone or email. Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.

2. PURPOSE OF INFORMATION COLLECTION – Verecan collects personal information to allow us to provide you services and meet legal and regulatory requirements. Personal information is collected through our client discovery process, which involves:

Client telephone and face-to-face conversations and meetings; Documents submitted to us or disclosed to service providers; and any transactions with outside service providers or us.

We do our best to obtain only necessary personal information from our clients. We are required to collect specific information to enable us to provide our services and fulfill our legal/regulatory obligations. In general, we collect information for the following purposes:

>To fulfil our fiduciary obligations as a Portfolio Manager;
>To verify your identity following applicable Anti-Money Laundering (“AML”) and Securities Legislation;
>To be able to open and service your Account;
>To be able to facilitate electronic fund transfers to and from your Account or from other financial institutions;
>To detect and prevent fraud and other unauthorized or illegal activities; To meet legal and regulatory requirements, and
>To fulfil tax reporting obligations.

SERVICE PROVIDERS
We may share your personal information with third-party service providers that provide services on our behalf and/or government agencies where required. Third-party service providers are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the delivery of the specific contracted service.
When you open an account with us, you will also be required to open an account with the Custodian. The Custodian will provide account administrative services such as trade execution, clearing, and other services on our behalf. We must also notify them of any updates or changes to your Account information.

SECURITIES REGULATIONS
We and/or the Custodian may share your name, contact information, and holdings with issuers of securities you hold in your Account and other persons/ companies as required by securities law. Such issuers may require your personal information to deliver financial reports, tax documents, and other relevant materials to you or comply with applicable regulatory obligations.

We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under the law, including any applicable anti-money laundering legislation or similar laws.

3. CONSENT – Unless you advise otherwise, by providing us with your personal information, you have consented to our collection, use, and disclosure of your information for the purposes described within this policy. Where appropriate, for less sensitive information, we may accept your verbal consent. Occasionally, we may imply consent where we can infer consent from your action or inaction. We will obtain your consent for any additional use or collection, or if the purpose of using the information changes.

Consent must be given by you or your authorized representative such as a legal guardian or a person having power of attorney.

You may withdraw your consent at any time, subject to legal or contractual restrictions. We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or process a request. If you choose not to consent, we will record the decision in our file.

In limited circumstances, we have the obligation to collect, use or disclose personal information without your knowledge and consent. This occurs when legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking consent might defeat the purpose of the information collection. Similarly, seeking consent may be impossible or inappropriate when you are a minor, seriously ill, or otherwise incapacitated.

4. LIMITS TO COLLECTION, USE AND DISCLOSURE – We limit the collection of your personal information to what we need in relation to the purposes identified to you. We collect the information directly from you unless you allow us to collect information from a third party or in accordance with the law.

We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use your personal information for other purposes without your consent, except as required by law.

Your personal information is only accessible to authorized persons, and only to the extent necessary to perform their duties.

You have the right to know, on request, to whom the information was disclosed. Only in rare instances are we prevented by law from making such disclosure. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.

5. RETENTION – We only retain your personal information as long as needed for the purpose it was collected. We must destroy this information in accordance with the law and our file retention guidelines. When we destroy your personal information, we make sure that confidentiality is secured and that no authorized person can access the information during the destruction process.

6. CLIENT LIST – We do not sell client lists to third party.

7. ACCOUNTABILITY – The privacy of our clients is crucial to us. We maintain reasonable administrative, technical, and physical safeguards to protect personal information in our possession. Our employees follow policies and procedures to keep personal information private and confidential.

We are responsible for your personal information in our possession or control, including information that may be transferred by us to third parties for processing. We require such third parties to keep personal information under strict standards of privacy and protection.

8. SAFEGUARDS – Verecan uses reasonable physical, organizational, and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

You may access your personal information to verify its accuracy, withdraw your consent to any of the foregoing collections, uses, and/or disclosures being made of your personal information, and update your personal information by contacting the Privacy Officer at the address below.

In certain limited and specific circumstances, we may refuse to provide to you the requested information. Exceptions to your access right can include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client privilege.

9. ACCURACY – We make every possible effort to ensure that your personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.

You may challenge the accuracy and completeness of your personal information. We will respond to an amendment request within a reasonable time.

Any request for access to information or request for amendment must be sent to the following address:
Verecan Capital Management Inc
Privacy Officer
1701 Hollis Street, Suite 105 Halifax, NS B3J 2T9
1-800-782-2345
compliance@verecan.com

10. QUESTIONS AND CONCERNS – Any of our employees can respond to your questions or concerns about personal information. Should you still require additional information, you may contact the Privacy Officer at the address above. A complaint concerning the protection of personal information should be addressed to the Privacy Officer at the address provided above.