At East Coast Fund Management Inc. (“ECFMI”) we recognize that all personal information is private and confidential. ECFMI’s Privacy Policy (‘Privacy Policy’) governs ECFMI’s collection, use and disclosure of personal information. It is the intention of ECFMI, by way of this Privacy Policy, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information and Electronic Document Act (PIPEDA). The following describes the collection, use, disclosure and retention of personal information that you provide to us or is shared with us from other sources.

PERSONAL INFORMATION

This includes information that specifically identifies you. Such information may include your age, marital status, employment history, Social Insurance Number, credit history, home address, personal email address and home telephone number. Personal information does not include your name and title, business contact information such as business address, telephone number, email address, which you provide to us for business purposes.

ACCOUNTABILITY

ECFMI acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. All staff members are informed of the obligation under law and of the need to use the utmost discretion when dealing with client information.

PURPOSE

ECFMI will only use client information for the purposes identified either before or at the time of collection. Such information is retained on record at ECFMI’s office. We do not sell our client lists or your personal information.

CONSENT

ECFMI will only use information for identified purposes and if the information is required for any new use, ECFMI will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally, or may be implied directly by the client or a client authorized representative.

COLLECTION

ECFMI will only collect information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation such as, the Money Laundering (Terrorist Financing) Act, Canada’s Anti-Spam Legislation and/or Foreign Tax Compliance Act (FATCA). ECFMI’s employees will do their best to explain why collection of information is necessary in a clear and informative fashion. In some instances, ECFMI may also collect personal information through other sources such as, but not limited to, financial institutions.

USE, DISCLOSURE & RETENTION

ECFMI will only retain personal information as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individual’s personal information is no longer required, ECFMI will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that information cannot be found or used by an unauthorized party. Information submitted to the website is kept strictly confidential. In all cases, the provision of personal information is voluntary; any personal information provided by users on the site is submitted at the user’s discretion. We collect personal information so we may provide users with the relevant information they have requested. We may disclose information to a third party to (a) comply with laws or respond to lawful request and legal process, (b) to comply with taxation and regulatory authorities and agencies or (c) for the purposes of due diligence involving a business transaction. ECFMI limits the information it collects to what it needs for these purposes, and ECFMI will use it only for these purposes.

ACCURACY

ECFMI strives to maintain accurate client information which not only help us provide better client service but also minimizes the potential misuse of personal information.

SAFEGUARDS

ECFMI understands the importance of protecting personal information and therefore implements a number of safeguards against unauthorized access or improper disclosure. For example, our computer network, employee computers, laptops, answering services are all password protected. In addition, filing cabinet units containing personal information are locked and can only be accessed by authorized individuals. Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continued maintenance and periodic review of our Privacy Policy and procedures.

DIRECTness

At ECFMI we make our best effort to inform clients of our policies and procedures and to explain how we manage personal information. If you have additional questions or concerns we will do our best to help you understand our policies and procedures.

ACCESS

When requested and supported by sufficient identity information, ECFMI will provide clients with their personal information as maintained in client files. We recognize a client’s right to their own information, how the information is used and to whom it is disclosed.

Links to Other Sites

ECFMI assumes neither responsibility nor control over the content, security, accessibility or accuracy of sites to which we may provide links. When leaving our site, please check the privacy policy and security certificates for the site you are visiting before sharing information.

Website Data Tracking

ECFMI maintains a statistical record of website usage and traffic. Analysis of this information reveals which pages are most often visited and the domains from which people visit the site. Identifying these trends helps us to provide more useful information to visitors. No personal information is collected during this process.

Changes to this Policy

Since ECFMI periodically reviews all of its policies and procedures, we change our Policy from time to time. Please refer to our website for updates.