Policy relating to the Collection, Use and Disclosure of Personal Information

ST Global Asset Management Inc. (“ST Global”) is committed to maintaining the privacy and confidentiality of all personal information under our care. In the course of providing portfolio management or exempt market dealer services, our firm is legally obliged to collect, use and store personal information about individuals. The purpose of this Policy is to answer questions about what personal information we hold and may transfer, the purposes for which we collect it, how we protect it, who it may be disclosed to, and how it can be accessed or modified. This policy applies to all accounts held by ST Global and is in addition to the service agreements governing the services we render for our clients. By opening or maintaining an account with ST Global, you signify your consent to the terms of this Privacy Policy. This Privacy Policy also serves to govern the conduct of all ST Global employees with regard to personal information.

1. TYPES OF PERSONAL INFORMATION UNDER OUR CARE

When we open and maintain an account, we are obliged to collect the following types of information out of necessity or legal obligation:

(i) Information provided on account applications or other forms, such as names, mailing addresses, telephone numbers, email addresses, social insurance numbers, dates of birth, employment information, spousal information, financial and net worth information as well as banking details;

(ii) Information about investments, assets, and transactions, such as account balances, trading activity, margin loans, and payment history;

(iii) Information we may receive from consumer-reporting agencies.

2. PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION

We collect and use the personal information we obtain during the account opening and account administration process for the following purposes:

(i) To open, maintain and administer client accounts;

(ii) In compliance with applicable federal and provincial laws;

(iii) To verify client identity and protect against fraud;

(iv) To provide the services requested by clients;

(v) To comply with industry specific regulations.

3. PROTECTION OF INFORMATION

ST Global protects personal information by storing it in locations that are designed to prevent the loss, misuse, unauthorized access, disclosure, alteration or destruction of that information. Personal Information is stored only as long as it is required and/or as dictated by law. Our employees have access to personal information only on a need-to-know basis.

4. DISCLOSURE OF INFORMATION

ST Global does not sell personal information to third parties. ST Global does not disclose personal information to third parties other than in the following circumstances and for the following purposes:

(1) In the normal course of business operations to open, maintain, administer, or service client accounts, including, without limitation, for purposes of facilitating the account opening process and the provision of customer service (including services rendered by third party agents or affiliates), for audit and accounting purposes;

(2) To specific ST Global employees in order to offer services to clients, to engage in surveillance, compliance, and reporting activities required by applicable law and/or to ensure disaster recovery services relating to such information (which may include trans-border transfers of information);

(3) To other suppliers or service providers who assist us in serving our clients. Our service providers may at times be responsible for processing or handling personal information. Such service providers are provided only with the information necessary for them to perform their services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and customary security practices. In the event our service provider is located in a foreign jurisdiction they are bound by the laws of the jurisdiction in which they are located and may disclose personal information in accordance with those laws;

(4) To legal counsel for the purpose of obtaining legal advice;

(5) Where we are required or permitted to do so by law, including to any law enforcement agency, securities regulatory authority or Self-Regulatory Organization, namely for the purposes of:

(i) Surveillance of trading-related activity;

(ii) Sales, financial compliance, trade desk reviews and other regulatory audits;

(iii) Investigation of potential regulatory and statutory violations;

(iv)Regulatory databases;

(v) Enforcement or disciplinary proceedings;

(vi) Reporting to securities regulators; and

(vii) Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and relevant law enforcement agencies within any territory regarding any of the preceding activities.

By opening or maintaining an account with ST Global, clients consent to the disclosure of personal information to a third party in the circumstances or for the purposes described above.

ST Global’s clients must understand, acknowledge and agree that their consent to the disclosure of personal information in connection with a matter referred to above is not a condition of ST Global for transacting with its clients, including the relevant offer or service to be provided, unless the disclosure of the information is necessary in respect of the particular matter or required by law. Subject to this qualification, consent to ST Global’s collection, use or disclosure of personal information may be revoked or withdrawn, at any time on reasonable notice, by contacting ST Global’s Compliance Department by email at [email protected] 

If consent were to be revoked or withdrawn, ST Global may be unable to provide certain or all services. Our Compliance Department personnel will be happy to explain any consequences of revoking or withdrawing consent.

5. ACCESS TO INFORMATION

ST Global makes every reasonable effort to ensure that personal information is accurate and up-to-date. Individuals can also access and update the personal information that we collect at any time by contacting our Compliance Department by email at [email protected].

Individuals may also consult the personal information ST Global maintains by contacting ST Global’s Compliance Department by email at [email protected] and scheduling an appointment. In your request, please include the relevant account number(s), and the information which you would like to have updated or modified.

6. INQUIRIES OR COMPLAINTS
ST Global’s Legal Counsel is responsible for the monitoring and compliance with this Privacy Policy. Inquiries or complaints regarding this Privacy Policy should be directed to our Compliance Department by email at [email protected].