IPC PRIVACY POLICY

OUR COMMITMENT TO PRIVACY

Our privacy policy (“policy”) explains how we handle the personal information we collect as part of our day-to-day business and lets you know about your rights when it comes to your personal information. We’ll always be clear about how and when we collect, use and share your personal information and we’ll never sell your personal information.

We may update this policy from time to time. Updates are effective on the date shown on this policy.

In this policy we refer to ourselves – Investment Planning Counsel Inc. and our subsidiaries – as “we”, “our” and “us”.

Our Privacy Officer monitors compliance with this policy.

WHAT IS "PERSONAL INFORMATION"?

Personal information is information that either on its own or combined with other information allows an individual to be identified. Examples include your name and address, as well as more sensitive information such as your health and financial records. When applicable, this includes information about other people such as your spouse, common-law partner, and children.

Learn more about how we collect, use, share, and protect your personal information as well as your privacy rights.

CONSENT

Your knowledge and consent are required for us to collect and use your personal information, except when allowed by law.

HOW WE COLLECT PERSONAL INFORMATION

We collect your personal information in three ways – directly from you, from other people and organizations, and from your use of our websites and mobile applications.

1. We collect personal information directly from you throughout our relationship with you. For example, we may collect personal information through paper or online applications for products and services, on the telephone, or through email.
2. Depending on the products and services you have with us, we may also collect your personal information from other people and organizations. These can include your advisor, other insurance companies, government departments and agencies, and other organizations that help us provide you with the products and services you’ve requested.
3. When you visit our website or use our mobile applications (collectively Online Services), we’ll also collect your personal information using cookies. Cookies make your next visit easier by storing your preferences.

When we collect personal information, we’ll only collect what we need and we’ll tell you why we need it.

When applicable, the personal information we collect may also include information about your spouse, common-law partner, dependants and beneficiaries. We’ll ask you to confirm their consent for us to collect and use this information, and to communicate with you about them.

INFORMATION WE COLLECT

Depending on the product or service, we may collect the following types of personal information. We’ve included some categories and examples of personal information we collect. These examples aren’t intended to be exhaustive.

• Identification and Contact Information - such as your name, address, telephone number, email address, date of birth, social insurance number or social security number (for tax purposes or when required), and information on government issued identification;
• Financial Information – such as annual income, assets, liabilities, banking information, your payment history, credit worthiness, investor profile;
• Employment Information – such as your job and where you work, your work history and compensation records
• Transaction Information - arising from your relationship with and through us, and from other financial institutions, such as account numbers and transaction history;
• Information pertaining to business clients – such as your business name, address, telephone number, email address, industry type, financial status and details of the owner(s), operator(s) and director(s);
• Online Services use – such as your internet (IP) address (a unique identifier or each device that connects to the internet), when you visit our site, which pages you visit and for how long;
• Additional information may be requested to help us determine your eligibility for the products and services that we offer;

HOW WE USE PERSONAL INFORMATION

We use your personal information to help you reach your financial goals.

Depending on the products and services you have with us, your personal information may be used to:

Know who you are:

• Verify your identity and see if you’re eligible for products, services,
• Provide you with advice,
• Maintain your profile and keep accurate records,

If you provided your social insurance number (SIN) or social security number (SSN), we’ll use it for tax reporting. Your SIN and SSN may also be used to link your products together and to keep your information separate from other customers with similar names.

Maintain our relationship with you:

• Administer your products or services, including processing transactions
• Inform you about features or benefits of products or services you already have with us
• Provide you with pricing and quotes for products that suit your needs
• Manage your records
• Improve our business operations, products, and services

Respect the law and manage risk:

• Prevent and protect you and us from criminal activity, fraud, misrepresentation, or cyber crime
• Respond to requests to provide your information to law enforcement, courts, and/or other authorities inside and outside of Canada
• Comply with tax requirements

Additional Uses:

We may communicate with you in various ways including telephone, email or mail using the contact information you have provided.

With your consent, we may use your personal information to promote our products and services and those of third parties that we select, which we believe you will be interested in. You can opt-out of this use at any time by contacting our Privacy Officer.

HOW WE SHARE PERSONAL INFORMATION

We share your personal information with other people and organizations who help us administer your products and services. Some of these people and organizations may be located outside of your province of residence or outside Canada. In that case, your information will be subject to the laws of the other jurisdiction, including any law permitting or requiring disclosure of the information to government agencies, courts, and law enforcement of that jurisdiction.

Other organizations we share your information with may include:

• Technology suppliers
• Print and mail services
• Record storage companies
• Courier companies
• Legal services providers
• Other financial institutions
• External auditors
• Credit reporting agencies

Other people we share your information with include:

• Your advisor and people who work with your advisor

We may also share your personal information with our subsidiaries, government departments and agencies, law enforcement, courts and other authorities inside and outside of Canada to meet our legal requirements and to prevent or address criminal activity, fraud, misrepresentation or cyber crime.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We take protecting your personal information seriously. We have technical and organizational safeguards to protect personal information against loss and unauthorized access, use or disclosure.

Everyone who works at IPC, as well as the people and organizations who act on our behalf, are responsible for protecting personal information.

To do this, we have safeguards to protect personal information from unauthorized access. These include:

• Strict access management policies
• Proactive threat monitoring
• Data encryption
• Multi-factor authentication
• 24/7 monitoring of our offices
• Controlled access to the buildings we operate in

An example of our strict access management policies includes limiting access to personal information to:

• IPC employees or authorized contractors who need access to the specific personal information to do their job
• People you have authorized (examples include a power of attorney or other personal representative or advisor)
• Other people and organizations who help us administer your products and services

All employees are provided information security, privacy, and code of conduct training reinforcing the importance of protecting personal information.

YOUR RIGHTS

You have the right to access and correct your personal information that we have collected from you. You also have a right to know which organizations have received your information from us.

To access or correct your personal information, please make your request in writing to IPC’s Privacy Officer, stating as specifically as possible which personal information is subject to your request. We will respond to your request as soon as possible and will advise you if for some reason we cannot respond right away. IPC may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.

In providing you with a list of the organizations we have disclosed your information to, we will try to be as precise as possible. When it is not possible to provide an exact list we will provide a list of organizations we may have disclosed your information to.

If we correct personal information, we will advise other organizations we have disclosed your information to of the correction.

There may be instances where we’re unable to fulfill your request, subject to certain restrictions or laws. If this happens, we will let you know as soon as possible.

HOW LONG WE KEEP PERSONAL INFORMATION AND WITHDRAWING CONSENT

Your personal information is kept only for as long as we need it to provide products and services to you, and for a reasonable length of time afterwards as required by our policies and/or applicable laws. We use care when destroying personal information to prevent unauthorized access.

You may withdraw your consent at any time, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive. If you wish to withdraw your consent to the use of your personal information, or to discuss the implications of such a withdrawal, please contact our Privacy Officer.

HOW TO CONTACT US

Contact us by writing to our privacy officer.

IPC Privacy Officer - Investment Planning Counsel

5015 Spectrum Way, Suite 300, Mississauga, Ontario L4W 0E4

privacy@ipcc.ca

Updated: March 20, 2024