Privacy Policy
Privacy and the Protection of Personal Information

The following policy is dated March 1, 2022.

Our Commitment to Privacy

At Odlum Brown Limited, we respect your privacy and the confidentiality of your personal information. We are committed to keeping the personal information you share with us, whether over the Internet, on the telephone or through our branches and offices, confidential. The use of such information will only be for the purpose for which it was collected. This Privacy Policy explains how Odlum Brown and its affiliated companies collect, use, disclose and protect the personal information we obtain. References to "Odlum Brown" are to the corporate entity Odlum Brown Limited and include its subsidiaries and affiliates, depending upon the context.

We may amend our Privacy Policy from time to time to accommodate changes in our services, technology or as a result of a legal development. We encourage you to check back and review our Privacy Policy periodically. Each time you submit personal information or use our services, you agree to be bound by the current terms of our Privacy Policy.

What is Personal Information?

Personal information is any information about you as an identifiable individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and website use information, together with your personal references and identification numbers (such as a social insurance number).

Important Principles For Your Protection

Our Privacy Policy applies to individuals, including individuals carrying on business alone or in partnership with other individuals. It consists of the following key principles:

• Collecting and Using Personal Information – Either before or when we collect personal information about you, we will explain how we intend to use it. We will limit the personal information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your personal information for any other purpose or before collecting personal information from, or providing personal information to, parties not affiliated with Odlum Brown.
• Disclosing Personal Information – We may provide your personal information to other persons, but only as disclosed herein, where we have your consent, or where we are required or permitted to do so by law.
• Protecting Personal Information – We will protect the personal information we obtain about you with appropriate safeguards and security measures. We will retain your personal information only for the time it is required for the purposes we explain or as otherwise required by law.
• Access to and Accuracy of Your Personal Information – We will give you access to the personal information we retain about you. We will make every reasonable effort to keep your personal information accurate and up-to-date.
• Accountability and Openness to Your Privacy Concerns – We will explain your options of refusing or withdrawing consent to the collection, use and release of your personal information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your personal information.

The following sections will answer most of the important questions that you may have about how we fulfill each of these important principles, and how we will hold ourselves accessible and accountable to you.

Why We Ask for Your Personal Information

We ask you for information to establish and serve you as our client. Personal information obtained from you will be used by Odlum Brown to protect and administer your accounts, records and funds; to comply with certain laws, regulations and regulatory policies; to help Odlum Brown improve products and services offered to you; and to understand your financial needs. The information we ask for depends on the products or services you request and in most cases are required by law or the policies of the regulatory organizations to which we are subject. Your social insurance number, for example, is required for products that earn investment income, in order to comply with the Canada Revenue Agency's income reporting requirements. Health information may, for example, be required for some insurance products to ensure you are eligible for coverage.

With your consent, we may share your personal information, where not prohibited by law, within the Odlum Brown group of companies for the purposes of referring life insurance, disability insurance, annuities and other specific insurance products or tax and estate planning and services to you. Sharing such information will help us serve you better and determine whether any products or services we provide through our affiliated companies are suitable for you. Sharing your personal information also helps us determine your financial needs because it allows us to review what products of Odlum Brown you have and how you use them. Please note, however, that we will not share health information that may have been provided in connection with any insurance product for other purposes. With your consent, we may use certain information to provide you with information about Odlum Brown and its products and services. This consent is optional, and you can decide to withdraw it at any time. Please refer to the Understanding Your Options section.

We only collect the information we need and only use it for the purposes explained to you. When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your personal information. If we wish in the future to use it for another purpose, we will ask you for your consent at that time. We will only ask for the information we need for that particular product or service. We will indicate clearly which information would help us to serve you but is optional for you to provide.

How We Collect Personal Information About You

We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties. Obtaining additional personal information about you from parties outside of Odlum Brown helps us assess your eligibility for our products and services. For credit or margin purposes, for example, we may need to know your creditworthiness. We may contact references you have provided or credit reporting agencies to verify information that you have given us or to give us information on your credit history. We will not do this without your consent, but please remember that if you do not give your consent we may not be able to provide the particular product or service you have requested.

Privacy on the Internet

We recognize that you may have special privacy concerns regarding our services provided on the Internet. In particular, we will want to ensure that your personal information is secure and that you are aware of and can control our use of your personal information in the Internet environment.

You can contribute to the confidentiality of your personally identifiable information when using our website by not disclosing your designated username and password to anyone. Remember, email over the Internet is generally unencrypted. We recommend that you do not send us sensitive or confidential information by ordinary email, as unencrypted email is generally not secure. We are equally concerned about your privacy on the Internet and this Privacy Policy applies in its entirety to anything you might do while visiting our website.

Odlum Brown also uses "cookies," a standard technology that installs information on a visitor's computer to permit our website to recognize future visits by that computer. Cookies enhance the convenience and use of the website. For example, Odlum Brown uses the information provided through cookies to recognize you as a previous user of the site, offer customized web pages for your use, track your activity on our website to respond to your needs, and otherwise facilitate your Web experience. The cookie is not used to retrieve any information from your computer that you have not already provided. You may choose to disable the "cookies" option on your browser; however, doing so may affect your use of our website and your ability to access certain parts of our website.

When We Release Your Personal Information

Under no circumstances do we sell client lists or personal information to others. We release your personal information to parties outside Odlum Brown only under the following circumstances:

• With Your Consent – We will disclose your personal information with your prior consent.
• Trusted Contact Person (TCP) – If you have designated a person as your TCP, we will disclose such personal information as we deem necessary using our best subjective judgment.
• To Facilitate Trading in Securities – We give a limited amount of information, only as necessary, to our service providers and agents such as our data processing agent or securities clearing agent, for the purposes of facilitating transactions in your account.
• When Required or Permitted by Law – In certain circumstances, the law may require or permit Odlum Brown to disclose your personal information without your knowledge or specific consent. For example, such information may be disclosed if required to comply with a subpoena, warrant, or court order, or if requested by a government institution which has the lawful authority to obtain the information.
• For Regulatory Purposes – From time to time we may disclose your personal information to securities regulatory and oversight organizations to which Odlum Brown is subject, such as the Investment Industry Regulatory Organization of Canada for the purposes of an audit or investigation relating to your relationship with Odlum Brown or Odlum Brown’s business generally.
• Protection of Public Interest – We may disclose information to the authorities to serve a clear public interest and fulfill our public duty – such as to protect against fraud, money laundering or other criminal activity.
• To Improve Our Service To You – Periodically, Odlum Brown may employ a third party service provider to help it survey clients and obtain their feedback on matters Odlum Brown believes will assist it to improve its service and product offerings to its clients. In such circumstances, Odlum Brown will only provide such third party service providers with your contact information for the sole purpose of inviting you to participate in a client survey and to collate your responses on a non-attributive basis. Odlum Brown will only employ such third party service providers if it obtains their written assurance to keep your personal information and responses you provide secure and not to use any of this information for any other purpose except the specific purpose for which it was provided or to share it with any other person unless compelled by court order or otherwise required by law.

In exceptional circumstances it may be necessary that we disclose your personally identifiable information if we believe, in good faith, that disclosure is otherwise necessary or advisable to protect Odlum Brown’s interests. We will seek to ensure that any proposed disclosure is required in the circumstances and then ensure that we disclose only the information that is required.

Understanding Your Options

We will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record and respect your choices. In many cases, you are free to refuse or withdraw your consent at any time. You may do so by contacting your Investment Advisor, the Branch Manager of your Odlum Brown branch or by calling an Odlum Brown Privacy Officer at (604) 669-1600, or toll free at (888) 886-3586. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent, and record your options. With few exceptions, you can change your options at any time.

How We Protect Your Information

Odlum Brown uses third party providers of information technology and data processing services that may store and/or process your personal information outside of Canada. Your personal information may be disclosed in response to valid demands or requests from government agencies under applicable law in those jurisdictions.

We will protect your personal information with appropriate safeguards and security measures. We have security standards to protect our systems and your personal information against unauthorized access and use. We use our best efforts to ensure our suppliers and agents, as part of their contracts with Odlum Brown, are bound to maintain your confidentiality and may not use the information they obtain for any unauthorized purpose. When we provide information in response to a legal inquiry or order, we ensure that the order is valid, and we disclose only the information that is legally required.

All employees of Odlum Brown are familiar with the procedures that must be taken to safeguard client information. And to us, protecting the confidentiality of your personal information is part of our jobs. We audit our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate.

We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed or required, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your Right to Access Your Information

We will give you access to the information we have about you. Most of this information is in the form of your transaction records which can be obtained by contacting an Odlum Brown Privacy Officer in writing at our head office address: Suite 1100 - 250 Howe Street, Vancouver, British Columbia, V6C 3S9. If you require other information, simply contact your Investment Advisor, the Branch Manager of your Odlum Brown branch or office that handles your account. We will ask you for specific details such as branch and account number. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request promptly but in any case within 30 days.

Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Odlum Brown or cannot be disclosed for other legal reasons. If you have any questions regarding decisions made, we will tell you the reasons for those decisions. Also, we do not ordinarily maintain disclosure records for regular or routine actions, updating of credit information, if required, or account balance deficiencies.

Keeping Your Information Accurate

We will make every reasonable effort to keep your personal information accurate and up-to-date. Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes such as if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections as soon as reasonably possible and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Your Concerns Matter to Us

Your comments and concerns are important to Odlum Brown. If you have any concerns or questions about privacy and confidentiality, or any concerns about the way a request for information was handled, you can take the following actions:

• First – contact your Investment Advisor or Portfolio Manager or the Branch Manager of your Odlum Brown branch. Your Investment Advisor or the Branch Manager may in most cases be able to resolve the matter but will, in any case, ensure that your concerns are addressed to an Odlum Brown Privacy Officer so that further action, if necessary, is taken to resolve the matter.
• Second – if your concern remains unresolved, you can contact an Odlum Brown Privacy Officer directly in writing at Suite 1100 - 250 Howe Street, Vancouver, British Columbia, V6C 3S9, by telephone at (604) 669-1600 or toll free at (888) 886-3586, or by facsimile at (604) 844-5342.