At Barrantagh Investment Management Inc. we have a strong commitment to earning and retaining our clients’ trust by providing a range of investment management services while maintaining a privacy policy that protects the confidentiality and integrity of your personal and business information.

Personal information is collected directly from you and may include: address, telephone number, date of birth, citizenship, social insurance number, marital status, employer, financial information, beneficiary, accountant, lawyer, etc.

Purpose

Personal information is collected to initiate an ongoing business relationship with you. Information is collected from you through discussions and the completion of our application forms. Information such as account data is also collected over time.

Accuracy

It is important for us to maintain accurate and up-to-date information in order for us to best meet your objectives. We may from time-to-time request specific information be updated and will only do so in your best interest or as required by law. It is important that you let us know of any changes to this information.

Limiting Collection

Only information necessary for us to conduct business on your behalf, and that which is required by law will be collected. Information is collected by fair and lawful means.

Consent

By signing our Application Form and/or Contract you understand the purpose of collecting and using this information and give us consent to do so. You may withdraw all or part of your consent for us to use your personal information at any time, subject to legal or contractual restrictions and reasonable notice. If consent is withdrawn we may be limited in the services that we can provide you.

Disclosure to Custodian

Barrantagh does not maintain custody of client assets, such as cash and/or securities. These assets are held and maintained by a separate custodian. The relationship between you and the independent custodian is governed by a separate agreement between you and the custodian. Any custodian selected by Barrantagh will have a Privacy Policy acceptable to Barrantagh. While Barrantagh makes every effort to ensure that the custodian will maintain confidentiality of records, we are unable to directly enforce such compliance.

Accountability and Disclosure

We are responsible for maintaining and protecting your personal information and have dedicated personnel to oversee this function. Our employees and service providers may have access to your personal information to enable them to perform their duties relating to our service engagement with you. Examples of services providers would include but not be limited to: auditors, custodians, courier/postal services, legal counsel, Federal and Provincial Governments and government regulatory agencies, secure off-site storage, secure document destruction providers.

Limiting Use and Retention

Your personal information will only be used for the purposes it was collected. If your information is to be used for purposes not previously identified, we will obtain your consent prior to its use, unless it is required by law. We will keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). The type of service and the kind of information affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date. Portions of this information may be held by our secure off-site storage service provider. Once we have determined that it is no longer required, it is destroyed in accordance with our records management and destruction policies.

Safeguards

One of the key elements underpinning your trust is the protection of your personal information. We have established controls including the access to our office and data records, passwords and file encryption for on-line activities.

Openness

Upon written request we will make information available to clients concerning the policies and practices that apply to the management of their information. We will respond within 30 days of receiving your written query.

Individual Access

You may request access to your personal information and should you have any questions as to its accuracy or completeness we will respond within 30 days of receiving your written request, unless prohibited by law. Depending on the nature of your request it may be necessary for us to charge you the costs incurred in providing this information. If we cannot provide you the requested information we will respond in writing with a full explanation.

Challenging Our Compliance

Obviously we would have no business if there was no trust between us. Upon your request we will immediately investigate and respond with our explanation of any aspect of our policies for the protection of your personal information. We welcome your privacy questions.

If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website, www.barrantagh.com, as soon as they go into effect. You have a right to know at all times what information we collect, how it is used, and under what circumstances it will be disclosed. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower right hand corner of this web page. We recommend that you print a copy of the updated policy for your reference and revisit it from time to time to ensure you are aware of any changes.