Privacy Information Statement

Your privacy is important!

MISSION STATEMENT
Your privacy is important. At HollisWealth, we are committed to protecting your privacy in order to ensure that the confidentiality, security and accuracy of your personal information are maintained at all times. Personal information is information that identifies you as an individual. Personal information could include your name, address, social insurance number, date of birth, citizenship and country of residence, banking information, identification documents, marital status, dependents, occupation, income and net worth. In order to protect your privacy, HollisWealth has developed policies and procedures2 based upon the following ten privacy principles:

PRINCIPLE 1 – ACCOUNTABILITY
HollisWealth is responsible for all of the personal information of its clients that it collects or that is under its control. HollisWealth has appointed a Privacy Officer who is accountable for HollisWealth’s compliance with its stated privacy principles. The Privacy Officer may be contacted at the address set out at the end of this Privacy Information Statement.

EMPLOYEES AND AGENTS:
All employees of HollisWealth are bound contractually or under the policies and procedures of HollisWealth to maintain the confidentiality of your personal information. In the event that your advisor is an agent of HollisWealth, your advisor is bound contractually or under the policies and procedures of HollisWealth to maintain the confidentiality of your personal information and to ensure that his/her employees or, in some cases, the employees of a corporation in which your advisor is the principal shareholder, maintain the confidentiality of your personal information.

THIRD PARTY SUPPLIERS:
All of HollisWealth’s third party service providers are bound contractually or by other appropriate means to maintain the confidentiality of your personal information and to not use your personal information for purposes that are not related to the service or product that they have been contracted to provide. In the event that your advisor is an agent of HollisWealth, your advisor is bound contractually or under the policies and procedures of HollisWealth to ensure that his/her third party service providers or, in some cases, the third party service providers of a corporation in which your advisor is the principal shareholder, maintain the confidentiality of your personal information and to not use your personal information for purposes that are not related to the service or product that they have been contracted to provide.

PRINCIPLE 2 – IDENTIFYING PURPOSES
HollisWealth shall identify the purposes for which the personal information of its clients is collected before or at the time the information is collected.

GENERAL PURPOSES:
HollisWealth collects your personal information for the purpose of establishing and servicing your account(s) and to fulfill our legal, regulatory and self-regulatory obligations in Canada and in some cases, abroad. In addition, HollisWealth may from time to time, with your consent, provide you with information which may be of interest to you or information relating to products and services that are available through other HollisWealth companies or may share your personal information with other HollisWealth companies so that they can provide you with such information directly. HollisWealth will not sell your personal information to anyone.

SPECIFIC PURPOSES:
Social Insurance Number
HollisWealth is required by law to keep a record of your social insurance number if you have an account that earns income or if you are opening a registered account. In addition, HollisWealth reserves the right to review your credit history and may, with your consent, use your social insurance number to obtain more accurate credit information.

Date of Birth
Your age is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through HollisWealth. Your advisor is required by law to consider, among other things, your age before making investment recommendations. In addition, HollisWealth is required to record your date of birth in order to comply with money laundering legislation.

Citizenship and Country of Residence
HollisWealth requires your citizenship and country of residence in order to fulfill its regulatory obligations. For example, depending on your country of residence, HollisWealth may not be permitted by law to open and service your account.

Banking Information
HollisWealth is required by law to record your banking information for purposes relating to the prevention of money laundering.

Identification
HollisWealth is required by law to verify your identify for purposes relating to the prevention of money laundering. In addition, in the event that you want to avoid adverse tax treatment under U.S. tax laws with respect to income earned from U.S. securities, you may be required to provide a copy of your identification or in the alternative, to complete certain U.S. tax forms.

Marital Status and Dependents
Your marital status and number of dependents is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through HollisWealth. Your advisor is required by law to consider, among other things, your marital status and number of dependents before making investment recommendations.

Occupation
Information relating to your occupation is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through HollisWealth. Your advisor is required by law to consider, among other things, information relating to your occupation before making investment recommendations.

Income and Net Worth
Information relating to your income and net worth is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investments products and services that are available through HollisWealth. Your advisor is required by law to consider, among other things, information relating to your income and net worth before making investment recommendations. In certain instances, HollisWealth is required by law to determine your creditworthiness and your income and net worth are among the factors that we use to make this determination.

PRINCIPLE 3 – CONSENT
HollisWealth shall only collect, use or disclose client information with the knowledge and consent of its client except where inappropriate or as otherwise required or permitted by law.

CONSENT:
By completing our account forms, you are consenting to the collection and use of your personal information for the purposes set out in this Privacy Information Statement and to the disclosure of your personal information to the persons identified in this Privacy Information Statement for the purposes identified.

COLLECTION:
The majority of your personal information is collected directly from you at the time your account is opened at HollisWealth. In the event that your credit history is obtained, HollisWealth may collect personal information directly from a credit reporting agency.

DISCLOSURE:
Your personal information is made available to the employees, agents and third party service providers of HollisWealth and in some cases, to credit reporting agencies and to government, regulatory or self regulatory authorities as required by any domestic or foreign law or as required under the rules and regulations of any self-regulatory authority of which HollisWealth is a member. In the event that HollisWealth buys or sells any part of its business in the future, your
personal information may be one of the assets that is transferred and may be disclosed to the vendor or purchaser, as the case may be, prior to the completion of such a transaction for purposes relating to the evaluation of such a transaction. In addition, with your consent, your personal information may be disclosed to other HollisWealth companies for the purposes of providing you with information relating to products and services that may be of interest to you. Your advisor may be an employee or agent of HollisWealth. In the event that your advisor is an agent of HollisWealth, your personal information may be made available to the employees and third party service providers of your advisor or, in some cases, to the employees and third party service providers of a corporation in which your advisor is the principal shareholder.

NON-HOLLISWEALTH RELATED BUSINESS:
Your advisor has been engaged by the applicable HollisWealth company for the purpose of advising others in the products and/or services that are available at HollisWealth (“HollisWealth Related Business”). Your advisor may from time to time offer you products and services relating to non-HollisWealth Related Business. Your advisor is required to obtain your consent before using any of your personal information that was collected for purposes relating to HollisWealth Related Business, as the case may be, for non-HollisWealth Related Business.

WITHDRAWING YOUR CONSENT:
You have the right to withdraw your consent to the use of your personal information that is not required for the purpose of establishing and servicing your account(s) and to fulfill our legal, regulatory and self-regulatory obligations in Canada and in some cases, abroad, or as otherwise permitted by law. If you DO NOT want HollisWealth to provide you with information relating to products and services that are available through other HollisWealth companies or other information which may be of interest to you or may share your personal information with other HollisWealth companies so that they can provide you with such information directly, please notify HollisWealth of your decision in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. Please be sure to include your name and all of your account numbers in your request. In the event that your advisor provides you with information which may be of interest to you or information relating to products and services available through other HollisWealth companies and you DO NOT want to receive such information, please notify your advisor of your decision. Please be advised that the withdrawal of your consent is NOT a condition of doing business with HollisWealth and you are free to withdraw your consent at any time. In addition, please be advised that HollisWealth will NOT sell your personal information to anyone and your advisor is prohibited from selling your personal information to anyone.

CONSENT NOT REQUIRED:
In certain circumstances, your personal information is made available without your consent when required by a court of law or by a regulatory or self-regulatory organization or to our legal advisors in order to protect the interests of HollisWealth. Regulatory authorities include, without limitation, provincial securities commissions, Canada Customs and Revenue Agency, provincial insurance regulators and provincial mortgage regulators. Self-regulatory authorities include, without limitation, the Investment Dealers Association of Canada, the Mutual Fund Dealers Association of Canada and Market Regulation Services Inc.

PRINCIPLE 4 – LIMITING COLLECTION
HollisWealth shall only collect the personal information of its clients that is necessary for the purposes that have been previously identified to the client.

NEW PRODUCTS AND SERVICES:
In the event that you would like to open additional accounts or obtain other investment products or services that are available through HollisWealth from time to time, HollisWealth may require personal information that was not previously collected. For example, HollisWealth does not require information regarding your designated beneficiaries when opening a regular cash account but will require such information if you decide to open a registered savings account.

PRINCIPLE 5 – LIMITING USE, DISCLOSURE, RETENTION
HollisWealth shall only use or disclose the personal information of its clients for the purposes for which it was collected unless the client has otherwise consented or as required or permitted by law and such client information shall only be retained for as long as necessary to fulfill the purposes for which it was collected or as otherwise required or permitted by law.

FURTHER CONSENT MAY BE REQUIRED:
In the event that HollisWealth would like to use your personal information in a manner that has not been previously identified, HollisWealth will notify you in advance and obtain your consent unless otherwise required or permitted by law.

RETENTION AND DESTRUCTION:
Your personal information is retained throughout the period of time in which you are a client of HollisWealth and for a reasonable period of time thereafter as required or otherwise permitted by law or as required to protect our legal interests. Your personal information is destroyed in a safe and secure manner once it is no longer needed.

PRINCIPLE 6 – ACCURACY
HollisWealth is committed to keeping the personal information of its clients accurate, complete and up to date at all times.

UPDATING YOUR INFORMATION:
In order to maintain the accuracy and completeness of your personal information, your advisor may require you to update your account documentation from time to time. If your personal information changes, please notify your advisor so that HollisWealth has accurate, complete and up to date information.

PRINCIPLE 7 – SAFEGUARDS
HollisWealth is committed to protecting the personal information of its clients and has implemented the necessary security safeguards that are appropriate to protect the sensitivity of such information. SECURITY: The majority of your personal information is contained on your account documentation. HollisWealth stores the bulk of your original account documentation offsite in a secure location. Account documentation that is maintained at HollisWealth’s head office is safeguarded by using a number of protective methods such as using locked, fireresistant filing cabinets and restricting access to certain designated areas where your account documentation is stored. Your advisor is also bound under the policies and procedures of HollisWealth to use similar protective methods to safeguard your account documentation and any other personal information that is maintained in his/her branch.

TECHNOLOGY:
HollisWealth has implemented industry standard methods of protecting your personal information that is available electronically or online from unauthorized access, disclosure, copying, use or modification. This includes the use of firewalls, encrypted passwords, anti-virus software, intrusion detection systems and other appropriate means to protect your personal information. Your advisor is also bound under the policies and procedures of HollisWealth to use appropriate protective methods in maintaining the security of your personal information that is in an electronic format. HollisWealth may from time to time use cookies on its website to improve functionality and in some cases, to provide clients with customized access to our website. Cookies are not used to collect personal information that may reside on your personal computer and are not used to track the websites that you visited before or after you leave the HollisWealth site.

PRINCIPLE 8 – OPENNESS
HollisWealth is committed to providing its clients with information relating to the policies and procedures that apply to their personal information.

ADDITIONAL INFORMATION:
You can obtain more information about our privacy policies and procedures by contacting your advisor or the Privacy Officer in writing at the address noted at the end of this Privacy Information Statement. This Privacy Information Statement and any amendments made thereto are available on our website at: www.holliswealth.com or by contacting your advisor directly for a copy.

PRINCIPLE 9 – ACCESS
HollisWealth is committed to providing its clients with information relating to the existence, use and disclosure of their personal information and clients shall be given access to such information where appropriate.

CONTACT US:
You can request access to your personal information by contacting your advisor directly or the Privacy Officer in writing at the address indicated at the end of this Privacy Information Statement. If you would like to update or amend any inaccuracies in your personal information, please contact your advisor directly. In certain instances, your advisor may not have access to all of your personal information where such information has been created for regulatory, self-regulatory, investigatory or any other purpose necessary to protect the legal interests of HollisWealth. In such instances, HollisWealth may not be able to provide you with access to all of your personal information.

PRINCIPLE 10 – RESPONDING TO INQUIRIES AND COMPLAINTS
HollisWealth is committed to providing its clients with access to an effective, fair and responsive inquiry and dispute resolution process.

INQUIRIES:
Your advisor should be able to answer most of your questions regarding HollisWealth’s privacy policies and procedures. In the event that you require further information, please direct your inquiry in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. In most instances, the Privacy Officer will investigate and reply to inquiries within 30 days. If the Privacy Officer is unable to respond to your inquiry within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response.

COMPLAINTS:
All privacy complaints must be directed in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. In most instances, the Privacy Officer will investigate and reply to complaints within 30 days. If the Privacy Officer is unable to respond to your complaint within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response.

CONTACT DETAILS:
The Privacy Officer can be reached in writing at the following address:
HollisWealth Inc.3
1 Adelaide St. E.
Suite 2700
Toronto, Ontario
M5H 3R3
Attention: Privacy Officer
or by facsimile at (416) 350-3088. Please be advised that all inquiries and complaints must be IN WRITING to the attention of the Privacy Officer. Telephone calls WILL NOT be accepted. Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint.

1 All references to the term “HollisWealth” collectively refer to Scotia Capital Inc., HollisWealth Advisory Services Inc., and Hollis Insurance Agency Ltd..
2 The information provided herein regarding the policies and procedures of HollisWealth may not in all cases be equally applicable to all HollisWealth companies (as such term is defined herein).
3 Goodman & Company, Investment Counsel Ltd. (“Goodman & Company”) is also a HollisWealth company but has its own Privacy Policy and Privacy Officer. The Privacy Policy for Goodman & Company is available online at www.dynamic.ca.