Privacy Policy

Privacy of personal information is an important principal to Rae & Lipskie Investment Counsel Inc. We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the services we provide.

Rae & Lipskie is committed to ensuring that your privacy is protected. Should we ask you to provide certain information, you can be assured that it will only be used in accordance with this privacy statement.

Rae & Lipskie may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you agree with any changes. This policy is effective June 1, 2007.

What we collect

We may collect the following information:

• Name, address and telephone number
• Email address
• Date of Birth, Social Insurance Number and/or passport number
• Spousal personal information such as the above
• Employment information
• Personal financial and income information
• Proof of citizenship
• Marital status

What is personal information?

Personal information, as it applies to this policy, is any information that identifies you, the client, as an individual. Personal information may also include communications you have with us regarding your investment portfolio(s).

Why we collect your personal information

We require this information to understand your needs and provide you with the utmost personal service to meet your needs, and for the following reasons:

• Internal record keeping
• To improve our investment techniques
• To maintain communications with you, such as your portfolio statements, newsletters and invitations for functions we may hold
• Supervision of trading activity, financial compliance and regulatory audits
• Establish your identity with your custodian
• To administer your investments

In most cases, law or securities regulators require certain information we request from you.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to secure the information we collect from you.

We maintain security policies, procedures and confidentiality to protect your personal information against loss, theft or misuse. We have safeguards in place to prevent disclosure, copying, use and modification of both hard copy information and electronically stored information. Such safeguards may include the following:

• Data security access control
• Physical site access control
• Remote user access control
• Contractual agreements with employees and necessary vendors.
• Network security
• Virus protection
• Regular backups of all computer information

Any personal information collected from you will only be used for the purposes identified at the time of collecting the information and will be retained for as long as is necessary to fulfill the service, or as required by law.

During the course of our relationship with you we may be required, at your request, to communicate with you electronically by email or through the Internet. Electronic copies of your financial statements and/or investment information may be sent to you, or as directed by you, to a third party. Please be aware there are significant security risks attached to these electronic communications (including human error) and therefore, we require a waiver signed by you.

All of our employees, custodians and authorized service providers are strictly required to protect the confidentiality of personal information.

Regulating your personal information

We will not provide your personal information to third parties unless we receive your permission or it is required by law. We may use your personal information to send you information that we think you may find interesting.

Who may have access to your personal information?

• Rae & Lipskie’s employees and affiliates
• Third parties as instructed by you
• Your account custodian(s) and their affiliates
• I.T. and other necessary vendors
• Canadian government, government agencies, and regulators

Keeping your personal information accurate

You can assist us in maintaining the accuracy of your personal information by notifying us of any changes or advising us of any errors in our records.

Resolving Complaints

Privacy related complaints may be directed to our Senior Administration Manager,

Sheila Yendt:

By email:

Sheila@raelipskie.com
Subject: Privacy Policy — Your Name

By phone:

519-578-6849 or 1-888-578-7542

By mail:

Rae & Lipskie Investment Counsel Inc.
Attn: Sheila Yendt
20 Erb Street West, Suite 201
Waterloo, Ontario N2L 1T2

If you have any questions about how Rae & Lipskie Investment Counsel Inc. handles your personal information, please do not hesitate to contact us.

This policy is made under the Personal Information Protection & Electronic Documents Act (PIPEDA). For more general inquiries, contact the Information and Privacy Commissioner of Canada (IPC). IPC oversees the administration of the privacy legislation in the private sector.

The Commissioner also acts as a kind of ombudsman for privacy disputes. Information and the Privacy Commissioner can be reached at:

Information and Privacy Commissioner of Canada

112 Kent Street
Ottawa, ON
K1A 1H3
Phone: 1-800-282-1376
Fax: 613-947-6850
www.privcom.gc.ca