Dixon Mitchell Investment Counsel Inc. (“Dixon Mitchell”) is committed to protecting your privacy.  This Privacy Policy explains how Dixon Mitchell collects, uses and discloses your personal information, and the steps we take to maintain its confidentiality and security.

Key terms of our Privacy Policy:

• For details on the personal information that Dixon Mitchell collects, please see the section below called “How Dixon Mitchell collects personal information”.
• For details on how Dixon Mitchell uses personal information, please see the section below called “How Dixon Mitchell uses personal information”.
• For details on how Dixon Mitchell discloses your personal information, please see the section below called “How Dixon Mitchell discloses personal information”.
• To change your privacy choices, please see the section below called “Opting out”.

Personal information

This Privacy Policy applies to “personal information” (i.e., information about an identifiable individual such as your social insurance number, date of birth, family circumstances, financial and net worth information, and banking information).  To the extent permitted by law, this Privacy Policy does not apply to information (such as your personal name, position or title, business address, business telephone number, business fax number and business email address) which enables you to be contacted at a place of business.  However, Dixon Mitchell treats all of the information in our possession and under our control with care and discretion.

Your consent

By using our services, submitting information to us in connection with our services or investing in securities of investment funds managed by us, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Dixon Mitchell, but then you might not be able to proceed with your intended interactions or transactions with Dixon Mitchell or otherwise receive the full benefit of our products and services. Please refer to the section below called “Opting out” of this Privacy Policy to learn about your options with respect to the withdrawal of your consent.

How Dixon Mitchell collects personal information

We may ask you to provide personal information when we interact with you, including when you request information or use a product or service provided by us. For example, we may collect your name, address, date of birth, social insurance number, family circumstances, employer information and investment experience.

Occasionally, we may collect personal information about you from third parties. We will only collect your personal information from a third party if we have obtained your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so.

How Dixon Mitchell uses personal information

Dixon Mitchell uses your personal information for the following purposes, and as otherwise permitted by law:

• to provide our portfolio management and investment advisory services to you, including by understanding your objectives and risk tolerances, and to otherwise facilitate your interactions and transactions with us;
• to verify your identity and protect against fraud;
• to process and respond to your inquiries, requests and other communications; and
• to comply with legal and regulatory requirements.

Subject to your right to withdraw consent as described in this Privacy Policy, Dixon Mitchell may also use your personal information collected by Dixon Mitchell for the following additional purposes that are not required for Dixon Mitchell to provide you with products and services:

• to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you;
• to administer and facilitate your participation in promotions related to Dixon Mitchell; and
• to conduct surveys on the quality of our products and services.

Dixon Mitchell may use your personal information to create non-personal information, and Dixon Mitchell may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.

How Dixon Mitchell discloses personal information

Dixon Mitchell does not sell your personal information to third parties. Dixon Mitchell does not disclose your personal information to third parties other than in the following circumstances and as otherwise permitted by law:

• Disclosure for Normal Business Operations – Dixon Mitchell may disclose your personal information to third parties in connection with normal business operations to open, maintain, administer or service your investment account, including without limitation for purpose of facilitating the account opening process (including the mailing of account opening materials and the scanning of account documentation, cheques and related materials into customer databases), the provision of customer service (including services rendered by third party agents or affiliates), the provision of back office administrative services (including the mailing of transaction confirmations and account statements, and record-keeping services), for audit or statistical purposes, or for the collection of any debt owed by you in respect of your investment or account.
• Disclosure to Authorizing Persons – If you use our services on behalf of another person or organization (such as your employer), Dixon Mitchell may provide your personal information to that authorizing person or organization.
• Disclosure to Affiliates, Agents, Suppliers and Service Providers – Dixon Mitchell may provide your personal information to its affiliates, agents, suppliers and service providers, including investment dealers and custodians, in connection with your use of our services.  Dixon Mitchell requires its affiliates, agents, suppliers and service providers to agree to use your personal information only for the purposes for which it is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.  
• Disclosure in Business Transfers – Dixon Mitchell may be involved in the sale or transfer of some or all of its businesses.  As part of that sale or transfer, Dixon Mitchell may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.  
• Law Enforcement and Legal Disclosure – Dixon Mitchell may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Dixon Mitchell has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to its legal counsel.  
• Specific Consents – Dixon Mitchell may disclose your personal information to other persons in accordance with express or implied consents that you give during your interactions and transactions with us.

Accessing your personal information

You may request access to your personal information and information about Dixon Mitchell’s collection, use and disclosure of that information by sending your request to Dixon Mitchell’s Privacy Officer at the address noted below.  Subject to certain exceptions and limitations prescribed by law, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.  You can help Dixon Mitchell maintain the accuracy of your information by notifying us of any changes to your personal information.

Security

We take reasonable organizational, technological and physical measures to protect your personal information against unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.

Location of your personal information

Dixon Mitchell stores and processes your personal information in Vancouver, British Columbia.  The disclosure of your information in accordance with this Privacy Policy and applicable law may result in your personal information being transferred outside of Canada.  For example, back-up copies of records that include your personal information are currently stored in electronic format with a third party located in the United States.  The laws of other countries regarding the collection, use and disclosure of personal information may be different from the laws of Canada, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. Dixon Mitchell uses reasonable safeguards, including contractual requirements with our service providers, to protect your personal information wherever it is located.

Retention of personal information

Dixon Mitchell will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Dixon Mitchell’s legal obligations or enforce or protect Dixon Mitchell’s legal rights, or a longer period required or permitted by applicable law.

Dixon Mitchell will delete or dispose of your personal information, or depersonalize the information, when Dixon Mitchell is no longer required or permitted by applicable law to retain the information for the purposes set out or referenced in this Privacy Policy.

If you ask Dixon Mitchell to delete your information, we will do so within a reasonable period of time. Please note that Dixon Mitchell may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of your information may remain in back-up storage even if you ask Dixon Mitchell to delete it.

Non-personal information

Dixon Mitchell may use your personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Dixon Mitchell may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with your personal information, then Dixon Mitchell will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with your personal information.

Other websites and businesses

Dixon Mitchell’s website and correspondence (including emails) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. Dixon Mitchell has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.

Opting out

In general, when you interact with Dixon Mitchell, you consent to the collection, use, disclosure and retention of personal information as set out in this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

Withdrawing your consent for integral purposes. You may withdraw your consent for purposes that are integral to the provision of our products and services, subject to legal or contractual restrictions and on reasonable notice to Dixon Mitchell, but then you might not be able to proceed with your intended interactions or transactions with Dixon Mitchell or otherwise receive the full benefit of Dixon Mitchell’s products and services.

Withdrawing your consent for additional purposes. Withdrawing your consent for additional purposes that are not integral to the provision of our products and services will not impact the provision of our products and services to you.

You may withdraw your consent to your personal information being used or shared to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you. You can always limit the electronic communications that Dixon Mitchell sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, we may still need to contact you with important information about your product or service.

To withdraw your consent, you may contact Dixon Mitchell’s Privacy Officer at the address noted below.

Who to contact about our Privacy Policy

If you wish to obtain further information about our privacy practices, or to address any matter concerning this Privacy Policy, please contact our Privacy Officer by mail, email, facsimile or telephone:

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