Privacy Policy

As of January 1, 2004, organizations in Canada that collect, use or disclose personal information in the course of commercial activities will have to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA").

As required by the legislation, SEAMARK Asset Management Ltd. has put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect going forward. To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA.

SEAMARK has designated a Chief Privacy Officer ("CPO"). The CPO is ultimately responsible for personal information under the control of SEAMARK and is accountable for compliance with the terms and procedures of this Privacy Policy.

SEAMARK will identify the purposes for which it collects the personal information before or when we ask for the information, and will not use or disclose this information for any other purpose other than those for which it was collected.

SEAMARK collects personal information to properly discharge regulatory responsibilities with respect to suitability assessment and other securities rules, to discharge obligations under federal anti-money laundering and suppression of terrorism legislation, and to meet obligations as a member of various self-regulatory organizations.

The prior knowledge and permission of the individual are required for the collection, use or disclosure of your personal information.

SEAMARK collects personal information only to the extent that is necessary for the purposes identified, using policies and procedures that are fair and lawful. The type of information collected is limited to the fundamental "know your client" information contained in the SEAMARK New Client Application Form and other information required to meet obligations imposed by securities regulations, SRO rules or other laws.

Personal information will only be used or disclosed for the reasons it was collected, unless a client provides consent to use or disclose it for another reason, or law requires it. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.

SEAMARK has a responsibility to ensure that all personal information on file is accurate, complete and up-to-date.

Security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. Safeguards vary depending on the sensitivity of the personal information, and the highest level of protection is given to the most sensitive personal information.

Information regarding the policies and practices used to manage clients' personal information is made available in a variety of formats so it is readily available and easy to understand.

Clients may request in writing access to their personal information. SEAMARK will inform the client whether the organization holds personal information, provide an account of the use that has been made of this information, and identify any third parties to which the information has been disclosed.

Any individual that wishes to challenge SEAMARK's procedures or wishes to make a complaint about SEAMARK's personal-information handling practices should contact the CPO at 1-888-303-5055 or by e-mail. Every complaint will be investigated and where a complaint is found to be justified, SEAMARK will take appropriate measures, including amending our policies and practices, when necessary.

If you would like to make an inquiry, suggestion or complaint regarding SEAMARK's personal information practices, you can contact the Chief Privacy Officer at 1-888-303-5055 or by e-mail.