Philosophy Surrounding Privacy:
This policy explains how Cormark Securities Inc. ("Cormark") collects, uses, discloses and safeguards personal information provided to us either directly by you or by a third party.

By providing personal information to us or authorizing a third party to provide your personal information to us, you signify your consent to Cormark's collection, use and disclosure of your personal information in accordance with this privacy policy.
For purposes of this privacy policy, "personal information" shall mean any information that can identify an individual directly or through other reasonably available means. Personal information will not include an individual's name, title, business name, business address or business telephone number.

As part of our commitment to treat personal information with respect we operate in accordance with the following ten principles (the "Principles"):

  • Principle 1 - Accountability
  • Principle 2 - Identifying Purposes
  • Principle 3 - Consent
  • Principle 4 - Limiting Collection
  • Principle 5 - Limiting Use, Disclosure and Retention
  • Principle 6 - Accuracy
  • Principle 7 - Safeguarding Client Information
  • Principle 8 - Openness
  • Principle 9 - Client Access
  • Principle 10 - Handling Client Complaints and Suggestions

Principle 1 - Accountability
We will maintain and protect all personal information under our control. We have designated an individual or individuals who is/are accountable for compliance with the Principles.

Principle 2 - Identifying Purposes
Prior to collecting personal information, we inform the individual or source from which it is collected of the purpose for which it will be used.

Principle 3 - Consent
Except where required or permitted by law, we obtain informed consent before collecting, using or disclosing personal information.

Principle 4 - Limiting Collection
The personal information we collect is limited to those details necessary for our business purposes identified at the time of collection.

Principle 5 - Limiting Use, Disclosure and Retention
We will only use or disclose personal information in accordance with the purposes for which it was collected, or when it is required or permitted by law. We will retain personal information only for so long as is required to fulfill the purpose for which it was collected or as required by law.

Principle 6 - Accuracy
We shall make every reasonable effort to ensure that personal information is maintained in an accurate, complete and up-to-date form in view of the purposes for which it will be used.

Principle 7 - Safeguarding Client Information
We shall utilize no less than industry-standard security safeguards to protect personal information that is in our custody.

Principle 8 - Openness
If you would like a copy of our privacy policies we would be more than happy to provide one to you and if you have any questions regarding same, we are more than happy to discuss the merits with you.

Principle 9 - Client Access
Upon your request, we shall inform any individual of: (i) the type of personal information we have collected; (ii) how we have used such personal information in the past, and how we may in the future; and (iii) whether or not we have disclosed such personal information to any third parties (and, if so, to whom). An individual may verify the accuracy and completeness of his/her personal information and may request that it be amended, if appropriate.
Prior to correcting any inaccuracies in connection with the personal information collected, we shall verify the identity of the individual making the request.

Principle 10 - Handling Client Complaints and Suggestions
Clients may direct any questions or inquiries with respect to the Principles or about our information-handling practices by contacting:

Julie Eisenstat, Managing Director, Chief Compliance Officer
Cormark Securities Inc.
Royal Bank Plaza, South Tower
200 Bay Street, Suite 2800, P.O. Box 63
Toronto, Ontario, Canada
M5J 2J2

Phone: (416) 943-6494
Fax: (416) 943-6492

Why We Gather Personal Information:
At Cormark, we gather and use personal information in accordance with all applicable securities legislation, regulations, rules and policies, as well as the rules of any self-regulatory agency (collectively, the "Securities Laws") applicable to Cormark.
We only use personal information for the purposes that we have disclosed. If for any reason personal information is required to fulfill a different purpose, we will obtain consent before we proceed.

Types of Information We Collect:
The collection, use and disclosure of information by Cormark may include, but is not limited to, the following:
  • Surveillance of trading-related activity;
  • Sales, financial compliance, trading desk review and other regulatory audits;
  • Investigation of potential regulatory and statutory violations;
  • Regulatory databases;
  • Enforcement or disciplinary proceedings;
  • Reporting to securities regulators; and
  • Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction with any of the foregoing.

The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may result in limiting our ability to provide you with the services or products you requested.

How We Collect Such Personal Information:
We may gather such personal information from you in person, over the telephone or by corresponding with you via mail, facsimile, the Internet, or from third parties who have your authority to disclose such personal information to us.

Cormark's Website:
When you visit our website, information is not collected that could identify you personally unless you choose to provide it voluntarily. You are welcome to browse the website at any time, anonymously and privately without revealing any personal or financial information about yourself.

When Information May be Disclosed to Outside Parties:
Except as specifically provided for in this privacy policy and as required by Securities Laws and other governmental legislation, we do not disclose any personal information to third parties.
The type of information we are legally required to disclose may relate to criminal investigations or government tax-reporting requirements. In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.
There are some situations where we are legally permitted to disclose personal information, such as employing reasonable and legal methods to enforce our rights or to investigate suspicion of illegal activities.

Our Employees and your Personal Information:
In the course of daily operations, access to private, sensitive and confidential or personal information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it.
As a condition of their employment, all employees of Cormark are required to abide by the privacy standards we have established. Employees are informed about the importance of privacy and they are required to agree to Cormark's Policy and Procedure Manual that prohibits the disclosure of any customer information to unauthorized individuals or parties.
Unauthorized access to and/or disclosure of personal information by an employee of Cormark is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

How We Safeguard Your Information:
We use industry-standard technologies and maintain current security standards to ensure that personal information is protected against unauthorized access, disclosure, inappropriate alteration or misuse.
Electronic customer files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked filing cabinets. Access is also restricted.

We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised. Our website uses Secure Socket Layer (SSL) and 128-bit encryption technologies to enhance security when you visit the secured areas of these sites. SSL is the industry-standard tool for protecting and maintaining the security of message transmissions over the Internet. When you access your accounts or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.

To safeguard against unauthorized access to your accounts, you are required to "sign-on" using a user ID and a password to certain secured areas of Cormark's website. Both user ID and password are encrypted when sent over the Internet. If you are unable to provide the correct password, you will not be able to access these sections.

Accessing and Amending Your Information:
You have the right to access, verify and amend the information held in your personal files. To help us keep your personal information up to date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.
Before Cormark is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will endeavour to respond within an appropriate timeframe.

Updating this Privacy Policy:
Any changes to our privacy policy and information-handling practices will be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this privacy policy.

Web Sites Governed by this Privacy Policy:
The website that is governed by the provisions and practices stated in this privacy policy is:
Cormark's website may contain links to other third-party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave the Cormark website. Additionally, we are not responsible for the privacy practices employed by other third-party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.



Julie Eisenstat
Managing Director,
Chief Compliance Officer
Direct: (416) 943-6494
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