We collect and use your personal information to evaluate your investment, insurance and financial solution needs, to assess which of our products and services will meet your needs, and to effectively manage your financial dealings with us.

To further enhance our protection of your personal information we will implement the federal and provincial privacy legislation; Canadian Investment Consultants will implement the following privacy policy effective January 1, 2004:

Protecting Privacy

• We will keep your personal and business information confidential
• We will allow you to control how we collect, use and disclose your personal information by first acquiring your informed consent
• We will allow you access to the personal information we have about you
• We will not sell your information to third parties

Accountability
We will be responsible for protecting all of your personal information that is in our control or is transferred to third parties with your consent. Our Privacy Officer will be accountable for ensuring our compliance with the principles described in this policy and applicable federal or provincial privacy legislation.

Identifying Purposes
The purpose(s) for which your information is being collected will be identified, explained, and documented at the time of collection. In general, Canadian Investment Consultants is a financial planning firm providing products and services which allow you to plan for, accumulate and protect wealth.

Consent
We will obtain your consent prior to collecting, using and disclosing your personal information. Your informed consent (expressed or implied) will be required for the collection, use or disclosure of personal information (except where permitted or mandated by law).

Limited Collection
We will only collect personal information that is needed for the specific purposes of servicing your accounts and investment or financial needs.

Disclosure and Retention
We will use and disclose your information only for the purposes required to provide those financial services and products, or acquire those products from other manufacturers, or when it is mandated or permitted by law. We will retain your information only for as long as it is necessary.

Accuracy
We will keep your information accurate, complete and up to date as is reasonably possible or as required by regulation.

Safeguards
We will safeguard your information with appropriate protective and security measures, both physical and technological.

Disclosure and Retention
We will use and disclose your information only for the purposes we will identify, or when it is mandated or permitted by law. We will retain your information only for as long as it is necessary.

Openness
Within a reasonable time after receipt of your written request, we will provide you with specific information on our personal information management policies and procedures. We will provide you with information that is easily understandable and we encourage you to contact us with any questions. For additional information you can access the federal copy of the of the privacy legislation from the government website www.privcom.gc.ca/legislation/index_e.asp.

Access
You will have the right to review any and all personal information we have about you, except where we are required or permitted by federal or provincial law to deny you access for a specific reason. We encourage you to verify the accuracy of your personal information and inform us in a timely manner of any changes in appropriate information affecting your financial plans or corrections that need to be made.

Concerns
If you have any concerns about the accuracy or use of your personal information you will be able to request that our Privacy Officer investigate the matter and respond to your concerns within a reasonable time.

1. What is personal information?
“Personal information" can generally be defined as information that identifies you as an individual. It includes, but is not limited to:

• Your name and legal land address
• Your age and gender
• Your financial history
• Your identification numbers including your social insurance number
• Your employment history

2. Why we ask for your personal information?
We will only collect the information we need to provide you with our services and products. The purpose(s) for using your personal information will be explained to you so that you may provide us with informed consent.

To better serve you we may ask for your personal information for the following purposes:

• To protect you and Canadian Investment Consultants from identity theft and fraud
• To assess which products and services are most suitable for your investment needs
• To better understand and serve your unique financial situation and investment needs, financial, retirement and insurance needs
• To set up and manage products and services you have requested
• To register or identify products and services provided through Canadian Investment Consultants by a third party, such as a fund company
• To comply with federal and provincial legislation

You will have the option of not providing us with personal information. However, we may not be able to provide you with the product or service you requested or that we have offered to you.

We will ensure you are aware of why we need to collect, use or disclose your personal information when you apply for any of our products or services. If we have a new purpose for using your personal information we will again seek your informed consent.

3. Where will we collect personal information from?
A majority of the information we will collect comes directly from your interview meetings with a financial advisor to formulate a financial plan and from application for our products or services. We will only request information that is applicable for the financial services that apply to you.

4. Who will we disclose your personal information to?
Generally, we will not disclose your personal information without your prior and informed consent.

With your prior consent we may disclose your personal information to other third parties outside Canadian Investment Consultants who assist us in serving your best interests (including your financial institution). We will only disclose to these third parties the information that is necessary to serve your investment needs. We will select third party service providers that use comparable safeguard standards to our own.

However, the law permits or requires us to collect, use and disclose personal information without your consent in certain circumstances such as:

• To assist investigative authorities or the courts
• To protect the public interest (e.g. to combat fraud or money laundering)
• To protect our interests
• To protect your interests when your consent cannot be obtained in a timely manner

We may also share your information with self-regulatory authorities when Canadian Investment Consultants is so required. These self regulatory organizations, (such as the Investment Dealers Association, Market Regulation Services Inc., the Mutual Fund Dealers Association and the Canadian Investor Protection Fund) require access to personal information for regulatory purposes. This includes: surveillance of trading-related activity, sales, financial compliance 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 other authorities.

As Canadian Investment Consultants continues to grow, we may expand or sell our businesses. The law permits us to disclose your personal information in such a business transaction. The receiving party must collect, use, and disclose the information only for the purposes for which you initially granted your consent to us. Such party will also be subject to the principles of our Privacy Policy and the relevant legislation protecting your privacy.

5. Will you be able to withdraw your consent?
You will be able to contact us to withdraw your consent at any time provided there are no contractual or other legal requirements limiting such withdrawal. Your Investment Advisor or our Privacy officer will explain your options and any consequences of withdrawing your consent.

If you do not want us to share information with any third party service providers who assist us in servicing your account, please contact us at any time.

If you do not consent to certain uses of your personal information, or if your consent is properly and legally withdrawn, we may not be able to provide you with certain products or services. We will explain the consequences to help with your decision.

6. How will we safeguard your personal information?
We will use a variety of security measures to protect your personal and investment information including:

• Locked file cabinets and offices
• Electronic security
• Secured retention and destruction of information
• Restricting employee access to files and data centers

Our Privacy Officer will be responsible for the review and adjustment of our security procedures. We restrict access to your personal information to the employees and agents who service your accounts. Our Privacy Officer will ensure our Privacy Policy is properly administered and that our security measures are up to date and effective.

7. How will you be able to find out what personal information we have collected about you?
You will be able to make a written request to know what personal information we have concerning you. You will have to provide us with a written request that has sufficient detail to enable us, with reasonable effort, to identify you and your personal information. We will generally respond within thirty days with the information you have requested or with a detailed response explaining why that information is withheld.

8. How will you be able to change or correct your personal information?
If you need to change your personal information or you become aware of an error in the personal information we have on file for you, please contact your Investment Advisor. You will have to provide us with a written request that has sufficient detail to enable us, with reasonable effort, to identify you and the personal information or correction being sought.

We will correct inaccurate or incomplete information within a reasonable time and notify you when such changes are completed. There is no charge for correcting your information. We will also ensure that any third parties that have received your personal information from us are notified of such changes or corrections. If there is any information that is still in dispute, we will make a note on your file.

9. How long will we keep your personal information?
Your personal information will be kept on file for as long as we need it to provide you with the products or services you have requested and to meet legal or regulatory requirements. The length of time your personal information is retained may vary according to the product or service and the sensitivity and nature of the information. This period may extend beyond the termination of our relationship for as long as it is reasonably necessary for legal or business purposes. After your information is no longer needed for the specific purposes identified to you, we will destroy, delete, erase or convert your personal information to an anonymous form.

10. Who will you be able to contact if you have any questions regarding our privacy policy?
If you have any questions or concerns about the way your personal information is collected, used, or disclosed by Canadian Investment Consultants (888)., you will be able to contact our Privacy Officer at:

Privacy Officer
Canadian Investment Consultants
60 Columbia Way
Suite 900
Markham, Ontario
L3R 0C9
Phone: (905)709-7911
Fax: (905) 709-7022

Our complaint process will be in accordance with relevant federal and provincial privacy legislation and will be fair, impartial and confidential.