Doherty & Associates Investment Counsel (“Doherty”) is committed to protecting the privacy of our customers and regards this as an integral part of the service we provide you. Each employee is responsible for ensuring the confidentiality of all personal information they may access. In addition, every employee annually signs a code of conduct, which includes provisions on the protection of personal information, and signs our privacy and corporate information securities policies.

We want you to understand:
• What is meant by personal information;
• Why we collect and use your personal information;
• Why we ask others for information about you;
• How we protect your information;
• Your right to access your information; and
• How your concerns may be addressed.

Personal Information
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and home telephone number.

Why do we need your personal information?
We require your personal information in order to establish a relationship with you, meet our fiduciary obligations, and provide you with the best possible service - the better we know you, the better we can serve you. Your signature, financial history, current financial position, social insurance number, age, investment objectives and risk tolerances, and other similar personal information allow us to:
• Establish your identity;
• Understand and assess your eligibility for our services;
• Understand your needs to ensure we may offer you appropriate services to meet those needs;
• Protect you and us from error and fraud; and
• Comply with the law.

How do we obtain your personal information?
Personal information is obtained primarily from you, although we may also obtain information from other sources with your consent. These other sources may include, but are not limited to, your accountant, financial advisor, other Doherty affiliates, credit bureaus, other financial institutions, etc.

How do we use your personal information?
The information we ask for depends on the product or service you want. For every product and service we require your name, address and certain information to identify you. Before or at the time of collecting any personal information we will advise you of the purpose for the collection. Use of your information may include the following purposes:
• To ensure our records are accurate;
• To establish and administer your account;
• To execute transactions or provide you with the desired service;
• To maintain, store, record and determine your account records;
• To verify previously given information when necessary;
• To provide you and your representatives with account information;
• To support your investment needs;
• To assess your eligibility for a particular service;
• To protect the interests of Doherty, such as the collection of a debt owed; and
• To meet legal, fiduciary and regulatory requirements, for example, Canada Revenue Agency's income reporting requirements.

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Who do we disclose your personal information to?
Your personal information will only be used for the purposes stated at the time of its collection to assist us in providing you with the best possible service. To meet your service requirements, Doherty may also provide your personal information to other third parties. Third parties that may be provided with your personal information include:
• Your financial representative (e.g. accountant);
• Other financial institutions, including credit bureaus;
• Affiliates of Doherty;
• Third-party service providers, who provide administrative and other services to our firm;
• Canadian governments, government agencies and regulators; and
• Any other legally required institutions.

Contracts between Doherty and third-party service providers ensure appropriate controls and protections and are in place at the service provider level to protect your personal information. Our service providers may, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and require access to certain personal information to perform contracted services. In this case, Doherty service providers are responsible for ensuring appropriate security measures and controls are in place to protect your personal information from unauthorized use, loss, theft, alteration and destruction.

Disclosing your personal information when required or permitted by law:
Doherty may be required to provide your personal information in response to a search warrant, order to produce information or any other legally valid demand or inquiry. We may also disclose your personal information to help us collect a debt owed by you.

Obtaining Your Consent
Before we provide you with services you may be required to complete account-opening documentation, including "Know Your Client" information. This documentation identifies how the personal information you provide will be used. You provide your consent when you sign and return this documentation. Also, consent may be obtained verbally at the time you provide us with your personal information. Doherty will not use your personal information without first obtaining your consent, and will only use it for the purposes stated at the time of collection.

Withdrawing your consent:
You may withdraw your consent for the use of your personal information by contacting Doherty at any time. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products Doherty is able to provide to you.

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Why we ask others for information about you:
With your consent, we may obtain information about you from third parties. Obtaining additional information from third parties helps us determine your eligibility for our services. It also gives us access to the information necessary to provide you with the material or assistance you request.

For example, to transfer securities in kind, we need to communicate with your broker and/or custodian. We may also need to assess the value and suitability of securities to be transferred. For this reason, we may contact other financial institutions to provide us with the relevant information. We may also contact other third parties to verify information you have provided.

Access to and accuracy of your personal information:
Upon request, Doherty will provide you with access to your personal information. In addition, we may provide you with a list of third parties to whom your personal information was given. Contact our Privacy Officer by fax or by mail as noted below.

You may request to update your personal information. We may not update or change personal information unless it is necessary to fulfill the purposes for which it was collected.

In certain circumstances Doherty may not be able to provide you with certain information. For example: (i) information containing references to other persons (ii) information containing propriety information confidential to Doherty or its affiliates (iii) information that has been destroyed or (iv) information that is too costly to retrieve.

Where is your personal information kept?
Your personal information may be kept in electronic or paper format in the offices of Doherty, its affiliates or its third party service providers. Your information may also be kept in off-site storage facilities. Our service providers may, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and require access to certain personal information to perform contracted services.

Protecting Your Information
Policies, procedures, guidelines, and safeguards have been put in place at Doherty to ensure your personal information is protected in accordance with all applicable privacy legislation, including the Federal legislation known as the Personal Information Protection and Electronic Documents Act.

We have thorough standards to protect our systems against unauthorized access, use, alteration, duplication, destructions, disclosure, loss or theft.

Our employees, who are bound by our Code of Conduct, Corporate Information Security Policy and Privacy Policy, and our service providers, have access to your personal information to enable them to perform their duties in servicing you. We have guidelines in place to ensure our service providers, agents and affiliates meet our security standards and as part of their contracts with us, they are bound to keep your information confidential.

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.

Security measures including passwords, restricted access to our offices and records, physical access security, and file encryption have been put in place to protect your information against unauthorized access, modification, loss, theft or general misuse.

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Doherty is committed to treating you with respect and consideration in all dealings. From time to time, however, a misunderstanding or error may occur regarding matters of privacy. In such circumstances, Doherty will act diligently to resolve the problem and will contact you as soon as possible within 30 days of our receipt of your complaint.

Requests and Inquiries

If you have any questions or privacy-related requests or concerns, please contact us at:

Doherty & Associates Ltd.
56 Sparks Street, Suite 700
Ottawa, Ontario K1P 1A9

You may want to consider using a method other than email for sensitive personal information.

We will respond to your requests and inquiries in a timely fashion. If speaking with us does not resolve your question or concern, you may contact our Chief Privacy Officer at:

Fax: (613) 238-3957
Mail: Chief Privacy Officer, Doherty & Associates Ltd.
56 Sparks Street, Suite 700
Ottawa, Ontario K1P 1A9

For more information about privacy or, if after contacting the Chief Privacy Officer, your concern has not been resolved, you may contact the Office of the Privacy Commissioner of Canada or the Office of your provincial Privacy Commissioner if you are resident in Quebec, British Columbia or Alberta as follows:

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