PRIVACY PLAN

At Integrated Asset Management Corp. (“IAM”) we recognize that all personal information is private and confidential. IAM’s Privacy Plan (“Privacy Plan”) governs IAM’s collection, use and disclosure of personal information. It is the intention of IAM, by way of this Privacy Plan, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Document Act (PIPEDA).

IAM recognizes the following key principles of PIPEDA:

Accountability:

IAM acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all IAM staff of the need to use the utmost discretion when dealing with client information. IAM’s privacy officer has the responsibility to carefully analyze and alter collection procedures both on a preliminary and ongoing basis to assure maximum privacy protection.

Purpose:

IAM will only use client information for the purposes identified either before or at the time of collection. It is our policy that we will not sell your information.

Consent:

IAM will only use client information for identified purposes and if the information is required for any new use, IAM will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by yourself or your authorized representative.

Collection:

IAM will only collect personal information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation such as, the Money Laundering (Terrorist Financing) Act. IAM’s staff will do their best to explain why collection of information is necessary in a clear and informative fashion.

Use, Disclosure and Retention:

IAM will only retain personal information for as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individual’s personal information is no longer required, IAM will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that information cannot be found or used by an unauthorized party.

Accuracy:

IAM strives to maintain accurate client information which not only help us provide better customer service but also minimizes the potential misuse of personal information.

Safeguards:

IAM understands the importance of protecting personal information and therefore, implements a number of safeguards against unauthorized access or improper disclosure. For example, IAM’s computer network, employee computers, laptops, and phone message centers are all password protected. In addition, filing cabinet units and storage rooms containing personal information are locked and can only be accessed by designated individuals. General entry to our offices is secured and cannot be accessed by unauthorized personnel without permission.

Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continual maintenance and periodic review of our Privacy Plan and procedures. IAM employees are subject to a strict code of conduct when it comes to your personal information.

Directness:

At IAM we make our best effort to inform clients of our policies and procedures and to explain how we manage personal information. Our Privacy Plan can be found on our website or can be requested via email or phone. If you have additional questions or concerns, our privacy officer will help you understand our procedures and policies.

Access:

When requested and supported by sufficient identity information, IAM will provide you with your personal information as maintained in your client files. We recognize your right to your own information, how it is used and to whom it is disclosed.

If an error or discrepancy is found in your personal information, we will act efficiently (in less than thirty days) to correct the mistake. An extension will only be applied if the request will unreasonably interfere with our business affairs.

Complaints and Recourse:

IAM’s privacy officer will deal with any complaints or conflicts arising in regards to the collection, use and disclosure of personal information. In order to adequately address the complaint, all details will be recorded and a file will be created. All individuals involved will be notified of an enquiry into the complaint. Once a decision of recourse has been determined, all parties involved will be informed of the outcome. IAM’s privacy officer can provide you with a more complete description of the recourse process. Individuals who are not satisfied with IAM’s recourse procedure can bring the complaint to the attention of the Federal Privacy Commissioner.

The measures outlined in this Privacy Plan in order to abide by PIPEDA’s key principles are intended to provide clients with comfort that IAM’s staff regards personal information with the utmost importance. The Privacy Plan is also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their information.

For more information please contact IAM’s privacy officer, Tom Felkai at 416.933.8263 or tfelkai@iamgroup.ca

A complete version of Personal Information Protection and Electronic Document Act (PIPEDA) can be found on the Department of Justice website at:

http://laws.justice.gc.ca/en/P-8.6/text.html

Integrated Asset Management Corp.
70 University Avenue, Suite 1200
Toronto, Ontario
M5J 2M4
Tel: 416.360.7667
Fax: 416.360.7446
www.iamgroup.ca