Confidentiality of Client Information

Virtus Capital Management Inc. (VCMI) earns your trust by adhering to privacy principles in protecting your personal information. The term “personal information” refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, personal information records, identification numbers such as your social insurance number, and your employment information.

Collection and Use of Personal Information

VCMI is required under securities legislation and anti-money laundering legislation to collect information to verify the identity and reputation of clients. VCMI is also required under securities legislation to make a determination to ensure a proposed investment is suitable for you. To assess the suitability of proposed investments, VCMI will obtain information relating to your investment objectives, risk tolerance, investment knowledge, financial situation and circumstances. In providing services to clients, VCMI may be required to use and share personal information with its employees, third party service providers and other financial institutions. When you open an account with us, you authorize us to collect this information during the course of our relationship. Personal information collected by VCMI will be held at the head office of the Firm located at 100 Arbors Lane, Unit B, Woodbridge, Ontario, L4L 3B6.

Sharing Personal Information

VCMI will not use or disclose personal information for purposes other than those for which it was collected except with the consent of the client or as required by law. Personal information will be retained only as long as necessary for these purposes or required by law.

Safeguarding Personal Information

Client personal information is protected by security safeguards that are appropriate to the sensitivity level of the information. All employees of VCMI are responsible for protecting client privacy, confidentiality and security. This obligation remains in effect even after an employee leaves the Firm. VCMI has appropriate controls in place over computer systems in compliance with its Privacy Policy.

VCMI will ensure that third party service providers requiring the use of personal information have appropriate security procedures and controls to protect the personal information of VCMI’s clients.

Updating and Accessing your Personal Information

With some limited exceptions, you have rights to access and update personal information held by VCMI about you. You may inquire about any personal information VCMI may have about you, by sending an email to twolfe@virtuscapitalmgmt.com, by telephone or by mail addressed to Virtus Capital Management Inc., 100 Arbors Lane, Unit B, Woodbridge, Ontario, L4L 3B6. You must include your full name, address and telephone number and a copy of an identity document (such as an ID card or passport). This allow VCMI to verify your identity and whether the Firm has any personal information regarding you. VCMI will contact you if the Firm needs additional information to make that determination.

You may request for VCMI to correct, cancel, and stop processing personal information that VCMI holds about you. If VCMI agrees the personal information is incorrect, or the processing should be stopped, VCMI will correct the personal information or stop the processing. If VCMI does not agree the personal information is incorrect; VCMI will inform you it does not agree. The Firm will record that you consider personal information to be incorrect in the relevant file.

Personal Information Protection and Electronic Documents Act

At Virtus Capital Management Inc., we are committed to providing our client’s with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our client’s, protecting their personal information is one of our highest priorities.

While we have always respected our client’s privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of PIPEDA (Personal Information Protection and Electronic Documents Act).

We will inform our clients’ of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection and Electronic Documents Act, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting client’s personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our client’s personal information and allowing our client’s to request access to, and correction of, their personal information.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Virtus Capital Management Inc.