Carte Wealth Management Inc. Privacy Policy

As of January 1, 2004, organizations in Canada that collect, use or disclose personal information in the course of commercial activities will have to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). As required by the legislation, Carte Wealth Management Inc. (Carte Wealth Management) has put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect going forward. These apply to all of the operating companies within the Carte Wealth Management group. To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA.

1. Accountability

Carte Wealth Management has designated a Chief Privacy Officer ("CPO"). The CPO is ultimately responsible for personal information under the control of Carte Wealth Management and is accountable for compliance with the terms and procedures of this Privacy Policy. Any individual that wishes to challenge Carte Wealth Management's procedures, or wishes to make a complaint about Carte Wealth Management's personal-information handling practices they should contact the CPO at 1-800-354-4956. Contact information is set out below. Every complaint will be investigated and where a complaint is found to be justified, Carte Wealth Management will take appropriate measures, including amending our policies and practices, when necessary.

2. Purpose of Collecting Personal Information

Carte Wealth Management will identify the purposes for which it collects the personal information before or when we ask for the information. We will not use or disclose this information for any other purpose other than those for which it was collected.

We collect personal information to ensure that we have all information:



For regulatory purposes, self regulatory organizations, including the Mutual Fund Dealers Association of Canada, and the Canadian Investor Protection Fund (collectively, "SROs") require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:



3. Client Consent

Our consent form is contained in our New Client Application Form. Consent may also be required (when our clients use a product or service subsequent to account opening. An authorized representative of the client (such as a legal guardian or a person having power of attorney) can give consent. A client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The implications of withdrawal are set out in the applicable sections of the New Client Application Form.

4. Limiting Collection

We collect personal information only to the extent that is necessary for the purposes identified above. The personal information is collected using policies and procedures that are fair and lawful.

5. Limiting Use, Disclosure and Retention

Carte Wealth Management will use or disclose personal information only for the reasons it was collected, unless a client provides consent to use or disclose it for another reason, or law requires it. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.

The type of information we collect is limited to the following



This information may be made available to related companies or third-party service providers to fulfil the purposes for which it has been collected.

The information may also be disclosed to SROs, which may use the information to review, monitor, audit or investigate Carte Wealth Management's compliance with securities rules. The information provided to the SROs may, in turn, be reported to other securities regulators, regulated marketplaces, other SROs or law enforcement agencies.

6. Keeping Information Accurate

Carte Wealth Management has a responsibility to ensure that all personal information on file is accurate, complete and up-to-date. Clients may, in writing, request that their personal information be amended as appropriate.

7. Safeguarding Personal Information

Security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. Carte Wealth Management's safeguards vary depending on the sensitivity of the personal information. The highest level of protection is given to the most sensitive personal information.

8. Openness

Carte Wealth Management ensures that clients have access to information regarding the policies and practices we use to manage their personal information. This information is made available in a variety of formats so it is readily available and easy to understand.

9. Access

Clients may request in writing access to their personal information. Carte Wealth Management will inform the client whether the organization holds personal information and provide an account of the use that has been made of this information, as well as identify any third parties to which the information has been disclosed. When a client demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required.

10. Complaints and Suggestions

If you would like to make an inquiry, suggestion or complaint regarding Carte Wealth Management's personal information practices, please contact our Chief Privacy Officer at 1-800-354-4956.