PRIVACY POLICY

Overview and scope

Veritas Investment Research Corp. ("Veritas") recognizes the importance of an individual's right to privacy and is committed to protecting the personal information that it collects, uses and discloses in providing investment advisory services and operating its business. This privacy policy ("Privacy Policy") outlines how Veritas manages the personal information and safeguards the privacy of its clients, the users of its website ("Website") and other individuals (collectively, "you").

This Privacy Policy does not apply to personal information about Veritas employment candidates or Veritas employees, partners, or contracted staff, which is dealt with separately. If you apply to Veritas for a job, Veritas will need to consider your personal information as part of its application review process. Veritas normally retains information from candidates after a decision has been made, unless you ask it not to retain the information. If Veritas offers you a job, which you accept, the information will be retained in accordance with its privacy procedures for employee records.

Privacy rights and accountability

All Ontario businesses engaged in commercial activities must comply with Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"). PIPEDA gives you rights concerning the privacy of your personal information. Veritas is responsible for the personal information it collects and holds. To ensure this accountability, Veritas has developed this Privacy Policy and has trained its partners and employees in respect of it.

Acceptance of Privacy Policy

By submitting your personal information to Veritas, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, do not provide your personal information to Veritas. Of course, certain services can only be offered to you if you provide personal information to Veritas, and therefore Veritas may not be able to offer you those services if you choose not to provide it with required personal information.

Personal information

PIPEDA defines "personal information" broadly as any information about an identifiable individual. Generally speaking, personal information does not include "business contact information" such as the name, job title, business address, or business telephone number of an employee of an organization.

Consent

Veritas obtains your consent before it collects, uses, or discloses your personal information. Normally, Veritas asks for your consent in writing, but in some circumstances, it may accept your oral consent. Sometimes, your consent may be implied through your conduct with Veritas.

Subject to legal and contractual requirements and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Veritas' Privacy Officer (see end of this Privacy Policy for contact information). The period of reasonable notice will vary depending on the nature of the information and its purpose.

If you provide Veritas or its service providers and agents with personal information of another individual, you represent and warrant that you have all necessary authority and/or have obtained all necessary consents from such person to enable Veritas to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

There may be circumstances where you have provided personal information for an identified purpose, and Veritas later needs to use that information for a different purpose. In such circumstances, Veritas will seek your consent to use the information for the new purpose.

Why Veritas collects, uses and discloses your personal information

Veritas collects, uses and discloses your personal information for the purposes identified at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes:

to provide you with investment advisory/research services, including more specifically:
- sharing your personal information with third parties for the purpose of providing investment advisory/research services in the context of client updates regulatory or otherwise;
to manage its business and maintain commercial relationships with you;
to evaluate your satisfaction and conduct market research;
to maintain and develop its systems and databases for managing documents and knowledge;
to detect and protect against error, negligence, breach of contract, fraud, theft and any other illegal activity, and where necessary to meet its insurance requirements;
to send you information about Veritas' services and about developments in markets, to invite you to Veritas events and to communicate with you generally;
as permitted by, and to comply with, applicable legal or regulatory requirements; and
to further any other purpose for which it has your consent.

Veritas may also ask for and collect your personal information at certain points throughout the Website. In addition to the information you knowingly provide, Veritas collects the domain names and IP addresses of its visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. This data is used to more efficiently operate Veritas' business, promote our services and administer the Website. As well, Veritas collects any information you may choose to provide in your communications with it.

How Veritas collects, uses and discloses your personal information

Veritas collects your personal information by fair and lawful means and, wherever appropriate, directly from you. Wherever possible, Veritas limits the amount of personal information it collects, uses or discloses to that necessary and appropriate to provide its investment advisory/research services and to operate Veritas' business.

When Veritas discloses your personal information

Veritas discloses your personal information only as described in this Privacy Policy, with your consent, or as otherwise permitted or required by law. Under certain circumstances and consistent with PIPEDA, Veritas will disclose your personal information, including:

when disclosure to third parties assists it in providing you the investment advisory/research services that you have requested, including engaging record keeping, calculation of net asset value, and fund accounting;
if Veritas engages a third party to provide administrative services to it (like computer back-up services or archival file storage) and the third party is bound by this Privacy Policy;
when necessary to collect outstanding accounts;
when necessary to comply with court orders, regulatory rules, or to satisfy Veritas' insurance requirements;
in connection with a business transaction involving Veritas; and
when Veritas reasonably believes that a third party requesting your personal information is your agent.

Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where Veritas may or must disclose information without your consent, in accordance with applicable law. For example, Veritas may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Veritas has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to protect Veritas' rights and property. Where obliged or permitted to disclose information without consent, Veritas will not disclose more information than is required for the purpose that obligates or permits it to disclose such information.

Disclosure of your personal information to third party service providers

When Veritas transfers your personal information to a third party to provide administrative and other services, it uses appropriate measures to ensure that the third party will only use your personal information to perform the services Veritas has specified. The increasingly global nature of Veritas' business sometimes requires it to use administrative service providers who may be located in the United States or elsewhere outside of Canada. Accordingly, your personal information may be transferred outside of Canada and if so, it will be subject to the legal requirements of the applicable foreign jurisdictions, including local requirements to disclose information to courts, law enforcement and national security authorities.

To the extent Veritas enters into arrangements with service providers, agents and contractors to store, handle or process personal information on its behalf, such as for data processing, document storage software support and office services, Veritas' policy is to require such parties by contractual or other means to provide comparable privacy protection while the information is processed or handled by them.

Where Veritas stores your personal information

Your personal information is stored in secured locations and on servers controlled by Veritas, located either at our offices or at the offices of our service providers. Your personal information may be processed, accessed and/or stored in Canada or another jurisdiction, and will be subject to the laws of that jurisdiction.

Security of your personal information

Veritas uses the standard safeguards of the financial services industry to protect the security of personal information in its possession, including physical, organizational and technological measures. These measures include:

premises security;
restricted access to files that contain personal information;
technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
internal password and security policies.

However, no method of transmitting or storing information is completely secure. While Veritas takes appropriate measures to protect your personal information, there is always a risk that it may be lost, intercepted or misused. Veritas may exchange electronic versions of documents and e-mails with you using commercially available software that may be vulnerable to attack by viruses and other destructive electronic programs. Veritas cannot guarantee that all communications and documents sent via e-mail will always be received, or that such communications and documents will always be virus free. Veritas makes no warranty with respect to the integrity of any electronic communications between Veritas and you or with respect to the security of any such communication and you consent to Veritas' exchange of electronic communications, including confidential documents, that are unencrypted.

Accessing your personal information

You may ask for access to any personal information Veritas holds about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to Veritas' normal professional and disbursement fees.

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

Updating the accuracy of your personal information

You can help Veritas maintain the accuracy of your personal information by notifying Veritas of any changes to your personal information. If Veritas holds information about you and you advise us that it is not accurate, complete and up-to-date, Veritas will take reasonable steps to correct it.

Being denied access to your personal information

Your rights to access your personal information are not absolute. Veritas may deny access when:

denial of access is required or authorized by law;
information relates to existing or anticipated legal proceedings against you;
granting you access would have an unreasonable impact on other people's privacy;
protecting Veritas' rights and property; and
your request is frivolous or vexatious.

If Veritas denies your request for access to your personal information, or refuses a request to correct information, Veritas will explain why.

Personal information and Website

Cookies

The Website may use "cookies", a technology that installs information on a Website user's computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. The use of cookie technology is common on the Internet, and many Internet browsers are initially set to accept cookies automatically.

If you would prefer not to accept cookies, you can set your Internet browser to notify you when your computer is receiving a cookie or to refuse cookies automatically. To readjust your Internet browser’s cookie options, please refer to the instruction documentation of your particular browser or seek online assistance.

Like many other websites, the Website may make use of "per session" and "persistent" cookie technology. Per session cookies track information during an open session and are stored only temporarily in your computer’s memory. Persistent cookies are deposited on a visitor's computer until they expire or until the visitor deletes the cookies. Information from these cookies help Veritas analyze traffic patterns to the Website, including the total number of visitors, the geographical location of the visitor, and the types of Internet browsers (e.g., Google Chrome or Internet Explorer) and operating systems (e.g., Windows or Macintosh) that the Website's visitors use. Veritas uses this information to facilitate and enhance your online visits. Veritas does not cross-reference this information with any type of personal information that is voluntarily offered through the Website.

Traffic patterns

On the Website, like most other commercial websites, Veritas may monitor traffic patterns, site usage and related site information. This is done in order to optimise its web service. Veritas may provide aggregated information to third parties, but these statistics do not include any personal information.

Google Analytics

The Website uses Google Analytics to collect information, in an anonymous form, about how visitors use the Website, including the number of visitors to the Website and the pages they have visited. Veritas uses such information to compile reports and to help it improve the Website. By using the Website, you agree to such use of Google Analytics. Should you wish to opt-out of the use of Google Analytics, please click on the following link: https://tools.google.com/dlpage/gaoptout

Google AdWords

The Website may also use third party vendor re-marketing tracking cookies, including the Google AdWords tracking cookie. This means Veritas may show ads to you across the Internet, specifically on the Google Display Network. Veritas does not collect personal information through the use of Google's or any other third party remarketing system. Rather, the third party vendors will place cookies on web browsers in order to serve ads based on past visits to the Website. This allows Veritas to continue to market its services to those who have shown interest in Veritas.

You may opt out of Google's use of cookies by visiting Google's Ads Settings. Also, you can opt out of other participating third party vendors' use of remarketing cookies by visiting the Digital Advertising Alliance of Canada's AdChoices Program opt-out tool page at: http://youradchoices.ca/choices/

Tracking information

In addition, Veritas may use non-personal information to create aggregate tracking information reports regarding Website user demographics and Website traffic patterns. None of the tracking information in the reports can be connected to the identities or other personal information of individual users. Veritas also may link tracking information with Website users' personal information. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Privacy Policy, and in accordance with the law.

Link to Third Party Websites and Social Media Platforms

The Website may present links to other websites. You should be aware that operators of linked websites may also collect your personal information and information generated through the use of cookies when you link to their websites. Veritas is not responsible for how such third parties collect, use or disclose your personal information, so it is important to review their privacy policies before providing them with your personal information.

Our Website may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Website.

Serious privacy breach notifications

Veritas will notify you of any breach of the security safeguards involving your personal information under Veritas' control if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to you (a "Serious Privacy Breach"). This notice will be conspicuous and given to you in the manner prescribed under PIPEDA as soon as feasible after Veritas determines that such a breach has occurred.

Likewise, Veritas will report any Serious Privacy Breach to the Office of the Privacy Commissioner of Canada in the manner prescribed under PIPEDA as soon as feasible after Veritas determines that such a breach has occurred.

Changes to Privacy Policy

Privacy laws are rapidly evolving and, as a result, Veritas reserves the right to change this Privacy Policy without notice and at any time. The most current version of this Privacy Policy is posted on the Website. Regardless of any changes Veritas makes to this Privacy Policy, Veritas will only use your personal information in accordance with the version of the Privacy Policy in place at the time you provided your information, or as otherwise required or permitted by law, unless you have given your express consent for Veritas to do otherwise.

Privacy Officer and requests, questions and challenges under Privacy Policy

Individual clients may review any personal information concerning themselves Veritas has on file in its offices by contacting their Veritas advisor or Veritas' Privacy Officer at the address below. Individuals who are not clients may request access to personal information Veritas holds about them by written request to:

Josie Monasterolo, Privacy Officer,
Veritas Investment Research Corp.,
100 Wellington Street West
Toronto, ON M5K 1E7
jmonasterolo@veritascorp.com
(416)866.8783

If you are not satisfied with Veritas' response, the Privacy Commissioner of Canada can be reached at:

112 Kent Street
Place du Ville Tower, 3rd Floor
Ottawa, Ontario K1A 1H3
1.800.282.1376

Effective date

This Privacy Policy was last updated and is effective as of September 6, 2022.