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LEGAL

Privacy Policy

Our Commitment to Privacy

At Raymond James Ltd., we recognize how important personal privacy is to you and to all of our clients. To provide the highest possible level of protection to you, we maintain standards designed to protect your privacy and prevent any misuse of your personal information. We have adopted the following principles and procedures which outline how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.

What is Personal Information?

"Personal information" is any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and website use information, together with your personal references and identification numbers (such as a social insurance number).

Why is Personal Information Collected?

Collecting and retaining personal information about you is essential to our ability to adhere to the "Know Your Client" rule. We also use personal information to protect and administer your accounts, records and funds; to comply with certain laws, regulations and regulatory policies; to help us improve our products and services offered to you and to understand your financial needs. The information we ask for depends on the products or services you request and in most cases is required by law or Canadian securities regulatory bodies. For example, your social insurance number is required for products that earn investment income, in order to comply with the Canada Revenue Agency's income reporting requirements. With your consent, we may also share your personal information where not prohibited by law, within the Raymond James group of companies, for the purposes of referring life insurance, disability insurance, annuities and other specific insurance products and services to you.

How Do We Collect Personal Information About You?

We collect most of our information directly from you. With your consent, we may also obtain personal information about you from third parties such as lenders or credit reporting agencies to give us information on your credit history. We may also contact employers or other personal references to verify information provided by you.

What Are Your Options?

It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from third parties. In many cases you are free to refuse or withdraw your consent at any time. However, if you choose not to provide requested personal information or consents, we may not be able to provide certain or any products or services to you.

To clarify any questions you may have about providing personal information, please feel free to contact your Financial Advisor or the Raymond James Privacy Officer at the contacts set out in this policy. We will be pleased to explain your options and any consequences of refusing or withdrawing your consent.

Privacy on the Internet

We recognize that many clients may have some privacy concerns regarding our services on the Internet. We share your concerns and are committed to protecting the misuse of client information on the web.

You can contribute to the confidentiality of your personal information by not disclosing your designated username and password for access to your Raymond James online account to anyone. Furthermore, remember email over the Internet is generally unencrypted. Therefore, we recommend that you do not send us sensitive or confidential information by ordinary email, as email is generally not secure.

Raymond James uses cookies, a standard technology that installs information on a visitor's computer to permit Raymond James' website to recognize future visits by that computer. Cookies enhance the convenience and use of this website. For example, Raymond James uses the information provided through cookies to recognize you as a previous user of the site, offer customized web pages for your use, track your activity at our website to respond to your needs, and otherwise facilitate your web experience. The cookie is not used to retrieve any information from your computer that you have not already provided. You may choose to disable the cookies option on your browser; however doing so may affect your use of this website and your ability to access certain parts of this website.

Our website may contain links to other websites. Always remember that when you click on to one of those links, you are contacting another website for which Raymond James has no responsibility or control.

Disclosure of Personal Information

In general, Raymond James will not sell, trade or lend your personal information to any third parties unless we have your express permission to do so. However, there are times when disclosure of your personal information is necessary.

In certain circumstances, disclosing information to a third party may be required to help complete a transaction initiated by you or the disclosure is otherwise lawfully permitted or required. For instance, we may disclose information to the authorities to serve a clear public interest and fulfill our public duty - such as to protect against fraud, money laundering or other criminal activity. We may also, from time to time, be requested to disclose information to securities regulatory and securities oversight organizations to which we are subject such as the Investment Industry Regulatory Organization of Canada (IIROC) for the purposes of an audit or investigation relating to specific accounts or our business generally. Also, Raymond James may disclose your personally identifiable information if it believes, in good faith, that disclosure is necessary or advisable to protect its interests.

Sometimes it is necessary to provide personal information about you to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. We will seek agreement from these vendors and service companies to safeguard confidential information about you and your products and services with us.

Protection of Personal Information

There are several ways we strive to protect your personal information:

We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. Our security standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity of our personal information.

We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures and training programs. We take appropriate measures to enforce employee privacy responsibilities.

Our suppliers and agents, as part of their contracts with Raymond James, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required - otherwise we will seek your consent prior to disclosing any information.

We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your Access to Personal Information

You may request access to your personal information on record with Raymond James and information about Raymond James' use and disclosure of that information by contacting the Raymond James Privacy Officer as follows:

Tel: 604 654-7236
Fax: 604 654-7238
Email: privacyofficer@raymondjames.ca
Address: Suite 2100-925 West Georgia Street, Vancouver, BC V6C 3L2

We will ask you for specific details such as branch and account number and we will respond to your request promptly. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Raymond James, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.

Keeping Your Personal Information Accurate

Raymond James attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Resolving Privacy Issues

If you have any questions about privacy and confidentiality - or any concerns about the way a request for personal information was handled, please contact the Raymond James Privacy Officer directly at the contacts listed above.