Fundserv Inc. (“Fundserv”) is a leading provider of electronic business services to the Canadian investment fund industry. This Privacy Policy describes Fundserv’s management of “Personal Information” (as defined below) and provides direction on how to obtain additional information about its Personal Information management practices.

This Privacy Policy may be changed from time to time in response to changes in the law and/or our operations and in this regard, the date on which this Privacy Policy was last amended will always appear at the top of the Policy for ease of reference. Please review the Privacy Policy if it has been modified since your last communication with Fundserv or visit to its website (“Web site”). By submitting your Personal Information to Fundserv after this Privacy Policy has been modified, you will be agreeing to the collection, use and disclosure of your Personal Information in accordance with the modified Policy.

By submitting Personal Information relating to someone other than yourself to Fundserv, you will be representing to Fundserv and Fundserv will rely on your representation, that you have consent or are otherwise authorized to disclose the Personal Information to us.

1. What is Personal Information?
   1. Fundserv is subject to the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) when it collects, uses or discloses Personal Information for its own commercial activities. Under PIPEDA and for the purposes of this Privacy Policy, personal information means information about an identifiable individual, with certain exceptions for information about an individual in his or her professional capacity, such as business address and business telephone number (“Personal Information”).
2. What Personal Information does Fundserv collect and how is it used?
   1. Fundserv collects and uses Personal Information of employees and representatives of Customers and potential Customers who provide their information to Fundserv in connection with a request for information, materials or services. Fundserv uses Personal Information to deliver publications and other materials produced by Fundserv, to register individuals for Fundserv events, and to respond to inquiries.
   2. By providing your Personal Information to Fundserv, you will be understood to be consenting to its collection, use and disclosure in accordance with this Privacy Policy for the purpose of responding to your inquiries and delivering materials and/or services that you request.
   3. You may withdraw your consent to the continued use of your Personal Information by contacting Fundserv’s Privacy Officer, as indicated below. Fundserv will be unable to provide you with information, materials and/or services for which Personal Information is required if you withdraw your consent and you are invited to consult our Privacy Officer about the implications before doing so.Fundserv as a Service Provider
   4. Fundserv provides services to organizations operating in the industry (“Customers”), which services include the use of an electronic network (the “Network”) to transmit information about Customers’ clients (“Investors”) for Customers’ purposes.
   5. In regard to its provision of the Network, Fundserv is a service provider to Customers and accesses and uses Personal Information of Investors transmitted through the Network only to the extent required to provide the Network and related maintenance and support services to Customers. For greater certainty, fundserv does not collect Personal Information of Investors, but provides the means by which such information is transmitted by Customers for purposes agreed to between Customers and Investors. Any requirement for notice or consent in regard to the use and disclosure of such Personal Information is the responsibility of Customer.
3. Does Fundserv disclose Personal Information?
   1. Fundserv may use and disclose Personal Information in connection with a contemplated or actual reorganization of its business or an assignment, sale or other transaction involving the sale of all or part of its business or assets, including for the purpose of permitting the parties considering the transaction to conduct the due diligence required to determine whether to proceed. In any assignment or sale, the assignee or purchaser may use and disclose the Personal Information it receives for substantially the same purposes as described in this Privacy Policy without confirming your consent. Fundserv may also disclose Personal Information for purposes related to its insurance coverage and will disclose Personal Information where required or permitted by law to do so, for example in connection with law enforcement activities or under the authority of a court order.
4. Does Fundserv outsource functions requiring access to Personal Information?
   1. Fundserv outsources some functions to third party service providers, including some functions that require access to Personal Information. Fundserv requires third party service providers to limit their access to Personal Information to that required to provide their services and to provide a level of protection for Personal Information that is commensurate to that provided by Fundserv. Some of the third party service providers retained by Fundserv operate in countries other than Canada, and in these circumstances, Personal Information accessible to the service provider will be subject to the laws in the service provider’s country of operation as well as PIPEDA, and may be disclosed pursuant to the laws of that country. Please direct any questions or concerns you have about the countries in which our service providers process your Personal Information to our Privacy Officer, whose contact information is provided below.
5. What security safeguards does fundserv have in place to protect Personal Information?
   1. fundserv uses a variety of security safeguards to protect Personal Information, including policies and procedures establishing who may access Personal Information and for what purposes, technological safeguards that limit access to Fundserv electronic resources and protect Personal Information in transit, such as encryption, and physical barriers to access to Fundserv facilities and areas within its facilities. Fundserv employees receive training about and are held accountable for compliance with this Privacy Policy and the Fundserv privacy practices by which it is implemented in our operations.
   2. In addition to Fundserv’s internal security measures, Fundserv annually engages external auditors to review its security policies and practices and other safeguards. For Customers who use the Network, a copy of the results of Fundserv’s service bureau audit, addressing, among other things, privacy, security and data integrity, is available upon request to Fundserv’s Privacy Officer.
6. How long does Fundserv retain Personal Information?
   1. Fundserv retains Personal information only as long as necessary given the purpose for which Fundserv collected the information or as required by law. Fundserv destroys or removes Personal Information after that time, and where the latter, may retain the resulting non-personal information for its business purposes.
7. Does the Fundserv Web site collect information automatically?
   1. The Web site uses cookies and other tools that automatically collect information about computers that connect to the Web site, such as the Internet Protocol (IP) address, platform and browser version. Fundserv uses this information to assess visitor interest in various features and pages of the Web site and to create or amend Web site content in response. Fundserv does not share such information with third parties. For more information regarding our use of cookies, please read our Cookie Policy.
8. Who can you contact with questions about this Privacy Policy?
   1. Fundserv strives to maintain the accuracy of Personal Information in its records and to this end, requests that you notify us if your Personal Information changes. Fundserv will provide you with access to your Personal Information in our records, except in the limited circumstances established by law.
   2. Where a request is made for access to or the correction of Personal Information that has been collected by a Customer and to which Fundserv only has access in its capacity as a service provider (for example, the Personal Information of Investors), Fundserv will transfer the request to the applicable Customer.
   3. If you are aware of any inaccuracies in Personal Information that you have provided to Fundserv, or you would like to obtain access to such Personal Information, or have comments or questions about Fundserv’s privacy practices in general or its management of your Personal Information specifically, you may contact Fundserv’s Privacy Officer in writing at:

Fundserv Inc.
333 Bay St., Suite 2600
Toronto, ON
M5H 2R2 Canada

Attention: Privacy Officer
E-mail: privacyofficer@fundserv.com

Cookie Policy

Introduction
In addition to any information that you choose to submit to us, we or selected third parties may use a variety of technologies that store or access information already stored on your computer or mobile device (each, a “device”) whenever you visit or interact with our website.

The Information Collection Technologies
We use cookies to store or access information already stored on your device. A cookie is a text file placed on a device when a user visits a website. Cookies can be temporary (e.g., session) or permanent (e.g., persistent). They can also be first party (e.g., placed by us) or third party (e.g., placed by a third party analytics provider).

Information About Why We Use These Technologies
We use the technologies above for the following purposes:

We use Google Tag Manager as part of the Google Analytics service, to analyze your browsing behaviour on our website. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser.

Your Consent and Your Right to Refuse the Use of Information Collection Technologies
We obtain your consent to our information collection technologies by providing you with transparent information in our privacy policy and providing you with the opportunity to make your choice. You have the right to object to the use of information collection technologies. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. If you would like to opt out of Google’s ad settings, please go to www.google.com/settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout. Please be aware that if you disable or remove these technologies some parts of our website will not work and that when you revisit our website your ability to limit cookies is subject to your browser settings and limitations.