At Avenue Living Asset Management Ltd. (“Avenue Living”), we are, and always have been, committed to maintaining the highest level of confidentiality regarding the personal information that our clients share with us. We have always recognized that this is your information, not ours, and we only share it when we have your express permission. Respecting your privacy is a value which is honoured throughout our company. In pursuit of this commitment, Avenue Living is guided and governed by the Personal Information Protection and Electronic Documents Act (Alberta), which regulates thecollection, use and disclosure of personal information.

The following Privacy Policy statement sets out in detail why Avenue Living may ask for your personal information, how we manage it and how we protect it.

BEING ACCOUNTABLE

Avenue Living acknowledges that it is responsible for protecting and safeguarding all personal information under its control. Avenue Living has established practices and procedures to ensure that this information is appropriately safeguarded.

IDENTIFYING THE PURPOSE OF COLLECTING PERSONAL INFORMATION

Under statue, Personal Information includes, but is not limited to, your name, address and telephone number, birth date, social insurance, passport or driver’s license number and photo, as well as your financial and investment information. This information may be collected through subscription documents, risk acknowledgement forms or other investment documents, or through conversations or other correspondence with you. We collect this and other information about you in order to: (i) satisfy regulatory requirements; (ii) properly identify you; (iii) to contact you or your designated representatives; (iv)) to manage the administration of your account; (v) to inform you of other services we offer that may be relevant to you; and (vi) to satisfy various legal, regulatory, custodial and tax reporting requirements.

OBTAINING YOUR CONSENT

Subscription agreements collected by Avenue Living contain a number of sections in which you are requested to supply personal information about yourself. By completing and signing this agreement or by providing us with personal information by any other means, you are consenting to the collection of your personal information and any subsequent personal information that is collected by us for the purposes which we have set out. You may withdraw your consent at any time, subject to legal and contractual conditions. Doing so, however, may have an impact on the services that we are able to provide to you.

COLLECTING ONLY ESSENTIAL INFORMATION

Our accounting, compliance and client service personnel collect and utilize only the minimum amount of personal information necessary for the applicable business transaction which you have intuited with Avenue Living.

LIMITING THE USE, DISCLOSURE, AND RETENTION OF YOUR PERSONAL INFORMATION

Safeguarding the confidentiality of personal information is a . No employee may release confidential personal information to any third party unless required by law or with the express consent.

Our accounting, compliance, service and administration personnel have been appropriately instructed and trained to ensure that account information, when requested, is only supplied to people who are expressly authorized by you to receive it. Our systems identify whether there are any such authorized recipients other than yourself for your account.

We will not disclose your personal information to third parties, except to the extent required to fulfill the purposes we have set out. We use service providers in various aspects of the services we provide to you, including, but not limited to, custodians, transfer agents, fund accounting, administrators, storage facilities, information technology providers, auditors, lawyers and other third parties. These third parties are only provided with the information necessary to perform the required services, and we require, under written agreements that these third parties protect the privacy of your information.

Avenue Living will not sell your personal information to any party for any purpose.

We may be required to disclose your personal information to domestic and international governments, and other regulators. We will only do so when required by law.

ENSURING THE ACCURACY OF PERSONAL INFORMATION

Staff who are in regular contact understand that they have a responsibility to update our records whenever they learn of changes in your personal information. As well, update forms are circulated periodically to give you the opportunity to revise your personal information. Should you have any concerns about the accuracy of your personal information which we have on file, please do not hesitate to contact us directly.

USING APPROPRIATE SAFEGUARDS

In the course of establishing a secure environment for the operation of our investment management activities, ICM has implemented a number of steps to safeguard the integrity of all personal information.

• Hard copies of personal information is available only to those staff that need to work with this material. Protection of our premises is secured through limited access only to those in possession of secure pass cards.
• Archival documents are stored with reliable third parties offsite at secure premises.
• Personal information in the form of electronic data is stored within our computer systems using firewalls, passwords and transmission encryption programs.
• All electronic data is backed up regularly at an offsite storage facility which maintains industry standard security systems.

BEING OPEN AND TRANSPARENT ABOUT OUR PROCESSES RELATING TO PERSONAL INFORMATION

Please do not hesitate to contact us in order to determine what personal information we have collected on you and how it is safely stored.

MAKING PERSONAL INFORMATION ACCESSIBLE TO CLIENTS

You may access your personal information that we have on file by contacting us at the address indicated under the “Contact Us” portion of this website. Avenue Living will endeavor to correct or amend any incorrect information on a timely basis.

RESPONDING TO INQUIRIES AND COMPLAINTS

Avenue Living will endeavor to respond to any inquiries or complaints on a timely basis. Please direct all inquiries in writing, to the address indicated under the “Contact Us” portion of this website. We will endeavor to acknowledge, investigate and respond to all queries on a timely basis.