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PRIVACY POLICY As it pertains to the information provided to Verecan Asset Management by our clients.

Verecan Asset Management Inc. (“Verecan” or “VAM”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information, as well as your rights regarding that information. 

PERSONAL INFORMATION 

Personal information means any information about an identifiable individual, including financial, lifestyle, or health information. It does not include publicly available business contact information such as name, title, business address, or business telephone number. Personal information may exist in written, electronic, audio, or other formats. 

PURPOSE OF INFORMATION COLLECTION 

We collect personal information to provide advisory services and to comply with legal and regulatory requirements. This information is collected through our client onboarding and ongoing relationship process, which may include: 

  • The Know Your Client process and related discussions 
  • Telephone, video, and in-person conversations and meetings 
  • Documents you provide directly or through service providers 
  • Your account activity and transactions 

We collect only the information necessary to: 

  • Fulfill our fiduciary obligations as a registered investment adviser 
  • Verify your identity under applicable anti-money laundering and securities laws 
  • Open, service, and administer your account 
  • Facilitate transfers of funds and securities 
  • Detect and prevent fraud and other unlawful activity 
  • Meet tax reporting obligations 
  • Comply with securities and other applicable laws 

SERVICE PROVIDERS 

We may share your personal information with third-party service providers who perform services on our behalf. These providers are contractually required to protect your information and use it only for the specific service provided. When you open an account with us, you will also open an account with the custodian, who provides services such as trade execution, clearing, and account administration. We must update the custodian with any changes to your account information. 

DISCLOSURE UNDER SECURITIES REGULATIONS 

We and/or the custodian may share your name, contact information, and holdings with issuers of securities you hold, as required by law. This allows issuers to provide financial reports, tax documents, and other required materials. We may also disclose personal information where permitted or required by law, including anti-money laundering laws or to comply with a court order. 

CONSENT 

By providing us with your personal information, you consent to our collection, use, and disclosure as described in this policy. Consent may be written, verbal, implied, or provided through an authorized representative. You may withdraw consent at any time, subject to legal or contractual restrictions. Withdrawal of consent may limit our ability to provide services. 

In certain limited circumstances, we may be required to collect, use, or disclose personal information without your consent, for example where required by law enforcement or where necessary to prevent fraud. 

LIMITS TO COLLECTION, USE, AND DISCLOSURE 

We limit collection of your personal information to what is necessary for the purposes described. Information is collected directly from you unless you authorize collection from a third party or the law allows otherwise. Your information will only be used for the identified purposes, unless you consent to another use or disclosure, or as required by law. 

RETENTION AND DESTRUCTION 

We retain your personal information only as long as needed to fulfill the purposes for which it was collected, or as required by law. When information is no longer required, it will be securely destroyed to prevent unauthorized access. 

CLIENT LISTS 

We do not sell or share client lists. We do not sell or share personal information as those terms are defined under U.S. state privacy laws, including the California Consumer Privacy Act. 

ACCOUNTABILITY 

We are responsible for personal information in our possession or control. VAM has designated its Chief Compliance Officer as the Privacy Officer and Qualified Individual under applicable U.S. and Canadian privacy and security requirements. This individual is responsible for overseeing our privacy program and ensuring compliance with applicable laws. 

SAFEGUARDS 

We use administrative, physical, and technological measures to protect your personal information from loss, theft, unauthorized access, disclosure, alteration, or destruction. Only authorized employees and service providers have access to your information, and only to the extent necessary to perform their duties. 

ACCESS AND ACCURACY 

You have the right to access your personal information, request corrections, and withdraw consent to its use or disclosure, subject to legal restrictions. Requests should be directed to the Privacy Officer at the contact information below. We make every effort to ensure your information is accurate and complete. 

CROSS-BORDER DATA STORAGE 

Personal information collected by VAM may be transferred to and stored in both Canada and the United States. As a result, information may be subject to the laws of those jurisdictions and may be accessed by courts, law enforcement, or regulatory authorities in those jurisdictions. 

ANNUAL PRIVACY NOTICE 

We provide this Privacy Policy at account opening and, as required by law, on an annual basis. If our practices change, we will notify you before the change takes effect. The most current version of this Privacy Policy will also be available on our website. 

VERECAN GROUP OF COMPANIES 

Verecan Asset Management Inc. is part of the Verecan Group of Companies, which includes Verecan Mortgage Services, Verecan Wealth Management Inc., and Verecan Capital Management Inc. With your explicit consent, we may share your information within our group to provide integrated services. You may withdraw this consent at any time. 

CONTACT INFORMATION 

Questions, concerns, or requests relating to your personal information may be directed to: 

Privacy Officer 

Verecan Asset Management Inc. 

1701 Hollis Street, Suite 105, Halifax, NS B3J 2T9 

1-800-782-2345