Privacy

Policy for the management and protection of personal information

The Emma group of companies (Emma Services financiers inc. and Emma Labs inc.) acts as an intermediary either between personal lines underwriters and independent consultants or between group investment bodies (mutual fund companies) and dealing representative of a mutual fund dealer associated with MICA Capital inc.

In exercising its responsibilities, Emma must collect, through its representatives and consultants, personal and confidential information related to their clients and necessary for carrying out its activities.

Emma is committed to protecting the personal information collected from clients. This policy explains the practices for collecting, using and disclosing personal information related to clients, as well as the measures adopted to ensure that such information is handled properly.

The policies and practices that we have implemented have been developed to embody the principles referred to in the laws applicable in Quebec to ensure the protection of personal information and its confidentiality. More specifically, the Act respecting the protection of personal information in the private sector (R.S.Q., c. P-39.1) and its regulations are applicable, and Emma is committed to their principles.

The expression “personal information” is defined as follows:

Personal information is any information which relates to a natural person and allows that person to be identified;

This definition refers to any information that makes it possible to identify you, such as your name, address, telephone number, email address, fax number or any other information that can be used to communicate with you, information of a financial nature about you or your spouse, information related to your occupation and the occupation of your spouse and information about your credit, financial instructions or state of health.

The concept does not apply to information about companies and other artificial persons.

A. Information collected

We collect personal information in accordance with applicable laws and in an ethical manner. We collect only information that is necessary and useful, directly or indirectly, to fulfill our duties so as to permit us to carry out our tasks and responsibilities.

B. 10 principles of confidentiality

1. Our Responsibility to Our Clients

We are responsible for all the information under our control, including all information transferred to a third party for processing, storage or otherwise.Therefore, we must protect the confidentiality of the personal information to which we have access.

We are responsible for all the information under our control, including all information transferred to a third party for processing, storage or otherwise.Therefore, we must protect the confidentiality of the personal information to which we have access.

As a condition of employment, all our employees commit to ethical principles, including a fundamental principle to maintain at all times the confidentiality, security and privacy of the information on file for each client.

Likewise, on an on-going basis, we assure you that our employees receive adequate and appropriate training and that they are regularly informed of changes made to our company’s procedures for managing and protecting your personal information.

2. Determining the Purposes of Collecting Information

When you deal with one of our consultants (personal lines underwriters) or one of our dealing representative of a mutual fund dealer (mutual fund), they will ask you for personal information for various purposes:

• To verify your identity and prevent fraud;
• To ensure that they understand your financial services needs;
• To determine whether a product or service is right for you;
• To determine whether you qualify for products or services with a view to offering them to you;
• To enrol you for any product or service that you have requested and to manage such product or service;
• And finally, to satisfy statutory and regulatory requirement

3. Your Consent

When you accept a personal insurance proposal or open a mutual fund account by signing the appropriate documents, you certify that you consent to the collection, use and disclosure of personal information. You also agree that Emma may from time to time provide to third parties with whom she has business relationships such as independent representatives or allow such third parties to access personal information in order to fulfill the mandate you entrusted to him. When required, Emma may be able to share your personal information with regulators with whom she or he must collaborate and who governs her / his activities.

It is your right, if you so desire, to refuse the collection, use and disclosure of your personal information. Moreover, you can withdraw your consent at any time thereafter, subject to restrictions provided by law or contract and reasonable notice. In several cases, the collection, use and disclosure of personal information is necessary for the proper management or administration of your file and the on-going delivery of services related to your file. Under such circumstances, you must know that we could be forced to close your file or cease to offer you a product or service.

You can terminate your consent at any time if:

• You give reasonable notice in writing to that effect;
• We are not legally bound to obtain, use or disclose personal information;
• Doing so does not prevent us from executing the contract under which we made commitments to you

4. Limiting the Collection of Your Personal Information

We collect only essential information that we need to process your file. We may ask you for the following information:

• Social Insurance Number (SIN) – For the purpose of reporting income to the tax authorities and other governmental purposes, including opening an income generating account or a registered retirement income investment so as to meet the requirements of the Canada Revenue Agency, we may use your SIN for administrative purposes, in particular to match up your personal information or as an internal identification number to distinguish you from clients whose name is similar to yours.
• RFinancial Information – To ensure that the advice we offer you and the investments you make are suitable by knowing you well.
• Health Information – To determine your eligibility for some insurance products.
• Contact Information – For example, your name, address, telephone number and email address.
• In some cases, you may decide not to give us certain information. However, in such cases, we may not be able to provide the product, service or information that you desire if the rules in effect require us to obtain such information.

5. Limiting Disclosure, Use and Retention

Your personal information will not be used or disclosed for purposes other than those for which it was collected, unless you consent thereto or the law so requires. We will retain your personal information for as long as necessary to achieve those purposes. The destruction of such information will be carried out in a secure manner so as to respect their protection and ensure their confidentiality.

We will not under any circumstances or for any consideration sell or give lists of our clients to other companies for their own use.

In order to properly execute the mandate that you have given us, we may send to a third party the personal information gathered about you, including in the following cases:

• We have obtained your consent to do so;
• We send your personal information to some other organization with whom we maintain business relations in order to execute your requests;
• A securities authority or other regulatory body so requires;
• We are so required or authorized by law

We keep files containing your personal information for only as long as such information is required for our business relations, in accordance with our internal document retention policies or legal and regulatory standards. Such files will be kept by the consultant or dealing representative of a mutual fund dealer with whom you usually do business, by Emma’s compliance department or our service providers.

Strict procedures for the retention of your personal information are followed, and we will destroy personal information that Emma no longer needs for specific purposes.

We may disclose personal information to legal or regulatory authorities where we suspect money laundering activities, illegal insider trading, a manipulative or deceptive trade practice or other criminal activities, to detect and prevent fraud or to meet statutory requirements or the rules of government agencies, regulatory bodies or self-regulation organizations. We may also disclose personal information to comply with a legal obligation (for example, a court order) or to protect our assets (for example, for the recovery of past due accounts). Where we must disclose personal information in such cases, we will open a file in which we will specify what information was disclosed, when, to whom and why.

6. Accuracy of Your Information

We are committed to maintaining the exactitude of personal information, and we make sure that it is complete and up-to-date. We try to take all reasonable measures to maintain its accuracy. If you find errors in our data or if information concerning you has changed, you must immediately notify the consultant with whom you do business or Emma so that we may make the necessary changes. We will make changes to your file if you show that the personal information it contains is incomplete, incorrect or ambiguous.

We will do our best to inform those to whom we have disclosed information of such changes as soon as possible.

To access your personal information, correct your personal information, submit a request for information or make a complaint, please contact us by sending your request in writing to the address given in Principle 10.

7. Our Priority is the Security of Your Personal Information

We maintain strict security measures to protect your personal information against unauthorized access, regardless of the format in which we store it. We strive to adapt our security measures to technological advances.

Protection methods include:

• Physical security measures, such as restricted-access facilities and locked filing cabinets;
• Electronic security measures and techniques for computerized personal information, such as passwords, encrypted data bases and personal identification numbers;
• Organizational procedures, such as restricting access to your personal information to a selected group of people;
• Contractual obligations with third parties who need access to your personal information that require them to protect the confidentiality and security of your personal information.

We have established a complete range of security control methods to protect personal information from unauthorized use, consultation, modification, copying, destruction and disclosure and from loss or theft.

On our Websites, cookies and other information tracking mechanisms may be used to improve the sites’ features and security or to offer users site consultation that is more personalized. It should be noted that cookies cannot, in any case, access files or data on your computer.

8. Openness

We will provide you with information on our policies and practices for managing your personal information.

We may occasionally make changes to our rules for protecting personal information or the measures we have implemented to ensure the security of such information. Where appropriate, we will inform you thereof, as required by law.

9. You Can Access Your Personal Information

You can access your file if you make a request in writing to Emma’s officer in charge of protecting personal information, at the head office. The access and modification rights include the following:

• The right to consult your file without charge;
• The right to obtain a copy of your file for a reasonable fee;
• The right to have corrections made to incomplete, incorrect or ambiguous information.

If you wish to consult or verify personal information or know to whom we have disclosed it, you can make a request for that purpose. We may ask you for specific information so that we can locate and provide such information. Depending on the nature of your request, you may have to pay a small fee for copying or research, but we will inform you before going forward. In some cases, in accordance with applicable law, we may not be able to provide you with some of the information about you that we hold. In that case, we will inform you of the reasons that prevent us from giving you access to such information.

10. Information Requests and Complaints

You can contact us to request information or to make a complaint with respect to our policies and practices concerning the protection of personal information.

We are committed to promptly and accurately answering your questions or concerns about confidentiality, the security of your personal information and our policies and methods for protecting personal information.

In the event that you make a complaint about the exercise of your rights as set out in this document, responsibility for your file will be assumed by the office of Emma’s officer in charge of protecting personal information, who will inform you of the procedure to follow. An enquiry will be carried out for each complaint. If a complaint is justified, the specific situation will be corrected and we will inform you thereof. If the problem raised by your complaint requires a change to our policies or procedures, we will act accordingly.

For any request or complaint, please contact us by writing to the following address:

Emma Services Financiers inc.
Officer in Charge of Protecting Personal Information
7900 Pierre-Bertrand Blvd., Suite 300,
Quebec City (Quebec) G2J 0C5