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Altamira's Privacy Policy

Altamira remains committed to providing you (our clients) with award winning customer service and advice. As part of this commitment, we strive to protect your privacy and the confidentiality of personal information that you have entrusted to us.

In order to maintain your trust and confidence in us, Altamira's Privacy Policy is designed to outline for you in a question and answer format important details about how we safeguard the privacy, confidentiality and security of your personal information.

Why does Altamira need to collect information about you?
What information about you do we collect?
What do we do with your personal information?
With whom is your information shared?
Where do we keep your information?
How is your information protected?
How is Altamira minimizing use of your personal information?
How does Altamira collect, use and protect your personal information received online?
What privacy rights do you have?
Who do you contact about privacy concerns at Altamira?

1. Why does Altamira need to collect information about you? To top

Simply, we collect personal information about you in order to properly serve you and your investment needs.

Secondly, we never collect more information about you than is absolutely necessary to serve you and necessary to meet our legal and regulatory requirements.

2. What information about you do we collect? To top

Personal and financial information you provide in Account Application forms that you send us to open new accounts or request product information. Personal information may include your name, address, social insurance number, birth date, bank account information and employment information. Some personal information may also be requested from your spouse or beneficiary (depending on the type of Altamira account). Financial information may include your annual income and net worth;
Information you provide during telephone conversations with an Altamira representative, which calls are all recorded for the purposes described below;
Information you provide in e-mails or contact forms that you send us;
Information that your browser provides about the browser type and configuration your computer uses so that you can view our website properly;
Information you provide upon registration for AltaAccess Online;
Log File Information. In an ongoing effort to improve the quality of our website, we regularly review server-generated logs, which provide information on website use, browser types and very limited demographic overview information. We make no attempt to identify individual users; and
Personal and financial information you provide in response to surveys, questionnaires, focus groups or other marketing initiatives.

3. What do we do with your personal information? To top

We use your personal information:

to properly identify you;
to professionally serve your investing needs;
to establish your account and to maintain, record and store your account information;
to understand your financial situation in order to provide you with suitable and appropriate investment advice;
to fully comply with our "Know Your Client" requirements under Canadian securities laws;
to execute transactions including transferring funds by electronic or other means;
to ensure quality control during telephone conversations with our representatives;
to provide verification of trade related telephone discussions with our representatives for our mutual protection;
to provide you with ongoing services including, but not limited to, account statements, trade confirmations, tax receipts, proxy mailings and other information necessary to operate your account;
to develop and offer additional products and services that we feel may be of interest to you; and
to meet our legal and regulatory requirements under Canadian law including compliance with Canada's anti-money laundering legislation.

4. With whom is your information shared? To top

Altamira is not in the business of selling or distributing our clients' personal information to others. Client confidentiality and privacy remains a fundamental principle of ours and of the Canadian mutual fund industry. However, we may share your information with others outside Altamira in certain limited circumstances including:

With Third Party Suppliers whom we hire to perform services on our behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, the preparation and mailing of client statements, document storage, imaging and market research. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These third party suppliers are not permitted to disclose this information to others. Sharing this information with these third parties is critical to Altamira providing you with its award winning customer service.
With Other Third Parties. If you purchase Altamira mutual funds through a financial advisor or through another registered dealer, we will share your personal information with the financial advisor and or the other registered dealer. We may also have to contact other financial institutions or mutual fund companies in order to gather complete information necessary to properly service your account with us.
With Affiliates of Altamira. To ensure you benefit from a full range of products and services and only with your consent, we may share your personal information with our affiliates including our parent company, National Bank of Canada, or any of its subsidiaries. This will allow them to propose additional financial products and services likely of interest to you.

The affiliates may provide the following products and services:
- deposits, loans and mortgages;
- credit, debit and payment card services;
- investment and financial management services;
- brokerage services;
- trust and custodial services;
- insurance services; and
- other related products and services.
When Permitted or Required by Law. Altamira is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry.

We may disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

We may disclose information to various regulators to which we are subject in order to comply with their regulatory requirements. This helps prevent fraud, money laundering, and other illegal or unethical activity. For example, the Mutual Fund Dealers Association of Canada (the "MFDA") is the self-regulatory organization of all Canadian mutual fund dealers. Altamira is a member of the MFDA. The MFDA may, from time to time, require access to personal information of clients, employees, agents, directors, or officers of Altamira. The MFDA collects and uses personal information from Altamira for regulatory purposes, including:
- regular compliance and other regulatory audits;
- investigation of regulatory violations;
- enforcement or disciplinary proceedings;
- regulatory databases; and
- reporting and information sharing with other securities regulators (e.g. Ontario Securities Commission).
In this way, the MFDA and other regulatory bodies ensure that Altamira remains in full compliance with its legal and ethical obligations to clients.
Business Re-organization As Altamira continues to grow, we may in the future re-organize or streamline parts of our operations. Because our business consists in large measure of our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business.

5. Where do we keep your information? To top

Altamira records and retains your personal information in electronic, microfilm or paper format at our Head Office location in Toronto.

Electronic access to your personal information is made available to Altamira staff at our branch locations throughout Canada. Additionally, paper records forming part of your personal information held by us may also be kept at the branch locations. Paper records are also kept in off site storage locations in Toronto as part of our document storage practices.

Your personal information may also be transferred to other off site locations as part of our disaster recovery practices.

6. How is your information protected? To top

The security of your personal information is our top priority. We employ extensive physical, electronic and internal procedural controls to protect your personal data. Altamira annually undergoes an independent security audit to ensure that our procedures and controls meet or exceed industry standards.

Altamira has comprehensive security standards to guard against unauthorized access to your personal information. For example:

Our Investment Specialists will seek confirmation of your identity for security purposes when dealing with you on the telephone;
We require users to identify themselves on the Alta Access Online "Sign-In Page" before granting Internet access to account information;
We protect your account and log in information using highly secure "firewalls";
We reconfirm your computer's identity each time you ask to see a new AltaAccess Online page;
We send and receive your Alta Access Online account and personal information in "encrypted" form to ensure maximum security;
We carefully review all court orders or legal enquiries received to confirm they are valid. We disclose only the personal information legally required under the terms of the court order or legal enquiry;
All Altamira employees are properly trained to ensure all personal information is handled properly and safeguarded adequately; and
Altamira will audit our privacy procedures and security measures in order to confirm that they remain adequate and effective.

While we make every attempt to provide the most secure environment for your data, there are a number of things you as a client can do to ensure the protection of your personal data. See Precautions for personal computers.

7. How is Altamira minimizing use of your personal information? To top

Within Altamira and among our service providers, we restrict access to personal information to those who need it in order to provide you with products and services.

We do not use personal or financial information for any purpose other than to best serve you and to identify how we can best meet your needs.

We do not ask for more information than we need to meet your financial needs and our legal and regulatory requirements.

8. How does Altamira collect, use and protect your personal information received online? To top

Visiting our informational sites When you visit one of our informational websites and navigate through the content provided we learn what pages were visited, what pages were downloaded, the address of the site you visited prior to accessing our site and your Internet protocol address. We only use this information to gather overall site statistics (for example total number of visitors to the site). No attempt is made to identify you as an individual.

Information such as how people are using our site, which sections are of most interest and which pages are visited more frequently assists us in adapting our site to better suit your needs and make accessing information easier. No personal information about you is retained by us.

Our sites offer a number of financial calculators or assessment tools (e.g.Wealth Check) to assist you with your financial decisions. The selections you provide are not recorded or in any way associated with you. They are used solely to determine an appropriate asset allocation and to make a comparison with your existing portfolio.
Cookies Cookies are small text files that are placed on your computer when you visit a website.

There are two types of cookies currently in use: "session cookies" and "persistent cookies". Session cookies store information only for the duration of your visit to a site. They are not written to the hard drive of your PC but rather are stored in your computer's memory. They do not exist after you have left the site. We currently do not use session cookies in any of our sites.

Persistent cookies are written to your hard drive and remain there until they expire or are deleted by you. We use persistent cookies to store non-sensitive information. We use them to improve our site by tracking general information only (for example which pages are viewed most often). We recommend that you accept cookies while using www.altamira.com if your browser settings prompt you to do so. If you choose, you can explore www.altamira.com with cookies set to OFF, but you will not be able to take advantage of any personalization features that are offered. You may wish to check your current cookie status at www.altamira.com. We may also provide you with the opportunity to accept cookies to maintain your preferences between visits to www.altamira.com, for example to display a list of funds in a custom portfolio. Please note that you will be asked if you would like to "save your preferences" and the site will not send a cookie with this information to your computer unless you do so.
Online transaction service When you register for our online transactional service we use the information you provide to identify your Altamira accounts that can be viewed over the Internet and to determine which services we can offer you.

Each time you use the service, we record your login id when you enter the system and when you leave. We record any changes to services that you have registered for and modifications to your personal information. Certain services require you to provide a valid e-mail address either for e-delivery or a trade request. This information is used solely for the purpose of notifying you when the publications, personal statements or trade confirmations become available or to contact you if a trade requires clarification.
E-mail When you send us an e-mail we use that address to respond to your query via e-mail. We will store your e-mail and our reply for future reference should there be further correspondence.

If you have asked us for a portfolio review (via Wealth Check) we will use your e-mail for follow-up /contact purposes only.

If you have asked us to put you on our e-mail mailing list to provide you with certain information on a regular basis you may ask us to remove you from that list at any time (using the unsubscribe instructions provided with each e-mail)

Please remember that e-mail sent via the Internet is generally unencrypted and a potential security risk. We will only request that you transmit confidential information over the Internet where the communication is encrypted. You should use caution when forwarding emails and ensure that you do not include confidential information within the body of the messages (such as account numbers).

9. What privacy rights do you have? To top

Except in limited circumstances, you may request from us access to your personal information that we hold. You may also question or challenge the accuracy and completeness of this information. We will respond to your request within 30 days.

Please note that we may not be able to provide you with your information in the following circumstances:

if it contains references to other persons and the references are subject to legal privilege;
if it contains information that is proprietary to Altamira;
if it relates to an investigation of a breach of agreement or law; and
if it cannot be disclosed for other legal reasons.

You are also permitted to withdraw your consent that allows us to share your personal information in certain circumstances (for example, the sharing of your information with our affiliates). You may withdraw such consent at any time by contacting us by e-mail or telephone at the address and number noted below. However, your decision to withdraw or revoke your consent may limit the products or services that we are able to provide to you.

10. Who do you contact about privacy concerns at Altamira? To top

Altamira has appointed a Chief Privacy Officer to handle all privacy issues. If you have any questions, concerns or issues about our Privacy Policy or about confidentiality issues or other issues raised here, you may contact us as follows:

Attention: Chief Privacy Officer
By mail Altamira Investment Services Inc. 130 King Street West, Ste. 900 The Exchange Tower Toronto, Ontario M5X 1K9		By e-mail advice@altamira.com		Telephone and fax 1-800-263-2824 (across Canada) 1-800-361-2354 (in Quebec) 416 507-7111 (Fax)

Investment Specialists or Private Wealth Consultants Or you may speak to any one of our highly trained Investment Specialists or Private Wealth Consultants throughout Canada. They will likely be able to respond to most of your privacy questions or concerns. Alternatively, they will pass your questions, concerns or issues on to our Chief Privacy Officer for resolution.

You may also contact the Privacy Commissioner

The Privacy Commissioner
The Privacy Commissioner of Canada 112 Kent Street Ottawa, Ontario K1A 1H3 Phone: 613 995-8210 or 1-800-282-1376 www.privcom.gc.ca		In Quebec: La Commission d'accès a l'information 575, rue Amable, bureau 110 Québec (Québec) G1R 2G4 Phone: 418 528-7741 or 1-888-528-7741