Privacy Policy

WealthSense is committed to protecting the privacy and confidentiality of personal information in our possession and control. This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which WealthSense collects, uses, discloses and otherwise treats personal information through our website available at WealthSense.ca , including all subpages and successor pages (collectively referred to as the “Website”) as well as through other interactions with our clients and prospective clients.

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. We strongly encourage you to refer to this Privacy Policy often for the latest information about our personal information practices.

We ask our clients for no more personal information than necessary.

WealthSense needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal
obligations. Understanding a client’s needs and wants, financial position and family issues enables us to ensure that all investment recommendations are
suitable. This is both a regulatory requirement and good business. WealthSense is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.

The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers (for tax reporting purposes), asset holdings and values, investment knowledge and objectives. We also collect your chequing account information, transactional history, account balances/limits and optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).

Our application forms for accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Policy. We also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect.

We limit the use of your personal information.

The personal information we collect when you open an account is used for the following purposes:

· helping us choose the portfolio that best fits you and your needs;
· verifying your identity and other information you have provided to us;
· opening and servicing your account;
· sending and receiving bill payments through your chequing account;
· detecting and preventing fraud and other unauthorized or illegal activities;
· meeting legal and regulatory requirements;
· transferring your account to or from another institution; and
· as otherwise required or permitted by applicable law.

Other ways we collect and use personal information.

Referral Program: If you participate in our referral program (or other “Invite a Friend” features that may be available on our Websites), we collect the email
address of the individual(s) who you wish to refer to WealthSense. We use thisinformation to send the recipient a one-time email containing information about the referral program. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you.

Marketing Communications: From time to time, we may obtain your consent to send you email, SMS text messages and other communications about
WealthSense products, services, or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at support@wealthsense.ca .

Customer Service/Relationship Manager: If you contact a customer service agent or Relationship Manager with a comment, question or complaint by email, text message, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and, product and service offerings.

Employment: If you inquire about or apply for a job with Wealthsimple, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.

Gifting: If you send a gift (or “Contribute to an Account”), we collect the email address of the individual(s) who you send a gift to, and your payment

How we collect personal information.

Except as otherwise set out in this Privacy Policy, we collect personal information directly from you. When you open a WealthSense account, you will be required to open an account. We collect personal information about you from our custodians, including records of transactions and statements of cash and securities in your accounts in order to monitor the investment performance of your portfolios and to provide statements to you as required by securities laws.

We limit access to clients’ personal information.

We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure
passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.

We implement safeguards to protect personal information.

WealthSense maintains reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control
against unauthorized access, use, modification and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.

Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your
password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).

We have personal information retention processes designed to retain personal information of our clients and prospective clients for no longer than necessary for the purposes set out in this Privacy Policy or to otherwise meet legal requirements.

We restrict disclosure of personal information.

We will not disclose, trade, rent, sell or otherwise transfer your personal information, without your consent, except as otherwise set out in this Privacy
Policy.

Service Providers: We may transfer your personal information to our affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting.

Broker: When you open a broker account with our custodian, we provide your account information to the respective brokerage in order to streamline the
application process. We also notify them of any updates or changes to your account information.

Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of WealthSense or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

Securities Regulations: We andor our custodian may share your name, contact information and holdings with issuers of securities that you hold in your account and other personscompanies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations. We and/or our custodian may also disclose certain personal information, including the number of and purchase price of units purchased, to the applicable Canadian securities regulatory authority where required by law.

Legal: We and our Canadian, affiliate and third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian law (which may include lawful access requests by Canadian, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

We expect similar safeguards from our service providers.

Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal
information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third-party service providers in other jurisdictions. In the event personal information is transferred to the other jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental
authorities in accordance with the laws of those jurisdictions.

We take privacy seriously.

WealthSense’s Chief Compliance Officer, is responsible for ensuring that WealthSense adheres to its privacy policy. The Chief Compliance Officer is
responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact him at the contact information set out below for any additional clarification desired. A client wishing to review his or her personal information in our possession should send a written request to this effect to WealthSense’s Chief Compliance Officer.

We collect and use information about your visit to our website.

In general, you can visit our Website without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Website and other related information such as page requests, browser type, operating system and average time spent on the Website. We use this information to help us understand Website activity and to monitor and improve the Website.

Cookies & Similar Technologies: The Website uses a technology called “cookies”. A cookie is a tiny element of data that the Website can send to your
browser, which may then be stored on your hard drive so that you can be recognized when you return. We use cookies on the pages on the Website where
you are prompted to log in or that are customizable. If you have registered with the Website, these cookies may let us know who you are and identify your browser as one that has visited the Website before and may be necessary to access your account information (stored on our computers) in order to deliver products and personalized services. We also use cookies to provide us and our service providers with information about your use of the Website that we may use to personalize the Website or other content in accordance with your interests and preferences (e.g. language preference) and improve your user experience. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from the Website, you may not be able to take advantage of all of the features of the Website.

Tracer Tags & Web Beacons: The Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which
pages you visit on the Website. These tracer tags are used to help us optimize and tailor the Website for you and other future visitors to the Website.

Website Analytics: We may use third parties to help us gather and analyze information about the areas visited on the Website in order to better understand,
evaluate and improve the user experience and the convenience of the Website.

Social Media: We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Website and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.

We use online advertising.

We may use third parties such as ad exchanges to serve our advertisements on our Website or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Websites and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Website.
We may provide links to third party websites. Our Website may contain links to other websites that we do not own or operate. Also, links to our Website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal info.