Optimum Asset Management Inc. undertakes to protect the confidentiality and ensure the security of the personal information of its clients. This Confidentiality Policy explains the measures the firm has taken to abide by this policy.

COLLECTION AND USE

Optimum Asset Management Inc. collects only personal information that is necessary for effective management of your account and that is required by the applicable laws and regulations, especially those pertaining to securities, taxation and financial services (the "law"). For example, we obtain personal information concerning our investors to open and administer their accounts. We also collect information from other financial intermediaries and during formal and informal meetings and discussions.

The information collected includes identifying information, such as name, social insurance number, occupation, marital status, address, telephone number, e-mail address, fax number and any other contact information, as well as information on your financial situation and the status of your assets, and changes in your personal situation.

Such information enables us to provide the agreed-on services and to carry out transactions on behalf of our investors that are in accordance with the investment management mandate.

Personal information may also be used for the following purposes:

  • To understand and assess investment needs and make any required adjustments to investment portfolios;
  • To carry out of Optimum Asset Management's internal and external audits;
  • To co-operate with regulatory authorities and meet legal requirements;
  • To complete certain transactions or make certain changes to an account, it may be necessary to provide information concerning the investor to financial intermediaries, for example, to confirm their identity.

DISCLOSURE AND RETENTION

We never sell or give client lists or client information to other companies or third parties for their own use.
We have the right to communicate information regarding you to government bodies and entities or to regulatory authorities in order to comply with laws, regulations, subpoenas, formal or official requests or any other similar procedure, within the limits provided by law.

We keep personal information only as long as it is required, for the purposes for which it was collected or to comply with applicable legal requirements.

If a client requires us to provide information concerning you to a third party, such as the client's accountant, tax specialist, notary or another person, they must make the request in writing, stating the person's identify and contact information and describing the information to be provided.

IF YOU CLOSE YOUR ACCOUNT

If an investor closes their account, the personal information on file will continue to be covered by this Confidentiality Policy.

PROTECTION OF PERSONAL INFORMATION

Optimum Asset Management Inc. has put in place both technical and organisational security measures to adequately protect clients'personal information from unauthorized access or handling, as well as from loss or destruction.
Access to investors'accountis stricly restricted to those employees who require the information to provide the requested services.

INTERNET

Like other types of communication, unprotected e-mails are not confidential and can be lost, altered, modified and even intercepted. Optimum Asset Management Inc. will accept no liability toward you or anyone else for damages resulting from transmission of electronic message to or from Optimum Asset Management Inc. As a reminder,other means of communication to send information to Optimum Asset Management Inc. can better protect personal information when deemded necessary.

MODIFICATION AND ACCESSIBILILTY

On request, we give our investors access to the personal information kept on file. Clients can verify how this information is used and ensure that it is accurate and complete, as well as provide udates as necessary, to the extent allowed by law.

WITHDRAWAL OF CONSENT

Subject to any legal requirement or contractual constraint, investors can change or withdraw at anytime their consent for the collection, use and communication of personal information by sending a written notice to Optimum Asset Management.

UPDATING OF POLICY

Any addition, change or deletion deemed appropriate and affecting this Confidentiality Policy will be made immediately.