PIPEDA

International Financial Data Services (Canada) Limited, (IFDS) provides market-leading transfer agency technology and services to the Canadian and global marketplace. This document summarizes, for the benefit of our employees, clients, our clients’ distributors, as well as for individuals, the principles we, at IFDS, apply to the handling of personal information in our Canadian operations. All IFDS employees must adhere to these principles and to our personal information handling guidelines. 

IFDS is a joint venture between State Street Corporation and DST Systems Inc., both of which provide their own services to many types of organizations and clients in many different countries around the world. This particular Privacy Policy applies only to IFDS’ operations in Canada. 

This Privacy Policy may be modified from time to time. The most up-to-date version can be obtained at our website at www.ifdsgroup.com. 

1. Collection, Use and Disclosure of Personal Information

As a provider of transfer agency technology and services, IFDS does not directly collect, nor does it use, personal information from or about individuals for its own independent purposes. Rather, we receive personal information from our clients or their distributors for processing purposes. We operate under the direction of our clients and on the understanding that appropriate consents have been obtained, either expressly or implied, for the collection, use and disclosure of personal information. IFDS uses the personal information we receive solely to provide services to our clients in accordance with our contractual obligation and for no other purposes. Our staff is required, as a condition of employment, to limit access to and use of personal information to the extent necessary for the performance of their specific employment duties. 

2. Security of Personal Information

As a processor of information on behalf of our clients, our most important privacy obligation is to take appropriate precautions to hold secure the information we receive. To that end, we apply security safeguards to our computing infrastructure and data in all forms. We maintain security policies, procedures and controls to protect the personal information we receive against loss or theft. We have safeguards in place to prevent unauthorized access, disclosure, copying, use and modification. We work with our clients to apply, to the extent that it is commercially and technologically feasible, the security standards required by our clients for the information we receive from them and which pertains to their business. 

Such safeguards and controls include, but are not limited to, the following:

1) Data security access control

2) Physical site access control

3) Network security

4) Virus protection

5) Intrusion detection

6) Remote use access control

7) Logical access control 

We test and update, as appropriate, our safeguards and controls on a routine basis.

3. Retention and Access to Personal Information

Individuals have the right to access the personal information held by an organization about them and to challenge an organization about its personal information practices. However, as a provider of transfer agency technology and related services, IFDS does not respond directly to requests from individuals to access personal information or to complaints from individuals about the personal information practices of our clients, any such requests and inquiries are referred back to our clients. This procedure is necessary to ensure that the authenticity of the request and the identity of the requester can be established by your firm and/or the distributor, as applicable, and that IFDS can receive specific instructions before personal information is released by IFDS on your behalf. 

4. Addressing Questions About Privacy and Requests for Access to IFDS

IFDS has appointed a Chief Privacy Officer to be responsible for its personal information practices and standards. Organizations, clients or individuals with questions or concerns about our personal information practices or individuals who require assistance in making a request to access their personal information through one of our clients can contact our Privacy Officer.

Legal Information

Purpose
International Financial has provided the information on its Web site for informational purposes only, and has a right to alter it at any time. International Financial does not guarantee its timeliness, accuracy, or completeness.

Copyright
Copyright 2001. Unless otherwise stated, copyrights and all similar rights in all material presented on the International Financial Data Services Web site, including graphical images, are owned by International Financial. Publication of materials on the International Financial site does not constitute the placing of such materials in the public domain.

Permission to Print and Copy
Permission to print and copy documents or graphics from this site is granted for personal and noncommercial use only and is expressly conditional upon your agreement that all prints or copies shall contain or refer to the copyright or proprietary notices in the International Financial Web site. The format and contents of the information shall not be altered in any way, and you will indemnify International Financial for damages and expenses, including attorneys' fees, it incurs related to your use of such materials and your breach of these requirements. No permission is granted to print and copy documents created by parties other than international Financial and appearing on this Web site, unless so indicated and subject to the restrictions indicated.

Trademarks and Service Marks
No license, assignment, or permission is granted herein, expressly, implicitly, or otherwise to use any trade name, trademark or service mark of International Financial or of any other party.

Warranty Disclaimer and Exclusion
International Financial makes no representations and hereby disclaims all warranties, expressed or implied, as to the timeliness, accuracy, completeness or suitability for any purpose of the information contained in the documents and related graphics published by International Financial its Web site or elsewhere on the Internet. The International Financial Web site and all such information are provided as is, as available. The information on the International Financial Web site shall not constitute any representation, warrant, or other commitment by DST or any of its affiliates with respect to any of the products or services described on the International Financial Web site.

Exclusion of Damages
In no event shall International Financial be liable for any damages whatsoever, whether actual, special, incidental, direct, indirect, punitive, exemplary or consequential arising out of the use of the International Financial Web site or any of the information or materials contained therein or accessible there from, including without limitation loss of profits or data, or the risks of the stock market

User Responses
Should any user of the International Financial Web site or viewer of documents or graphics copied or printed therefrom communicate with International Financial about the Web site, or the documents, graphics or information contained therein, International Financial shall have no obligation of any kind with respect to such communication, which shall be deemed non-confidential, and International Financial shall be free to use and distribute the information contained in such communication for any purpose whatsoever, unless International Financial and the party responding otherwise agree in writing.

Links Provided
References on this Web site, or links to or from this Web site to mutual funds/variable annuities, financial advisors, or any other entity which may offer securities or other investments for sale do not constitute any offer to sell any such securities or investments, nor do such links constitute any endorsement, referral or other recommendation of any kind