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 this website at www.ifdsgroup.com.

Privacy Policy
IFDS collects information from visitors who access the various parts of our Web site. We only disclose this information in accordance with this Privacy policy, our contractual rights and obligations and as required by law. We do not use information gathered in any marketing or sales promotions.

We want you to understand our commitment to personal privacy and our use of information. For this reason, we have prepared this privacy policy. IFDS reserves the right to make changes to this policy and to our related procedures at any time. As we make changes to our policy, we will update this Web page.

We preserve the content of your email, your email address, and our response so that we may better serve you. Depending on the content of your email, we may be required by existing laws and regulations to keep this information.

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. Consent is not required for the collection, use and disclosure of personal information relating to the contravention of a law. 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
IFDS is a processor of information on behalf of its clients. As such, it applies security safeguards to its computing infrastructure and data in accordance with, at a minimum, the standards set by its clients. 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
IFDS retains all information collected unless specifically instructed by our clients to destroy the 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 Chief Privacy Officer. The Chief Privacy Officer's address is 30 Adelaide Street East, Suite 1, Toronto, Ontario, M5C 3G9 Canada.

Legal Information
Please read this notice before using this website. Your use of this website constitutes your agreement to the terms and conditions set out below. IFDS may change, modify or remove portions of these terms and conditions at any time. Any such amended terms and conditions will be posted on this website. Your continued use of this website following the posting of such amended terms and conditions constitutes your agreement to such amended term and conditions.

Purpose
IFDS 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 International Financial Data Services (Canada) Limited. All Rights Reserved. The contents of this website are protected by the copyright laws of Canada and worldwide copyright laws and treaty provisions.

IFDS either owns the intellectual property rights and other content contained on this website, including the manner in which the content is provided, or has obtained the permission of the owner of the intellectual property in such content to use the content on this website. Such content, including but not limited to graphical images, text, design, drawings, photographs, code and software, and all organization and presentation of such content, which forms a part of this website, are all owned by IFDS. Publication of materials on this website 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 non-commercial use only and is expressly conditional upon your agreement that all prints or copies shall contain or refer to the copyright or proprietary notices displayed on the IFDS website. No permission is granted to access, display on your computer, read, download or print copies of documents created by parties other than IFDS and appearing on or available through this website, unless so indicated and subject to the restrictions indicated. The format and content of the information shall not be altered in any way, and you will indemnify IFDS for damages and expenses, including all legal fees it incurs related to your use of IFDS and third party materials displayed on or available through use of the IFDS website and your breach of these requirements.

Trademarks and Service Marks
All trade-marks appearing or displayed on this website belong to their respective owners. The absence of a product or service name or logo from this list does not constitute a waiver of the trade-mark or other intellectual property rights of IFDS and/or its related companies concerning that name or logo. No license, assignment, or permission is granted herein, expressly, implicitly or otherwise to use any trade name, trademark or service mark of IFDS or of any other party.

Warranty Disclaimer and Exclusion
IFDS 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 IFDS its Web site or elsewhere on the Internet. This website and all information displayed thereon or made available through its use are provided on an as is, as available basis. The information on the IFDS Web site shall not constitute any representation, warranty, or other commitment by DST or any of its affiliates with respect to any of the products or services described on the IFDS Web site.

Exclusion of Damages
In no event shall IFDS or its employees, agents, directors, officers or affiliated companies, be liable for any damages whatsoever, whether actual, special, incidental, direct, indirect, punitive, exemplary or consequential arising out of the use of the IFDS 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

Governing Law
The laws of the Province of Ontario and the federal laws of Canada applicable therein shall govern as to the interpretation, validity and effect of these terms and conditions in any dispute regarding the use of this website without giving effect to any principles of conflict of laws. Any dispute with IFDS arising from your use of this website shall be brought exclusively in the courts of Ontario.

Information Accuracy
All information on this website is subject to change without notice. IFDS assumes no liability or responsibility for any errors or omissions on this website.

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

Links Provided
Links are provided for your convenience only and are entirely independent of this site. IFDS does not control or review these sites and is not responsible for the content, completeness, accuracy or security of the materials on any such sites.

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.