Legacy Private Trust (the “Company”) is committed to ensuring the protection of your privacy and the confidentiality of your personal information. This policy applies to personal information that the Company collects, uses or discloses in the course of its commercial activities.

When we collect information from you, we will explain what information we are collecting, why we are collecting it and how we intend to use it.

We will use your information in order to provide you with the proper level of service and to meet our compliance and tax reporting legal requirements.

We will provide your information to other parties where we have your consent, where the other parties are our suppliers or business partners who provide service to your account, where we are required or permitted to do so by law, and where transfers of our business are involved.

We will take appropriate steps to protect your information. We have thorough security standards in place to protect your information against unauthorized access and use. We also provide training to our employees so they will understand the need for confidentiality when dealing with your information. We will retain your information as long as it is necessary to service your account or as is required by our industry’s regulations.

We will address and respond to any of your concerns about our handling of your information.

We ask for a variety of information when you open an account with us. Specific regulations demand that we obtain a minimum amount of information about you so that we can provide the proper level of service and supervision to your account. We may also require your country(ies) of tax residency as well as your Social Insurance Number (“SIN”) or Tax Identification Number (“TIN”) in order to comply with certain Canada Revenue Agency or Income Tax Act reporting requirements.

With your consent, we may obtain information about you from third parties such as credit agencies. We may also, with your consent, provide your information to outside sources. For example, service providers who we hire to do things like process your trades and send your month‐end statements to you will have access to certain account information including your name and address in order to perform their required functions. We require our third party service providers to sign a Privacy Agreement to help ensure that they will protect the confidentiality of your information. We are also obliged to provide your information to regulatory bodies. We may also be required to disclose your information to government agencies or law enforcement agencies, or when we are in receipt of a valid Court Order or search warrant. We may also disclose your information to outside sources to help us collect a debt owed to us by you. As well, we may disclose your information as a result of a transfer of our business, should we decide in the future to sell off all or part of our business or to merge with another financial institution.

Most of your information is in the form of account documentation and transaction records. You will receive copies of any documents you sign to open your account with us. You will also receive copies of monthly (or quarterly) statements of your account, which detail all of the transactions that have taken place in your account during that period. If you require further details about your information, you may contact us at any time. Naturally, we will have to assess your request to ensure that it does not contain references to other persons, or violate our legal privilege.

Having accurate information about you will enable us to give you the best possible service. We expect that you will provide us with updated information when you move or change telephone numbers, or have any other material changes in your information. If you detect any errors in information (such as the information appearing on your copy of your application form), please let us know immediately.

When you sign the documentation required to open your account, you will see that within that documentation is our Privacy Agreement. By opening an account with us, you are providing your consent for us to collect, use and disclose your personal information. If at any time you wish to withdraw this consent, please advise us. However, please note that withdrawing consent may mean that we will be unable to provide certain services to you. We will explain the consequences of withdrawing consent, should you choose to do so.

When you send Legacy Private Trust an email, we learn your exact email address as well as any other information you may have included in the email. While we may use your email address to reply to you, we do not make your email address known to anyone outside our firm. Please keep in mind that information sent via email is generally unencrypted, so we would remind you not to send us confidential information via email.