Privacy and Protection of Personal Information Policy

Vesta and Your Privacy

Vesta Wealth Partners Ltd. considers your personal privacy to be an important part of our service to you. We understand the need to safeguard information about you that you have entrusted to us. As part of our commitment to you we have adopted principles designed to protect your privacy and prevent misuse of your personal information and help you understand our commitment to your personal privacy.

References to " Vesta ", "we" or "our" are to Vesta Wealth Partners Ltd.. Where we use the term "personal information" we are referring to any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and Website use information, together with your personal references and identification numbers (such as a social insurance number).

Our privacy policy applies to personal clients, including individuals carrying on business alone or in partnership with other individuals. The following sections will answer most of the important questions that you may have about how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.

Vesta 's Principles on Privacy

We have incorporated certain principles for the protection of personal information in our privacy policy.

Why Does Vesta Collect Personal Information?

We collect, retain, and use personal information about you only when we reasonably believe that it will help administer our business or provide products, services and other opportunities to you as our client. We collect and retain personal information about you only for specific business purposes - and we will tell you why we are collecting and retaining it on your request. The information we ask for depends on the products or services you request and in most cases are required by law or the policies of the regulatory bodies to which we are subject.

Your social insurance number is required for products that earn investment income, in order to comply with the Canada Revenue Agency's income reporting requirements. If you provide your social insurance number, we also use it to keep your personal information separate from that of other clients with a similar name.

With your consent, we may share your personal information, where not prohibited by law, to affiliated companies of Vesta for the purposes of providing other services to you. Vesta may use your personal information to provide you with information about Vesta's products and services and other matters. This consent is optional and you can decide to withdraw it at any time. Please refer to our section regarding your options below.

How Does Vesta Collect Personal Information?

We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties.

When Does Vesta Release Personal Information?

Vesta does not sell client lists or personal information to others.

We do not reveal personal information about you to parties outside our affiliated companies for their independent use unless you request or authorize it or the information is provided in order to complete a transaction initiated by you or the disclosure otherwise is lawfully permitted or required. We may disclose information to the authorities to serve a clear public interest and fulfill our public duty - such as to protect against fraud, money laundering or other criminal activity. We may, from time to time, be requested to disclose information to regulators to which we are subject for the purposes of an audit or investigation relating to specific accounts or our business generally. In certain circumstances, Vesta may disclose your personally identifiable information if it believes, in good faith, that disclosure is otherwise necessary or advisable to protect its interests.

Sometimes it is necessary to provide personal information about you to a party outside our company, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. These vendors and service companies agree to safeguard confidential information about you and your products and services with us and must abide by applicable law.

Does Vesta provide options?

It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from third parties. In many cases you are free to refuse or withdraw your consent at any time. If you choose not to provide requested personal information or consents, we may not be able to provide certain products and services to you or you may be ineligible for or be unable to use certain products and services we provide.

Vesta will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record and respect your choices. If you wish to discuss your options you may do so by contacting Vesta's designated privacy officer set out below, or contacting our Compliance Department. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.

How Long Does Vesta Retain Personal Information?

We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.

How Does Vesta Protect Personal Information?

Vesta stores and processes your personal information in Calgary, Alberta, Canada. Certain personal information about you is retained by the Vesta office that handles your account.

We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. Our security standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity of our personal information.

We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.

All our suppliers and agents, as part of their contracts with Vesta, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required - otherwise we will seek your consent prior to disclosing any information.

What about the internet?

We share your concern about your privacy in the Internet world and are committed to its protection. The principles set out in this privacy policy apply equally to anything you might do at our Website.

You may be asked to provide certain personal information as part of an application for use of our Website service. If, as part of such application, Vesta requests that you transmit confidential information to us over the Internet, we ensure that such transmission is encrypted. We use your logon id to identify you as a user of the service. We use the transaction information in the aggregate to assess and improve the service. You can contribute to the confidentiality of your personally identifiable information when using the Vesta Website by not disclosing your designated username and password to anyone.

When you send us an e-mail or when you ask us to respond to you by e-mail, we learn your exact e-mail address and any information you have included in the e-mail. We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We will not sell your e-mail address to anyone outside of Vesta. We may use your e-mail address to send you information about our products or services that we believe may be of interest to you. If you don't want us to contact you with product information by e-mail, you may tell us so at any time. Remember e-mail over the Internet is generally unencrypted. We recommend that you do not send us sensitive or confidential information by ordinary e-mail, as unencrypted e-mail is generally not secure.

Our Website may contain links to other Websites. When you click on one of those links, you are contacting another Website for which Vesta has no responsibility and over which Vesta has no control.

How Do I Access My Personal Information?

You may request access to your personal information on record with Vesta and information about Vesta's use and disclosure of that information by contacting your portfolio or relationship manager or by contacting the Vesta office directly. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request promptly but in any case within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Vesta, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.

How Do I Keep My Personal Information Accurate?

Vesta attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Who Should I Contact Regarding Privacy Issues?

Vesta has designated a privacy officer, Jared Wolk, to respond to your concerns or questions about privacy and confidentiality - or any concerns about the way a request for personal information was handled. To reach our privacy officer, please refer to the following: in writing, at 640, 330 5th Ave SW Calgary Alberta T2P 0L4; by telephone, at 403-930-0700; by facsimile, at 403-930-0701; or by e-mail, at