Use of Personal Information

Our office generally uses personal information to manage and administer our business, including to understand your insurance needs, communicate with you effectively and to provide you with information regarding current and future products.

For example, our office may use your personal information to:

• determine your eligibility for, offer and/or provide you with insurance products, investments and services that you request;

• establish your account, execute your transactions and maintain your account information;

• evaluate credit worthiness and monitor, collect premiums and fees;

• verify your identity;

• ensure your personal information is accurate and up-to-date;

• determine prices, fees and premiums including by evaluating your coverage needs and assessing risk;

• maintain, administer, collect, service and renew your account(s) and assess your ongoing needs for insurance products, investments and services;

• investigate and settle claims;

• determine your eligibility for and offer and provide other products or services that may be of interest to you, such as insurance, investment or retirement products or group benefits, unless you ask us not to;

• detect and protect against error or fraud;

• maintain business records for reasonable periods;

• meet legal, regulatory, self-regulatory, insurance, security and processing requirements; and

• otherwise with consent or as permitted or required by law.

Disclosure of Your Personal Information

As necessary to carry out the purposes for which our office collects and uses your personal information, our office may disclose your personal information to third parties. This may include our wholesale organizations known as Managing General Agencies (MGA), and others such as other insurance brokers, insurers, claims adjusters, government, regulatory and self-regulatory agencies, lawyers, accountants, bookkeepers, financial institutions, benefits providers and medical professionals, and others involved in the claims handling process in accordance with legal and insurance regulatory reporting requirements or standard accepted insurance brokerage and insurance practices. Our office may also disclose your personal information with your consent or as permitted or required by law.

Your Consent

Our office collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us.

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for a service you have requested). You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information either directly or through our agents, other insurance brokers, insurance companies, claims adjusters or your employer, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Privacy Statement, if applicable, or otherwise at the time of collection.

If you obtain insurance for a family member or other third party or otherwise provide personal information concerning a third party, including a family member, for example by naming him/her as a beneficiary, you represent that you have obtained any necessary consent to our collection, use and disclosure of his/her personal information for the purposes described above.

You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. There may be consequences to failing to provide or withdrawing your consent, such as your inability to acquire or renew an insurance policy and/or cancellation of a policy. Note also that where we have provided or are providing services to you, your consent will be valid for so long as necessary to fulfill the purposes described in this Privacy Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and foreign government entities as required to comply with laws).

Security

We take reasonable physical, organizational and technological security measures, such as locked filing cabinets, confidential shredding and a security system to safeguard the personal information in our custody or control. These safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized employees or agents of our office who require access to your personal information in order to fulfill their job requirements will have access to your personal information.

Access, Correction and Contacting Us

Our office may establish and maintain a file of your personal information for the purposes described above. Subject to applicable legal restrictions, you may request to have access to the file containing your personal information and the correction of your personal information by writing to the address below. We may take reasonable steps to verify your identity before granting access or making corrections. In addition, if you wish to make inquiries or complaints, obtain information on how to access and rectify the files held by personal information agents we consulted, have other concerns about our personal information practices, or report a breach of privacy, you may write to the address below. Please include your name, address, telephone number and email address whenever you contact us, including by email. This helps us handle your request correctly.

Swell Private Wealth Ltd.

201 – 462 4th St S.E.,

T1A 0K6

Attention: Privacy Officer Steve Meldrum

steve@swellwealth.com

If you feel your concern has not been addressed correctly, you may contact the product provider directly or the Privacy Commissioner of Canada for assistance between the hours of 8:30 a.m. to 4:30 p.m. EST, at 1-800-282-1376 or online at http://www.priv.gc.ca.

Privacy Statement Changes

This Privacy Statement may be revised from time to time. If we intend to use or disclose personal information for purposes materially different than those described in this statement, we will make reasonable efforts to notify affected individuals, if necessary, including by revising this Privacy Statement. If you are concerned about how your personal information is used, you should contact us as described above to obtain a current copy of this statement. We urge you to visit our website to obtain the current version and review this Privacy Statement frequently. Your continued provision of Personal Information or use of our products or services following any changes to this Privacy Statement constitutes your acceptance of any such changes. This Privacy Statement is effective as of 20 July 2017.