Scope and Application of Policy

We are committed to protecting and maintaining the accuracy, confidentiality and security of your personal information as a client of Gateway. This Client Privacy Policy describes the personal information Gateway collects from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Client Privacy Policy (“Policy”) applies to all commercial and business relationships in which Gateway is engaged. The Policy is intended to comply with privacy legislation relating to commercial activity in all jurisdictions in which Gateway operates, where such legislation is in force. In Canada, to the extent that Gateway operates in provinces that have not adopted privacy legislation, this policy complies with federal legislation, which governs such jurisdictions.

Privacy Officer

In order to ensure compliance with this policy and applicable privacy legislation, Gateway has appointed a Privacy Officer. Gateway’s Privacy Officer will also address and evaluate complaints to the policy on a case-by-case basis. If you have any questions or complaints about the application of this policy, please contact Gateway’s Privacy Officer:

Sam Lancaster
Privacy Officer
Gateway
2236 – 10 Aspen Stone Blvd S.W.
Calgary, Alberta T3H 0K3, Canada

Direct Telephone: (403) 240-3246
Confidential Fax: (403) 240-4570
E-mail: sam.lancaster@trumanhomes.com

Collection, Use and Disclosure of Personal Information

For purposes of this Client Privacy Policy, personal information means any information about an identifiable individual, other than the person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business with you or provide services or products to you.

The type of information we collect about you includes the following:

• Information such as your name, home address, telephone number and e-mail address
• Social Insurance Number, identity card number, or other government identification number
• Copies of any agreements you enter into with us
• Information that you provide to us, such as your preferences, identities of your advisors and decision makers, feedback and comments
• Credit and financial information
• Verifying your identity in order to grant website access

Gateway uses the personal information above for different purposes relating to the management of our business and our relationship with you. These purposes include, but are not limited to the following:

• Establishing, maintaining and managing a business relationship with you so that we may provide you with services or products that you have requested
• Enabling us to comply with your requests such as preferred method of communication
• Sharing your personal information with a party representing you, such as your investment representative, financial planner or to other third parties at your direction/consent
• Enabling us to review the products and services that we provide to you so that we may understand your requirements for our products and services and improve our products and services
• Sharing your personal information within Gateway for purposes of contacting you in your role as an investor, including informing you of investment opportunities
• Protecting our business from error, fraud, theft and damage to our goods and property
• Enabling us to comply with applicable law or regulatory requirements (including tax requirements)
• Safeguarding and protecting Gateway’s confidential information
• Other purposes reasonably required for the management of our business relationship with you and the management of Gateway’s business

Gateway shares your personal information with its employees, auditors, contractors and consultants and other parties, including its subsidiaries and affiliated companies who require such information to assist us with administering our business relationship with you. These include third parties that provide services to us or on our behalf, third parties that collaborate with Gateway in the provision of services to you and third parties with whom we contract to perform our services.

In addition, your personal information may be disclosed or transferred to another party (including to another member of the Gateway or an affiliate of Gateway) in the event of a change in ownership of, or a grant of a security interest in, all or part of Gateway through a sale transaction or some other form of business combination, merger or joint venture. We will disclose personal information in these circumstances only when the third parties agree to use such personal information solely for the purposes evaluating and carrying out the transaction and, with respect to that information, to act in manner consistent with the principles articulated in this Client Privacy Policy.

Gateway may contract with third parties located in one or more countries outside of Canada, including potentially in the United States of America to provide Gateway with processing, storage or other administrative or data-related services. Please be advised that in that case your information may be transferred to, processed, used and stored in those countries, and that the governments, courts or law enforcement or regulatory agencies located in those countries may be able to obtain disclosure of your information through the laws of, or pursuant to a lawful order made in, those countries.

What Data We Collect and How We Use It

We may collect the following categories of information for the purposes explained below.

• Website activity: This is data about your browsing activity on the website. For example, which pages you visited and when.
• Device and browser information: This is technical information about the device or browser you use to access the website. For example, your device’s IP address, cookie string data and (in the case of mobile devices) your device type and mobile device’s unique identifier such as the Apple IDFA or Android Advertising ID.
• Hashed email addresses: We may collect hashed versions of the emails that are entered on that Advertiser’s site. These hashed emails are used as an additional identifier to help us better target ads for Advertisers, including across multiple devices or browsers.

Your Choices and Opting-out

We recognize how important your online privacy is to you, so we offer the following options for controlling the targeted ads you receive and how we use your data:

• You can opt out of receiving targeted ads served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve or by clicking here. Please note that, if you delete your cookies or upgrade your browser after having opted out, you will need to opt out again. Further, if you use multiple browsers or devices you will need to execute this opt out on each browser or device. If you opt-out we may collect some data about your online activity for operational purposes (such as fraud prevention) but it won’t be used by us for the purpose of targeting ads to you.

Consent

We require your consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By providing us with the personal information described in this Policy, we assume you have impliedly provided Gateway with your consent to collect, use and disclose your personal information in accordance with this Policy.

You may withdraw or limit your consent to Gateway’s collection, use and disclosure of your personal information at any time, subject to your legal and contractual obligations you may have to us as a result of our business relationship. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to our Privacy Officer in writing.

In some circumstances, Gateway is entitled, or required, to disclose your personal information without your consent. These circumstances include, but are not limited to:

Protecting your health or safety

• The disclosure is necessary for an investigation or proceeding
• The disclosure is required or authorized by law
• The disclosure is required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information
• The disclosure is to a public body and relates to an investigation of an offence
• The disclosure is to a lawyer who is representing Gateway
• The disclosure is required to respond to an emergency
• Where the personal information is publicly available

Accuracy and Retention of Personal Information

Gateway endeavours to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If your personal information changes or you believe information we have about you is not accurate, please notify us as soon as reasonably possible. Any request to verify or correct your personal information must be made in writing to Gateway’s Privacy Officer. In some circumstances, we may not agree to your request to change your personal information, but will instead append an alternative text to the record in question.

We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of your business relationship with us but it will only be for as long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.

Safeguarding Personal Information

Gateway is committed to protecting the security of your personal information. We endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Access to Your Personal Information

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing to Gateway’s Privacy Officer. Gateway will endeavour to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. We may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Gateway reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:

• Would disclose personal information, including opinions, about another individual
• Would disclose Gateway’s trade secrets or other confidential business information
• Is subject to lawyer-client privilege
• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information
• Does not exist or cannot be found
• Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual
• May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions
• May be or is required to be withheld by other legislation

Where information requested will not or cannot be disclosed, Gateway will provide the reasons for non-disclosure.

Revisions to This Policy

Gateway may amend this Client Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Policy on our website at www.liveatGateway.com. We encourage you to review the website on a regular basis. Any changes to this Policy will be effective as of the date posted on the website.

Interpretation of This Policy

The Privacy Officer has the responsibility and authority to interpret and administer this Policy. This Policy does not create or confer any additional rights or obligations to those imposed under provincial or federal privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and applicable provincial or federal privacy legislation, then this Policy will be interpreted to give effect to and comply with such privacy laws.