1. Accountability – Milestone is accountable for maintaining and protecting the personal information we collect. A Privacy Officer has been appointed to ensure our compliance with the Act.
2. Identifying Purposes – we will identify the purpose of all personal information collected either before or at the time of collection.
3. Consent - your knowledge and consent are required for the collection and use or disclosure of personal information, except as permitted by law. By signing your Milestone Investment Management Agreement you acknowledge and understand the need for us to collect this personal information and provide your consent for us to do so. You may withdraw your consent for us to use your personal information at any time, subject to any relevant legal obligations of Milestone.
4. Limiting Collection – the collection of personal information shall be limited to that which is necessary for the purposes identified by Milestone. Information shall be collected by fair and lawful means.
   
   At a minimum, to satisfy the Canadian Securities Administrators’ ‘know your client” regulations we must obtain the following information to open an account and properly manage an investment portfolio:
   • Social Insurance Number
   • Date of Birth
   • Home address and phone number
   • Employment information
   • Copy of driver’s licence or passport
   • Banking information
   • Net worth and income information
   • Citizenship
5. Limiting Use, Disclosure and Retention – Milestone will not sell, trade or lend your personal information, nor will we use or disclose personal information for purposes other than those for which it was collected, unless otherwise requested by you, or as required by law. Personal information shall be retained only as long as necessary for fulfillment of those purposes.
   
   In our business, there will be times when personal information must be disclosed to certain third parties in order for them to effectively deliver their services. These would include:
   • Our custodian and brokers
   • Regulatory Organizations including the Ontario Securities Commission
   • SS&C Technologies who provide our portfolio management software
   • Other service providers, such as mutual fund companies, who are required to issue tax information
6. Accuracy – personal information collected by Milestone shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
7. Safeguards – Milestone has implemented policies to safeguard against unauthorized access to your personal information. Confidential data is stored in locked filing cabinets and is accessible only to authorized personnel. Our offices are monitored by building security and we have alarm systems in place to ensure no one enters our premises without permission. Our computer network is secured by a “next generation” firewall that is regularly upgraded and access is password-protected. Additionally, when communicating personal information to clients electronically, Milestone’s policy requires that attachments be password-protected, unless a customer requests otherwise. The content of envelopes sent by postal mail or courier are verified by a second person before sending.
8. Openness – upon request Milestone will readily provide you with information about its policies and practices relating to the management and safeguarding of personal information. You may use any of the methods described in the section entitled “Contact Milestone’s Privacy Officer” to reach us.
9. Individual Access – you may request a copy of the personal information retained by Milestone on your behalf at any time (subject to satisfactorily identifying yourself to us), including details of how it is used and to whom it has been disclosed. If you find any errors in the data please let us know and we will make the corrections immediately. Of course you can help us maintain the accuracy of your information by notifying us of any changes as they occur.
   
   You may use any of the methods described in the section entitled “Contact Milestone’s Privacy Officer” to reach us.
10. Recourse (challenging compliance) – should you ever become concerned about the private information held by Milestone on your behalf or about our policies and procedures for safeguarding the privacy of your information, please contact us by any of the means described in the section entitled “Contact Milestone’s Privacy Officer” and we will advise you as to your avenues of recourse.

We use this information to operate and improve our website.

When you request information from us, we may use the email address that you provide to send you information about offers on services that we believe may be of interest to you. If you no longer want to receive email correspondence from Milestone, please contact us by any of the means described in the section entitled “Contact Milestone’s Privacy Officer”.

We provide links to certain other websites that we feel may be of interest to those viewing our site. Milestone provides these links as a courtesy and does not necessarily endorse or support the information or services described on these sites. Milestone is not responsible for the content or the privacy policies of the sites to which we provide a link.

Milestone’s Client Portal www.client.mstone.com uses session (or transient) cookies to identify users during their navigation of the portal only.

We are not concerned with who is using our site, but rather with how our site is being used. We track usage in order to modify the site according to our customers' needs. Please understand that any data captured from this system is for internal use only and is not shared with any other party.

Milestone may, from time to time, modify or supplement this Privacy Policy. We will post any revised version of this Privacy Policy on our website www.mstone.com and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on November 21, 2018.

Any interpretation associated with this Privacy Policy will be made by Milestone. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word "including" is used, it shall mean "including without limitation".

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Milestone any obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.