OPEN ACCESS PRIVACY POLICY

Effective Date: Feb 1 2017

The Open Access Privacy Policy is to be read with, and is subject to, the Open Access Website Terms of Use.

Open Access Limited (“Open Access”, “we”, “us” or “our”), respects your privacy and protect the confidentiality of your personal information. This Privacy Policy explains our practices and procedures concerning the collection, use, disclosure and retention of personal information and reflects our commitment to compliance with applicable privacy laws, including the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

Personal Information We Collect

Personal information is any information about an identifiable individual. Most of the personal information we collect is received either directly from individual plan members (“Members”) or from sponsoring employers (“Sponsors”).

We collect personal information as necessary to allow us to provide retirement plan and related services. We collect name and contact information from Sponsor representatives.

In order to establish and operate individual plan member accounts, we require various kinds of personal information about Members including the following:

· Name and contact information.

· Social insurance number.

· Place of employment.

· Date of birth.

· Family member information for spousal accounts.

· Beneficiary information.

· Termination information.

· Salary range.

· Net worth including information about your savings, assets and investments.

· Investment and retirement objectives.

Each Member is asked to complete an Investor Profile which provides us with the personal information required to set up and operate that Member’s account, including information that enables us to select the correct investment portfolio and update that portfolio selection as required.

How We Use Personal Information

We use Member personal information in order to establish, operate and maintain the Member’s account or retirement plan. This may include verifying a Member’s identity, evaluating a Member’s investment and retirement objectives and determining the suitability of our products and services for that Member and communicating with the Member, including providing periodic account statements, newsletters, and information about other products and services.

We use personal information relating to Sponsors and their representatives in order to establish, operate and maintain the Sponsor’s employee benefit plan. This includes providing plan related communications, and communications about other products and services.

We may use personal information as necessary to comply with our legal, regulatory, self-regulatory, audit and insurance requirements, and for other purposes with your consent or as permitted or required by law.

When We Disclose Personal Information

We may retain third party service providers (including affiliates and advisors acting in this capacity) to assist us with administrative tasks related to account and plan operation and maintenance (including for information technology, data hosting, data processing, marketing, analytics, audit, statistical or record-keeping purposes. Where these service providers are given access to personal information in connection with services performed for us, they are made aware of and are required to comply with this Privacy Policy. The information disclosed to service providers in such circumstances will also be limited to that required in order to fulfill the purpose(s) for which disclosure is taking place. Some of these service providers may be located outside of Canada, including the United States, and as a result, your personal information may be processed and stored outside of Canada. While outside of Canada, personal information will be subject to applicable foreign laws, which may permit foreign government, regulatory or national security agencies to access information in certain circumstances.

We may disclose personal information in the context of an actual or possible corporate reorganization, merger or amalgamation, or an actual or possible sale of all or a substantial portion of our assets. In such circumstances, disclosure would occur on the condition that the information only be used for the purpose of evaluating the transaction, or on completion of the transaction, for the purposes outlined in this Privacy Policy.

We may disclose personal information as necessary to meet legal, regulatory, industry self-regulatory, insurance, audit and security requirements, and otherwise with your consent or as permitted or required by law, including as necessary to comply with Canadian and foreign laws applicable to us or our service providers. For example, we disclose to the Canada Revenue Agency such information as is required by law for income tax reporting.

Our Website

Our website may use tracking technologies, such as “cookies”. A “cookie” is a small text file containing a unique identification number that identifies the Internet browser of the visitor. This information is transmitted to us each time our website is visited. Cookies allow us to collect and store information such as the type of Internet browser and operating system you use; the date, time and duration of your visit to our website; the Internet address of the website from which you linked to our website; and the pages that you visited while on our website. Unless you actively submit personal information while on our website, however, we will not normally be able to use cookies to determine your identity. You may be able to adjust your browser settings to block cookies or to notify you before a cookie is sent.

Consent

Consent to the collection, use and disclosure of personal information may be given in many ways. For example, by completing and signing the Open Access Investor Profile, Members expressly consent to the collection, use and disclosure of their personal in accordance with this Privacy Policy. Consent may also be implied if you provide your personal information for a specific purpose. If you provide us with personal information relating to someone else (for example, a spouse or beneficiary), we will assume that you have obtained that individual’s consent to provide their personal information to us for the purposes described in this Privacy Policy.

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. For example, if you no longer wish to receive our newsletters or promotional communications, you may withdraw your consent at any time by contacting our Privacy Officer or by using the unsubscribe feature in the message, where applicable. However, if you withdraw your consent to certain collections, uses or disclosures of your personal information, we may not be able to continue to provide you with our products and services.

Safeguarding your Personal Information

Personal information is maintained in a file on our servers (or those of our service providers) and will be accessible by authorized employees, agents and representatives who require access in order to provide products or services to you or to maintain those products or services. We employ various physical, electronic and procedural safeguards to protect your personal information.

Retention of Personal information

We retain personal information for as long as is necessary to fulfill the purpose(s) for which it was provided, unless we are required or permitted by law to retain the information for a longer period. Personal information that is no longer needed is securely destroyed or made anonymous as appropriate.

Accuracy and Access

You may request access to or correction of the personal information we hold about you by writing to our Privacy Officer using the contact information set out in the “Questions or Concerns” section below. Your right to access or correct personal information is subject to applicable legal restrictions. If we are unable to provide access, where possible, we will provide reasons for our inability to do so. We may take reasonable steps to verify your identity before granting access or making corrections.

Updates to this Privacy Policy

This Privacy Policy is effective as of the date noted above. From time to time we may update this Privacy Policy. We recommend that you review this Privacy Policy frequently to obtain the current version. Your continued provision of personal information or use of our services following any changes to this Privacy Policy constitutes your acceptance of any such changes.

Questions or Concerns

Our compliance with this Privacy Policy and with applicable privacy laws is overseen by our Privacy Officer. If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

Privacy Officer

1 Richmond Street West, Suite 800

Toronto, Ontario

M5H 3W4

(416) 364-8877

compliance@openaccessltd.com