PRIVACY POLICY

Gary P. Kwasnecha & Company Ltd. operating as Financial Services Group (FSG) is committed to ensuring the privacy of all our clients. The conduct of our office personnel is bound by strict client confidentiality rules, respecting the private nature of all client data and communications. FSG handles your personal information in accordance with the Alberta Personal Information Protection Act, the BC Personal Information Protection Act, the N.W.T. Personal Information Protection Act, the Ontario Personal Information Protection Act, and the Federal Personal Information Protection Act and Electronic Documents Act ("PIPEDA") as applicable to each client.

Purpose

FSG, through its advisors and the support personnel, collect personal information from you for the purpose of offering you financial planning advice, and implementing your financial plan through the purchase of applicable financial products and ongoing services.

Information Collected

FSG personnel will collect:

• Demographic data (name, address, date of birth, Social Insurance Number, etc)
• Identification data (required for financial products) such as Driver's License number, Birth Certificate number, Passport number or health care numbers
• Financial data (income, investments, assets, liabilities, etc) and other personal data (retirement date, financial goals and objectives, risk tolerance, etc)
• In certain situations, other data, such as health information, will be collected should you wish to implement certain security products, such as Critical Illness, Life Insurance, Disability Insurance or Long Term Care Insurance.

Your personal information will be commingled for record-keeping purposes (both electronically and physically). Spousal information (unless you provide us with a notice to the contrary) will also be stored in these collective files.

Discloser to Third Parties

Information collected on applications, forms, and through personal correspondence or meetings with advisors and office personnel is made available only to members of our firm, our regulators when required by law or regulation, and to the extent of their implementation requirements, to other financial institutions utilized in your planning.

For regulatory purposes, self-regulatory organizations ("SROs") including the Mutual Fund Dealers Association (MFDA) require access to collected personal information of current and former clients, employees, agents, directors, officers, and others. This information is collected, disclosed and used for the following regulatory purposes: sales, financial compliance, regulatory audits; investigation of potential regulatory and statutory violations; regulatory databases; enforcement or disciplinary proceedings; surveillance of trading-related activity; reporting to securities regulators; and information-sharing with securities regulatory authorities, regulated marketplaces, and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

Frequently, the financial planning services we provide to our clients are based on the combined income, assets and objectives of client spouses. In the absence of a written request to the contrary, we will allow for the disclosure of personal information between spouses. We will also provide information, at your request only, to other third parties such as other family members, accountants and lawyers.

Record Retention

Personal information provided to us, required for the creation, updating and management of financial plans and purchase of financial products will not be destroyed in a scheduled manner. However, data deemed unnecessary to provide you with financial planning services and products will be destroyed in a confidential manner. Some client information is retained indefinitely for legal purposes.

Accuracy

You have the right to correct any of the personal information we have on file for you.

Consent

Your consent to the collection, use and disclosure of your personal information as described in the manner above, is given at the inception of your relationship with Financial Services Group. It is your right to withdraw full or partial consent. Please be aware that withdrawing your consent may prevent us from continuing to provide you with our services. To withdraw your consent, please contact us in writing.

Our Privacy Officer may be contacted at: