Louisbourg Investments Inc. (“Louisbourg”) is committed to protect the confidential information of its clients, employees, and long-term consultants. The Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) applies to any organization, which collects, uses or discloses personal information during its activities. PIPEDA and the provincial legislations apply to Louisbourg when dealing with its clients, employees, and consultants.

Under all circumstances, it is understood that Louisbourg shall protect the confidentiality of any information it is entrusted with.

This policy sets out Louisbourg’s standards for collecting, using, disposing, and storing the personal information of our clients, employees, and long-term consultants. This Policy also explains how we safeguard the personal information and the right to access that information by our client and employees.

Identifying Purposes
For Clients

The purpose of the collection and verification of information is to both ensure that Louisbourg’s clients are protected by assisting them in determining investment objectives, risk tolerance, and suitability of investments, and to satisfy Louisbourg’s legal and regulatory obligations, including potential insider relationships, the prevention of possible money laundering, and tax evasion.

For Employees and long term consultants

The personal information gathered shall be used for the employment contract between Louisbourg and the employee or its consultants and for the application of the Personal Trading Policy.

Limiting Use, Disclosure, Retention

When personal information is collected from clients, it is to be retained for the period during which clients maintain an account with Louisbourg and for a period following the termination of the account, which is stipulated, by law or regulations. When personal information is no longer required, it is to be disposed of in a secure manner.

The personal information collected from any employee or any long-term consultant will be retained for the period during which the employee is with Louisbourg and for a period following the termination of the employment or contract as provided by law or regulations.

As a portfolio manager, Louisbourg may in, certain cases, be required to make certain personal information of its clients, employees or long-term consultants available to certain companies, government agencies, regulatory and self-regulatory agencies and organizations. These entities are bound to ensure the confidentiality of the personal information provided by Louisbourg. The communication of personal information shall be done with the consent of the individual unless otherwise required by law.

The personal information shall not be preserved for longer than needed for the established purposes. After which any such information shall be disposed of in a secure manner.

Accountability

Louisbourg has appointed a Privacy Officer who is responsible for ensuring that Louisbourg complies with the principles outlined in this Privacy Policy and its related procedures.

All employees and long-term consultants of Louisbourg are bound by Louisbourg’s established Policy and procedures to ensure that the personal information of its clients remains confidential.

Accuracy

Louisbourg is committed to maintaining accurate records of its clients’ personal information. From time to time, Louisbourg will request updated account documentation to ensure that the personal information is complete and accurate.

Safeguarding Client Information

Louisbourg has implemented and continues to maintain rigorous safeguards to ensure that the personal information remains confidential and is protected against loss or theft, as well as unauthorized access or disclosure.

Protection methods include limited access to the premises, technological measures such as off-site backups and archiving to protect personal information of its clients.

Request for Access to Information

All clients, employees, and long-term consultants have the right to request any information we hold about them and to see this information. They also have the right to enquire on how we used it and to whom it may have been disclosed.

Questions regarding Louisbourg’s Privacy Policy and the assurance of the confidentiality of the personal information, if any, collected from clients, employees, and long-term consultants may be directed, in writing, to:

Louisbourg Investments Inc.
c/o Privacy Officer
Regulatory and Compliance
770 Main Street
Suite 1000
Moncton, New Brunswick E1C 1E7

Complaints and Concerns

A complaint concerning the protection of personal information should be addresses to the Privacy Officer at the address provided above.

Compliance

This policy and the related procedures will be reviewed periodically to ascertain their conformity and effectiveness. Furthermore, the Privacy Officer will send at least on annual basis or further to any changes a reminder of the Policy and its related procedures to all employees and long term consultants.