SEI INVESTMENTS CANADA
PRIVACY POLICY

At SEI Investments Canada Company (“SEI”), we recognize the importance of respecting identifiable information about individuals (“Personal Information”) and maintaining privacy. We are committed to protecting Personal Information that is collected through all our standard and online business processes, in accordance with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other applicable laws and regulations governing collection, use and disclosure of Personal Information (together “Privacy Laws”).

SEI’s Privacy Policy and Procedures (“Policy”) are in accordance with the 10 guiding privacy principles incorporated into PIPEDA.

Accountability
SEI has appointed a Privacy Officer who is responsible for implementation and ongoing compliance of this Policy. Every employee of SEI is also required to abide by the Policy and maintain the confidentiality of Personal Information that is collected and used by the organization.

Personal Information Collected
Where SEI collects Personal Information on it’s own behalf, it may collect Personal Information such as name, date of birth, Social Insurance Number, personal income, investment information, and other financial or lifestyle information that will allow it to service its accounts and meet it’s regulatory obligations.

Visiting the SEI Website
This Policy applies equally to all Personal Information collected by SEI including information collected on the SEI website. SEI collects information from website visitors through the use of cookies. A cookie is a piece of data stored on a user’s hard drive containing information about the user (which can include Personal Information). SEI can use cookies to deliver user specific content. Although a cookie on its own does not disclose a user’s identify, it will identify a user’s browser to SEI servers. Browsers can be set to refuse cookies. If you do not accept cookies, you may be limited in access to some areas of the SEI website.

Identifying Purposes
SEI will collect and use Personal Information for the following purposes:

1) Where SEI is a service provider for an individual, we collect and use Personal Information to:
i. Establish and service the individual’s account and respond to requests made by or on behalf of the individual.
ii. Develop and offer additional products and services that we believe may fit the individual’s needs and to communicate, advise and inform the individual about such additional products and services.

2) In other relationships that SEI maintains with advisors, consultants and prospective clients, SEI may collect Personal Information during the course of normal business activity, as permitted by law.

3) To develop and offer additional products and services.

4) To maintain key contact information in our firm’s contacts database.

5) To compile statistics about our client base and conduct market research.

6) To protect against error and fraud.

7) To satisfy legal, regulatory and other requirements of industry organizations that SEI is or may become a member of, such as the Mutual Fund Dealers Association.

In situations where SEI acts as a service provider for institutional entities (such as pension plans or endowments), SEI does not collect any Personal Information on its own behalf, but only acts on Personal Information that is provided by its clients. This may be done through the course of normal business activity, through dealings with the client’s other service providers and as part of services such as asset allocation planning.

In these situations, individual requests for information regarding Personal Information collected about them will be redirected back to the client.

Limited Disclosure of Personal Information
At SEI we are committed to safeguarding your Personal Information and maintaining your privacy. Except as provided in this Policy or as permitted by law, we do not sell or disclose Personal Information to third parties unless we have your prior written consent.

Personal Information collected by SEI may be subject to transfer to another company in the event of a change of ownership of all or part of the organization. This will only occur where the parties have entered into an agreement under which the collection, use and disclosure of Personal Information is restricted to those purposes that relate to the business transaction, including a determination of whether or not to proceed with the
business transaction.

SEI also shares Personal Information with the following parties:

1) Parties representing individual clients, such as investment representatives, or other third parties as directed by the individual.

2) Regulatory and government entities as part of normal legal/regulatory requirements.

How SEI Protects Personal Information
Only authorized and trained SEI employees are permitted to have access to files containing Personal Information. Personal Information is stored in paper and electronic files at regional SEI offices.
SEI will only retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected or to meet legal or business requirements.
SEI utilizes physical, electronic and procedural safeguards in order to protect the Personal Information we have under our control against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our commitment to Personal Information security involves monitoring new advances in security technology and enhancing our security architecture to ensure that we provide the highest level of privacy and safety available. However, we cannot guarantee that the information submitted to, maintained on, or transmitted by electronic means to SEI will be completely secure.

Consent
Your provision of Personal Information to SEI means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. If you do not agree with these terms, please contact us at the number provided below so that we may implement your choices. Please note however, that withdrawing your consent may affect our ability to continue to provide you with some products and services. Individuals can also opt-out of receiving informational updates on SEI products and services by contacting our Privacy Officer directly as indicated below.

Individual Access to Personal Information
SEI is committed to protecting your Personal Information and ensuring that it is kept up to date, accurate and complete as necessary for the purposes for which SEI uses the data.

Where SEI has collected Personal Information about you on its own behalf, please contact SEI’s Privacy Officer at the address below to:

1) Ask questions or express your choices about the collection, use or disclosure of Personal Information by SEI;

2) Request access to your Personal Information;

3) Request an update for any information that is inaccurate, incomplete or out of date by sending a written request to our Privacy Officer at the address below; or

4) Register a privacy-related complaint.

SEI Investments Canada Company
Attention: Privacy Officer
70 York Street, Suite 1600
Toronto, Ontario
M5J 1S9
Phone: 416 777 9700
Email: privacyofficecanada@seic.com