At Invesco Canada, our focus is to put clients’ interests first. As one of Canada’s leading investment management companies, our reputation has been built on a foundation of investment discipline and a track record of success. A subsidiary of Invesco Ltd., our focus is on investment management, offering a diversified suite of solutions to institutions, organizations, companies and individuals across Canada and around the world.

The following is provided to give you information on our commitment to protecting your privacy and maintaining and safeguarding the confidentiality of your personal information.

What is personal information?

Personal information means any information about an identifiable individual, including information such as your home address and telephone number, date of birth, age, marital status, employment history, Social Insurance Number and credit history.

How do we collect your personal information?

Personal information is collected either directly from clients or through a financial services professional such as a financial advisor. The information is obtained by us when clients or advisors send us completed applications, agreements, forms or other documents by paper or electronically. In servicing our clients’ accounts, we may also generate personal information, including, where applicable, transaction information, and account statements. From time to time, we may be required to collect information from a third party who is not a financial advisor (for example, an executor of an estate account or a third party consultant), and such information may be considered personal information as well.

What information do we collect?

The personal information in client accounts may include the name, mailing address and phone number(s), social insurance number, birth date, account holdings and transactions and the name and address of the named beneficiaries of our clients. Other types of information we may collect and hold in client accounts depend on the investment or services requested. For example, where a client has established a pre-authorized chequing plan which enables them to make purchases at regular intervals, we maintain the client’s financial institution account number. At times, we may request independent sources to verify and supplement information that is provided to us.

E-mail policy

We do not sell or share our list of e-mail addresses with any third parties for marketing purposes.

How we use your e-mail address:

• If you are a registered user of www.invesco.ca, you must provide us with a valid e-mail address, there may be times we may need to contact you regarding your account at www.invesco.ca. Please note that you will never receive an e-mail from Invesco Canada asking you to provide your login ID, password or any other sensitive personal information.
• If you voluntarily subscribe to our e-Option service, you will receive an e-mail when information you requested is available online. You may update your eOption settings at any time.
• In order to provide the best service possible, we may wish to contact you with information about Invesco Canada that we feel is of interest to you. Should you receive an unwanted e-mail from Invesco Canada, you may opt out of future mailings at any time either by logging into your personal account and changing your e-mail settings or by contacting Invesco Canada directly.

How do we use personal information?

We may use personal information for these stated purposes:

• Identifying clients and determining clients’ eligibility to invest in our products (where applicable)
• Establishing and administering client accounts, which involves determining, maintaining, recording, and storing account holdings and transaction information in applicable client records
• Ensuring the information in our records is accurate
• Executing client transactions
• Verifying previously given information when necessary
• Providing clients and ,if applicable, advisors/dealers with account statements and other account related information
• Providing financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service client accounts
• Communicating with clients and, if applicable, advisor/dealers regarding service
  offering or products which may be of interest to you
• Meeting legal and regulatory requirements

We do not sell personal information. We may use personal information for general research in an effort to enhance our service and product offerings.

When is information disclosed to third parties?

We disclose personal information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy and for no other purpose. Third parties who may be provided with personal information include:

• Advisors/dealers, where applicable
• Other mutual fund companies, financial institutions and securities dealers whennecessary to carry out client instructions such as transferring funds
• Other Invesco Canada affiliates, who perform services for us, such as advisory services, back office functions and record keeping, or whose products are a constituent of an Invesco Canada product
• Domestic and international governments, government agencies, law enforcement agencies and regulators (only when compelled by law)
• Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, imaging and document storage

At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party’s jurisdiction, including laws with respect to disclosure of such information.

Invesco Canada ensures that the third party provides a comparable level of protection for that personal information, and that use of the personal information is limited to purposes set out in this policy.

Disclosing your personal information when required or permitted by law We may also disclose personal information in connection with:

• A corporate reorganization in which case the information would only be shared with employees of the organization who have a strict need to know the information to evaluate the reorganization.
• A potential merger or amalgamation with another third party or a sale of all or a substantial portion of our assets to enable that third party to evaluate the transaction and, in that case, the information would only be shared with members of that organization who have a strict need to know the information to evaluate the transaction
• An actual merger, amalgamation or sale of all or a substantial portion of our assets where you would then become a client of a different organization

In all cases above, Invesco Canada will only disclose the information if the third party has agreed to: protect the information at least as well as we do under our privacy policy;

only share it with members of their organization who have a strict need to know the information; and use it only for the purpose of the transaction and for no other purpose. Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose personal information to a third party without client consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities.

We may disclose user information when we believe in good faith that such disclosure is required by and in accordance with the law.

How do we obtain your consent?

In providing information to us, either directly or through a financial services professional such as a financial advisor, and continuing to conduct business with us, you are consenting to the use of your personal information.

How can you withdraw your consent?

You may withdraw your consent to our use of your personal information at any time by contacting us at 1.800.874.6275. If you withdraw consent, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.

How can you access and update your information?

Invesco Canada will provide you with reasonable access to your personal information on your written request. Our verification procedures help to ensure that personal information is only released to the correct authorized person. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law.

Except under limited circumstances, you may ask us to amend or update your personal information at any time. Invesco Canada reserves the right to charge you minimal costs incurred in providing the information requested. If you have a sensory disability, please let us know and we will make every effort to provide your personal information in an alternative format.

Invesco Canada may not be able to provide you with full access to your information if:

• It contains references to other persons
• We would have to disclose proprietary information confidential to Invesco Canada or its affiliates
• It has been destroyed
• It cannot be disclosed for legal or regulatory reasons
• If we are unable to provide you with access to your personal information, we will give you an explanation.

How is your information protected?

Invesco Canada is as concerned with protecting your personal information as you are. We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and file encryption for online activities. Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing client accounts.

What online protocols are in place online to protect your information?

At Invesco Canada, we take the issue of privacy seriously. We want to assure you that the security and confidentiality of personal information that you disclose while visiting Invesco Canada’s websites will be respected. Policies governing the protection of privacy on the website are strictly observed and enforced to ensure this happens. Privacy, security and confidentiality are as important online as with all our other business functionality.

Along with our privacy policies, we employ usage of firewalls, encryption of all data, and user authentication protocols. We may also place cookies on your computer to allow for easier navigation and to customize your web experience on our sites. A cookie is a piece of information about an internet session that may be created when a visitor accesses a website.

We use the information collected from you when you visit our website to address your specific requests and to provide better customer service. It may also be used to document communications between Invesco Canada and our online visitors and to comply with any applicable legal and/or regulatory requirements. If you have any questions about the protection of your personal information that you have disclosed on Invesco Canada’s websites, you may send an e-mail to privacy@invesco.com so that we can address your questions as quickly and completely as possible.

How long do we keep your information?

In order to service your account and to meet regulatory and legal obligations, Invesco Canada may be required to maintain information related to you and your account for a certain period of time. Personal information may be destroyed once it is deemed that your information is no longer necessary for the above-mentioned reasons. Personal information is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.

Will we change this policy?

If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. You have a right to know at all times what information we collect, how it is used, and under what circumstances we can disclose it. Any change to this policy will become effective on the date the change is posted on our website.

You will be able to clearly see the effective date at the lower left hand corner of the web page. We recommend that you print a copy of the updated policy for your reference and revisit it from time to time to ensure you are aware of the changes.

Resolution of your concerns:

If you have any issues or concerns, please take the following steps:

Step 1. Your issue or concern may be easily resolved by contacting our Client Relations group:
Telephone: 1.800.874.6275
Fax: 1.800.631.7008
E-mail: inquiries@invesco.ca

Step 2. If speaking to our Client Relations group does not resolve your issues or concerns, you may contact the Privacy Officer at Invesco Canada at privacy@invesco.com or by calling 1.800.588.4880 and request to speak to a Privacy Officer.

Step 3. If after contacting the Privacy Officer your issue or concern has not been resolved, you may contact the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1.800.282.1376 or 819.994.5444
Fax: 819.994.5424
TTY: 819.994.6591