Canada

Modifications
How We Collect and Use Your Information
How We Secure Personal Information
Who We Share Personal Information With
How We Offer Goods and Services
Third Party Sites
Your Rights and How to Assert Them

Unless otherwise indicated, defined terms used herein shall have the same meaning as provided in the Terms and Conditions and Relationship Disclosure Information (the "RDI") received with your Engagement Letter. This Online Privacy Statement shall supplement the terms of the RDI and applies to the collection, use and disclosure of personal information through Wealth Online. Your execution of the Engagement Letter, which includes its attachments and schedules by reference, and use of Wealth Online constitutes your consent to the collection, use and disclosure of your personal information as outlined in this Online Privacy Statement. Where you provide BNY Mellon with personal information relating to another, you represent to BNY Mellon that you have consent or are otherwise authorized to disclose to BNY Mellon such personal information for the purposes outlined above.

MODIFICATIONS

We may modify this Online Privacy Statement at any time without notice to you, so please check from time to time for such modifications. This Online Privacy Statement can be found on the home page of the Wealth Online site for your reference. The date on which this Online Privacy Statement was last modified appears at the top for your reference. Any changes to this Online Privacy Statement will be effective as of the date they are posted. Your continued use of Wealth Online following any such modifications will mean that you accept and agree to the modifications. If you have specific questions regarding this Online Privacy Statement or any information you have sent via Wealth Online, please do not hesitate to contact our Chief Compliance Officer (contact details below).

HOW WE COLLECT AND USE YOUR INFORMATION

BNY Mellon Wealth Management, Advisory Services, Inc. and its affiliates (collectively "BNY Mellon") will collect personal information from you such as name, address, social insurance number, assets, and income. This personal information, in addition to information collected during your relationship with BNY Mellon, will be used by BNY Mellon to establish and administer our relationship and the Account, communicate with you, provide advice and professional services as set out in your Engagement Letter, and comply with laws and reporting requirements. BNY Mellon shall not otherwise use such personal information for any purpose or, except as set out below, disclose such personal information, to a BNY Mellon affiliate or arms-length third party, except as authorized by you, required by law, or required due to our professional obligations.

We use cookies, web beacons and similar technologies (collectively called "Cookies" in this Online Privacy Statement) to track information provided to us by your browser and by our software application when you use Wealth Online, including IP address, the operating system installed on your device, the browser types used on your device and your activity on the Site. Cookies are small pieces of information that a website stores on the web browser on your device and can later retrieve. "Session" Cookies are temporary and will expire at the end of a browser session; that is, when you leave a website. Session Cookies allow a website to recognize you and carry information as you navigate between pages during a single browser session so as to allow you to use the website efficiently. "Persistent” Cookies, in contrast, remain in the Cookie file of your browser even after you leave a website and after the browser is closed. They enable a website to recognize you upon your return, remember your preferences and provide tailored services to you. Cookies will not contain information that will enable us to contact you via telephone, e-mail, or other means. We use Session and Persistent Cookies on Wealth Online. If you do not wish to accept these Cookies, either disable them or refrain from using Wealth Online. Please note that if you disable the Cookies, you may experience reduced functionality or be unable to use some or all parts of Wealth Online.

HOW WE SECURE PERSONAL INFORMATION

BNY Mellon maintains physical, electronic and procedural safeguards that comply with applicable industry standards and are designed to protect your personal information. Internal data security policies restrict access within BNY Mellon to personal information to those who require the information to provide you with services. Employees who violate our data security policies are subject to disciplinary action, up to and including termination.

Although BNY Mellon maintains a rigorous security program, as described in the RDI and which we routinely test and tweak as industry practices evolve, and works hard to prevent, promptly detect and mitigate attacks on our systems and information holdings, no safeguards are 100% effective in protecting electronic record keeping systems and information. There are inherent risks associated in holding personal information in electronic form. Those risks include the unauthorized interception, loss, manipulation and loss of integrity of information as well as the possibility of the transmission of viruses or other malicious code. Therefore, we cannot guarantee that personal information in our networks will never be compromised through malicious activities, including unauthorized access, use and disclosure of the information. You have a role to play in protecting your personal information. The security of that information depends in part on the security of the devices you use to communicate with us, the degree to which you protect your user IDs and passwords, and the security provided by your Internet service provider.

The risk factors outlined above could have consequences that include: a temporary loss of access to account information; unauthorized access to, use of and disclosure of personal information including for fraudulent purposes; and the manipulation of personal information. Should any of these consequences occur, you may be advised to monitor your accounts and credit rating, replace some of your IDs, and give notice to your bank and other financial services providers. You may also want to submit a complaint to the applicable privacy regulator and/or authorities.

HOW WE SHARE PERSONAL INFORMATION WITH

As set out in the Terms and Conditions attached to your Engagement Letter, BNY Mellon discloses your personal information to related and third party entities involved in providing our services to you including, counterparties that effect transactions on your behalf, custodians and sub-custodians, sub-advisors and their counter-parties, dealers, brokers, and proxy voting services. We do not control the privacy practices of these entities, some of which you will have authorized to collect your personal information from BNY Mellon, and others of which BNY Mellon will have contracts with which include provisions on the use and protection of personal information we provide.

BNY Mellon may transfer necessary information to its service providers in order to service your relationship and Account. BNY Mellon requires its service providers to provide a level of protection for personal information they receive from BNY Mellon that is comparable to the level of protection that BNY Mellon provides.

Some of the related and third party entities and service providers described above operate outside of Canada. As set out in the RDI, personal information that is processed or stored outside of Canada is subject to the laws of the jurisdiction in which it is processed or stored, including any privacy and data protection laws. Not all of these laws offer similar protection to personal information or provide all of the privacy rights to the individuals to whom it relates as do privacy laws in Canada.

Personal information processed or stored outside of Canada may be the subject of a legally valid order for disclosure, to the government, courts, and/or law enforcement in the jurisdictions in which the information is processed or stored. Moreover, exercising your rights in regard to your personal information may be more difficult where the information is outside of Canada for reasons that include that Canadian privacy regulators may not have the authority to enforce those rights as against entities outside of Canada.

As mentioned in the RDI, we are obliged to provide personal information to government agencies and regulators which may use the information to carry out their mandate including investigations, reporting and proceedings.

BNY Mellon may provide the personal information of one Owner of a Joint Account to other Owners of that Joint Account. Please read the sections on Joint Accounts in the Terms and Conditions for additional information. BNY Mellon may disclose personal information in connection with a reorganization of its business, financing or other transaction involving all or part of its business or assets, including for the purpose of permitting the due diligence required to determine whether such a reorganization, financing or transaction should proceed, and for insurance purposes.

HOW WE OFFER GOODS AND SERVICES

BNY Mellon sends or has service providers send on our behalf, marketing or promotional emails and other commercial electronic messages to our clients from time to time. The kinds of commercial electronic messages we may send you include: emails containing information about our company, fund reports, market/ investment commentary, invitations to events, and articles or newsletters we consider may be of interest to you. You may decline to receive these messages at any time by clicking the Unsubscribe link in the message or following the instructions in the message on how to unsubscribe. You may also contact us at marie-claude.lepage@bnymellon.com if you wish to unsubscribe from any or all of these messages. Although you may unsubscribe, BNY Mellon will still be permitted to send you certain types of commercial electronic messages that do not require consent under Canada’s anti-spam law. For example, we may send you emails containing account statements or trade confirmations, which we are required by law to provide.

THIRD PARTY SITES

This Site may contain links to third party sites (including social media bookmarking buttons that enable you to share certain content on our Site). Please review the Cookies and privacy statements of these third party sites to understand how they may use Cookies and your personal information. For clarity, this Online Privacy Statement does not apply to any third party site including the purposes for which the operator may use and disclose personal information.

YOUR RIGHTS AND HOW TO ASSERT THEM

Except in limited circumstances set out in the law, you are entitled to have access to your personal information in BNY Mellon’s records and to request that we correct any errors or omissions in that information. Requests for access to and/or correction of your personal information must be made in writing and submitted to us as indicated below. Additionally, where we have relied on your consent to process particular information and you have provided us with your consent to process the information, you have the right to withdraw such consent at any time.

You may obtain more information about BNY Mellon’s personal information management practices, obtain access to or request the correction of your personal information, or request that BNY Mellon review its management of your personal information by contacting BNY Mellon as follows:

Marie-Claude Lepage

Chief Compliance Officer

BNY Mellon Wealth Management, Advisory Services, Inc.

200 Wellington Street West, 3rd floor

Toronto, Ontario M5V 3C7

Office: 416-840-8008

Fax: 416-840-8002