The Westman Group’s Commitment to Privacy

Protecting the privacy and the confidentiality of our customers’ personal information has always been fundamental to the way that we do business. The objective of our Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and other applicable privacy legislation.

This Privacy Code applies to all aspects of the Westman Group’s handling of personal information, including collection, use, retention and disclosure.

Purposes for the Collection, Use, Retention and Disclosure of Personal Information

The following are identified purposes for which we collect, use, retain and disclose your personal information:

• To establish and serve you better, which may include the extension of credit facilities to you (and the related credit application process).
• To provide you with information about products and services that we believe would interest you.
• To manage proposed or actual sales or leases of all or part of our business or assets.
• To meet legal and regulatory requirements or as required or permitted by law.
• To achieve any other purpose to which you have given your consent.

Control Over Collection and Use of Personal Information

We generally collect, use, retain and disclose personal information only with your consent. In obtaining consent, whether express or implied, we will explain the purposes for which we will manage personal information. We will not depart from these original identified purposes unless further consent is given.

We will explain the options of refusing or withdrawing consent to the collection, use, retention or disclosure of personal information, and we will record and respect your choices.

• We will protect personal information with reasonable safeguards and security measures commensurate with its sensitivity.
• We will give you access to the personal information we retain about you except where exempted by law.
• We retain personal information only as long as it is reasonably required, or as is required by law.
• We will make every reasonable effort to keep personal information accurate, complete and up-to-date.
• We will only disclose personal information to the extent that is necessary to accomplish a business purpose or discharge a regulatory, legal or public duty.
• To view a complete copy of the Code, or for answers to questions about privacy practices or about the way a request for personal information was handled, contact the Westman Group’s Privacy Officer at: privacy@westmangroup.com