Our Privacy Policy informs you of the policies and practices we have in place relating to the management of personal information at Full Circle Group Benefit Consultants. This policy applies to business owners, and personal customers, including individuals carrying on business alone or in partnership with other individuals. It consists of five key principles:

1. Collecting and using information

Either before or when we collect information about you, we will explain how we intend to use it. We will limit the information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your information for any other purpose and before collecting information from third parties such as credit bureaus.

Your personal financial information is used to help us manage operations and risk within Full Circle Group Benefit Consultants. Your information is also used in order to satisfy valid information requests from regulators and other organizations or individuals who are legally entitled to make such requests.

2. Releasing information

We may provide your information to other persons -

• where we have your consent

• where the other parties are our suppliers or agents who assist us in serving you

• where we are required or permitted to do so by law or applicable regulators and self-regulatory organizations

• where transfers of a business are involved

3. Protecting information

We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time it is required for the purposes we explain.

4. Providing information access and accuracy

We will give you access to the information we retain about you. We will make every reasonable effort to keep your information accurate and up-to-date.

5. Respecting and responding to your privacy concerns

In the Full Circle Privacy Code, we will explain your options for refusing or withdrawing consent to the collection, use and release of your information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your information.

In the Full Circle Privacy Code, we will explain how we fulfill each of these important principles.

Why we ask for your information

We ask you for information to establish and serve you as our customer. We obtain most of our information about you directly from you. The information we ask for depends on which product or service you want. For every product or service, we need your name, address, birthdate, occupation and some identification. Here is why we need some of the other information we ask you to provide.

• Birthdate

This helps us identify you and ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products and services that may be of benefit to a particular age group.

• Social Insurance Number (SIN)

Your SIN is required to keep your information separate from that of other customers with a similar name, including information we obtain with your consent through the credit approval process.

• Financial information

This is used to ensure that the advice we give you is appropriate for you.

• Health information

This is required for some products to ensure you are eligible for coverage, and may also be used to investigate and adjudicate your claims, and to help manage and assess our risks.

We only collect the information we need and only use it for the purposes explained to you.

How we obtain your consent

It is important to understand the different ways that we may obtain your consent to collect, use, disclose and share your personal information. Depending on the situation and the sensitivity of the information, we may obtain your consent in different ways. Express consent may be obtained verbally, online or in writing. Implied consent may be obtained through your use of a product, or when you approach us to obtain products or services from us. We will not make your consent a condition of obtaining a product or service, unless it is reasonably or legally required, and we will clearly indicate when this is the case.

Why we share your information

We share information within Full Circle Group Benefit Consultants to manage our business risks and operations, and to comply with legal or regulatory requirements. With your consent, we may share your information within Full Circle Group Benefit Consultants. This will help us serve you better and determine whether any products or services of Full Circle Group Benefit Consultants are suitable for you so that we can offer them to you. We want to serve you better and meet your customer service expectations. Agreeing to let us share your information within Full Circle Group Benefit Consultants helps us to meet this goal.

Sharing information lets us instantly recognize your total relationship with Full Circle Group Benefit Consultants, no matter when or where you contact us or which one of us you contact. It also means that in some circumstances, changes to your information can be made once and be effective for all your products or services with Full Circle Group Benefit Consultants.

Sharing your information also helps us determine your financial needs because it allows us to review what Full Circle Group Benefit Consultants products you have and how you use them. We may then offer you other Full Circle Group Benefit Consultants products and services – including special promotions – that we believe will be of interest to you.

This consent is optional and you can decide to withdraw it at any time for the purposes listed above. Please refer to the “Respecting your preference” section.

Why we ask others for information about you

With your consent, we may obtain information about you from third parties.

Obtaining additional information about you from parties outside Full Circle Group Benefit Consultants helps us assess your eligibility for our products.