NGAM Canada Commitment to Privacy.  NGAM Canada is committed to providing its investors with innovative investment products and superior client service. As part of that commitment, we employ a variety of safeguards designed to protect, in accordance with applicable federal and provincial legislation, your personal information received by us.  We do not barter, sell or otherwise market your personal information to any person or entity.  In this Policy, “personal information” means information in any format about an identifiable individual that is in our possession or otherwise under our control.

What personal information do we collect?  As an investor of the Natixis/NexGen Funds or other NGAM Canada investment products or services, we collect certain personal information about you to provide you with our products and services, serve you better and as required by law. The nature of the personal information will change depending upon the particular product or service, but may include your name and address, contact information, account holdings and transactions, social insurance number, date of birth, banking information, beneficiary, financial advisor and spousal information.  Where you provide us with the personal information of another person (for example your spouse), we will understand you to have the consent of that person or be otherwise authorized to do so.  NGAM Canada may collect the information directly or indirectly from your professional advisors, such as financial advisors, attorneys, accountants and executors and through means including (i) account applications and other account documentation; (ii) forms, questionnaires; (iii) and our internet website.  We will keep a record of any third party from whom or which we collect personal information.

For what purposes do we use the information? We use your personal information to open and administer your account, to communicate with you, to make the investments you direct us to make and to comply with all legal and regulatory requirements including reporting requirements to securities and taxation authorities.  We may also use your personal information for internal business purposes (compiling statistics on products or lines of business) and unless you indicate otherwise, to provide you with information about products, services and events that we believe will interest you.  Please advise our Privacy Officer in writing if you prefer not to receive such materials or have us otherwise use your personal information.

What information is disclosed to third parties and for what purpose? We only disclose personal information to third parties for business purposes in connection with the management and servicing of your account. Those parties may include your professional advisors, including your financial advisor, executor, attorney or accountant, a custodian and/or a government agency.

We use third party service providers and will permit them access to your personal information where it is required in connection with the provision of services to NGAM Canada.  More particularly, NGAM Canada uses third party account statement preparation and mailing companies, courier and image and document storage companies and information technology services companies.  We use service providers that operate in the United States and in India and as such, any personal information that we permit them to use will be subject to the laws of those countries as well as Canadian law and may be disclosed in compliance with those laws, including to the governments of those countries or their agencies.  All of NGAM Canada's third party service providers are bound contractually to maintain the confidentiality of your personal information and not to use your personal information for purposes that are not related to the service or product that they have been contracted to provide.

To ensure that the servicing and management of your account is not interrupted, we may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets and for the purpose of permitting a third party to a proposed transaction to conduct the due diligence required to decide whether to proceed. In this case, we make efforts to ensure that the personal information disclosed continues to be used only for the purposes permitted by this Privacy Policy, unless your consent is obtained to a new use.  We also disclose personal information where necessary for our business processes, including to obtain insurance coverage and to file a claim with our insurers.

How do we safeguard your personal information?  Access to your record or file is only granted to those employees and agents authorized to have access because they have a specific need to know the information, to provide products and services to you or for the other purposes described in this Privacy Policy.  In addition to this organizational safeguard, NGAM Canada maintains physical, procedural and electronic safeguards to protect personal (and other confidential) information from access by unauthorized persons or for unauthorized purposes.

How can you get access/request correction of your personal information? You may access your personal information in our possession or control at any time upon a written request to our Privacy Officer as provided below.  In certain limited circumstances imposed by law,  we may be unable to provide such access.  If you believe that any of your personal information is incorrect, please write to our Privacy Officer setting out the correction that you are asking us to make.

Can you withdraw your consent? You may withdraw your consent to us using your personal information at any time by contacting us, in writing, at the address noted below or e-mailing us at info.canada@ngam.natixis.com, subject to legal or contractual restrictions and reasonable notice. Withdrawal of your consent, however, may affect our continued ability to administer your investment account. Please contact us for more information respecting the consequences of a withdrawal of your consent.

Who do you contact if you have any concerns? If you have any questions or comments about NGAM Canada’s privacy policies, please contact us at NGAM Canada LP, 145 King Street West, Suite 1500, Toronto, Ontario M5H 1J8 or at info.canada@ngam.natixis.com.

We reserve the right to amend or supplement our Privacy Policy at any time and for purposes that include changes in the law or other requirements to which we are subject and/or our operations.

Last Updated: October 2015