PRIVACY POLICY

EFFECTIVE DATE: JANUARY 2021

QV Investors Inc. (“QV”, “us”, “we” or “our”) is committed to protecting the privacy and confidentiality of your personal information in our possession and control. We operate www.qvinvestors.com, including all subpages and successor pages (collectively referred to as “Services”). This Privacy Policy outlines our commitment and outlines the policies regarding our collection, use and disclosure of personal data when you use our Services and the choices you have associated with that data.

Please note this Privacy Policy may be updated periodically to reflect changes to our personal information practices. We strongly encourage you to refer to it often for the latest information available on our policies.

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.qvinvestors.com

INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve our Services to you.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). We limit the use of personal information and collect only what is necessary for the purposes as listed below in the Data Usage section. Personally identifiable information may include, but is not limited to:

• Name, address, phone number, email address
• Information related to the set up and maintenance of your investment account(s) where applicable which includes investment objectives, risk tolerance, financial circumstances, employment information, government issued identification, etc.
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send. Additionally your personal data will be used to satisfy the legal and regulatory requirements when an account is opened for you.

Usage Data

We may also collect information on how the Services are accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Services, to improve and customise our Services.

You can enable or disable location services when you use our Services at any time by way of your device settings.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

• • Session Cookies. We use Session Cookies to operate our Services.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

USE OF DATA

QV Investors uses the collected data for various purposes:

• To provide and maintain our Services
• To provide you with investment management services established in your agreement
• To fulfill our legal obligations
• To detect fraud
• To notify you about changes to our Services
• To allow you to participate in interactive features of our Services when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Services
• To monitor the usage of our Services
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

DEFINITIONS

• Services
  Services are the www.qvinvestors.com website and client portal operated by QV Investors.
• Personal Data
  Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage Data
  Usage Data is data collected automatically either generated by the use of the Services or from the Services infrastructure itself (for example, the duration of a page visit).
• Cookies
  Cookies are small files stored on your device (computer or mobile device).
• Data Controller
  Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
  For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers)
  Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
  We may use the services of various Service Providers in order to process your data more effectively.
• Data Subject (or User)
  Data Subject is any living individual who is using our Services and is the subject of Personal Data.

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), QV Investor’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

QV Investors may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law

RETENTION OF DATA

QV Investors will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

QV Investors will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your province, state, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

QV Investors will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

Business Transaction

If QV Investors is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, QV Investors may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

QV Investors may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of QV Investors
• To prevent or investigate possible wrongdoing in connection with the Services
• To protect the personal safety of users of the Services or the public
• To protect against legal liability

SECURITY OF DATA

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

OUR POLICY ON “DO NOT TRACK” SIGNALS UNDER THE CALIFORNIA ONLINE PROTECTION ACT (CALOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. QV Investors aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where QV Investors relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Service-related services or assist us in analysing how our Services are used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Services.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.

LINKS TO OTHER SITES

Our Services may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CHILDREN’S PRIVACY

Our Services do not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please Contact Us.