Fidelity Canada privacy policy

We collect information to better serve you. The type of information depends on the service we provide.

If you are an investor or Fidelity Private Wealth client, we collect your name, contact information, Social Insurance Number, banking information and other information necessary to provide you with portfolio management services, to keep records, to prevent error and fraud, to provide you reports and tax reporting, to make payments to you by way of electronic funds transfer or to respond to inquiries from your advisor, if your advisor referred you to us.

If you are a member of the general public, you may subscribe to receive educational and marketing materials from Fidelity. Fidelity will collect and use your name, contact information and consent for these purposes.

We do not sell any personal information. Portions of your personal information may be provided, in confidence, to third-party service providers for services that include the preparation and mailing of client account statements or other documents on our behalf and for other services such as information technology, data processing, payment processing, and the advertising/ marketing services as described in this policy. At times, we may use affiliated Fidelity companies, located outside of Canada, including the European Union, the United Kingdom, and the United States, to perform data storage and processing services for us, and may use third-party service providers located outside of Canada. This may involve the transfer of your personal information to these entities. In such cases, the information is subject to the laws of Canada and the laws of the service provider’s place of business. In all cases, we require that our service providers protect your information and only use it for the limited purpose of providing their services to us. However, your information may potentially be accessible to law enforcement and national security authorities of the foreign jurisdiction.

We may also share your information with other Fidelity companies, other financial institutions and government organizations and, if you are an investor who was referred to us, your advisor. Where information is shared outside Fidelity, it is on a strictly limited basis in order to complete transactions on your behalf, to provide you with services or to meet legal obligations, such as tax reporting. We might be required to disclose personal information in response to a search warrant, court order or other demand or valid inquiry. This may include requests from regulators, including, but not limited to, the Mutual Fund Dealers Association of Canada or the Investment Industry Regulatory Organization of Canada, or the provincial securities commissions. A regulator may, in turn, disclose your personal information to other regulatory or government organizations. Fidelity may also share your personal information with certain government entities if there is reasonable cause to believe your personal information has been compromised and reporting to such an entity may reduce or mitigate the risk of significant harm to you.

When you use our website, read our emails, or engage with us through an electronic device, we and our third parties will automatically collect information about how you access content and about your device.

We use this information to analyze the use of our service, improve our service offerings, and provide you with information and offers.

This information is normally collected by us and our third-party partners via tracking technologies, including cookies, tracking pixels, Flash objects, web beacons, and embedded scripts. We may also collect information regarding your IP address, location, network connection (e.g. Wi-Fi, Bluetooth, near field communication), Internet search provider, device identifier and advertising identifiers.

We may combine such information with other personal information that we have obtained directly from you, and may also use this information to create anonymized data and to compile aggregate data for internal and external business purposes.

We have included additional information about tracking technologies below (see Targeting and Advertising section below), and have provided you with “opt-out” options.

Fidelity’s website may use YouTube's API services in connection with embedding video thumbnail images and descriptions provided by YouTube LLC (“YouTube”). As such, you acknowledge and agree that by accessing the videos linked through the embedded video thumbnail images and descriptions, you are also bound by YouTube’s Terms of Service and Google’s Privacy Policy. Using YouTube’s offering requires a connection to be established to YouTube’s servers. During this process, certain information is transmitted to YouTube. We do not control the collection, storage or use of any of your information by YouTube and do not have access to any information collected. You should review Google’s and YouTube’s Privacy Policies carefully before you use any YouTube features. Further information about how your data are collected and used by YouTube and your rights in relation to this can be found in YouTube's privacy policy at www.youtube.com.

Personal information is collected from our interactions with you. We might interact with you directly, such as when you call or write to us or visit privatewealth.fidelity.ca. We may record your telephone or online discussions with our representatives, and we may monitor live or recorded calls or online discussions for our mutual protection, to enhance customer service, for training purposes and to confirm our discussions with you. No matter how we collect your personal information, we try to ensure its accuracy and completeness to the extent required for our use of the information. In order to maintain the accuracy of your information, please make sure we know about any changes as soon as possible.

We may also receive information about you from the digital advertising companies with whom we work (see Targeting and Advertising section below), to help use to deliver ads to you and recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that digital advertising companies share with us. We may work with our digital advertising company partners to match their identifiers to our own, to enhance data points about a unique browser or device.

We have always considered the protection of sensitive information to be a foundation of customer trust and a sound business practice. We employ extensive physical, electronic and procedural controls, and we regularly review these controls to determine whether they need to be adapted to respond to changing requirements and advances in technology. Within Fidelity and among our service providers, we aim to restrict access to personal information to those who need it to provide products and services to you.

The transmission or storage of information via electronic means can be compromised or exposed to unauthorized parties. While Fidelity has taken steps to protect your information, we encourage you to take precautions to ensure your information is kept secure and only transferred to us via secure means.

We believe that privacy, security and service in our online operations are just as critical as in the rest of our business. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.

We use a variety of protections designed to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures.

When you visit our Internet sites, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited and average time spent on our websites. This information may be used, for example, to alert you to software compatibility issues, improve our web design and functionality or to provide you with customized services and product/ service offerings.

Cookies

Cookies are small amounts of data that a website sends to a web browser on a visitor’s computer. We use cookies and similar technologies to support the operation of Fidelity websites, as well as to promote products and services that may be of interest to you.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Fidelity website, or if you delete cookies, you may experience some inconvenience in your use of Fidelity websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device or your online preferences.

Website cookies

Our cookies help us to collect information about visitors to Fidelity websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Fidelity cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

These cookies are collected via Google Analytics, which is a web analytics service provided by Google Inc. that provides statistics about visitors to our website. You can opt out of these cookies by clicking here.

Email cookies

Fidelity also uses cookies and similar technologies in the emails that we send. We will gather information such as your IP address and geographical location, as well as whether you open the email, which links you click on within the email and any Fidelity webpages you subsequently visit. We will have the ability to link any activity on Fidelity webpages and emails we send to your email address. This is done by matching your IP address, as opposed to storing any personal information about you. Please note this does not track any activity on non-Fidelity pages. You can remove these cookies from your device at any time by clearing your cookies and cache.

Targeting or Advertising Through Interest Based Advertising

We participate in various forms of targeted advertising (interest-based advertising) and use third-party analytics and advertising companies to provide you with targeted advertising and offers. Specifically, we permit third-party online advertising networks and services, social media companies and other third-party services, to collect information about your use of our website and mobile App over time so that they may display advertisements on our website or mobile App, or on other websites, applications of services that you may use, and other devices that you may use.

Typically, targeting or advertising cookies will be used to deliver advertisements relevant to you. They are also used to limit the number of times you see an advertisement, as well as to help measure the effectiveness of the advertising campaign. Such cookies or tracking technologies may recognize the device you are using and collect click stream information, browser type, time and date or your visit to our website or elsewhere online, and similar information. Targeting cookies are used to

• understand what Fidelity advertisements you might be interested in on our site
• understand what Fidelity advertisements you might be interested in on other sites

As part of this, we use several third-party services to help us understand what advertisements you might be interested in. These cookies hold information about your computer, and they might hold a record of what other websites you've looked at, so that we can show you promotions while visiting other websites.

We may also use advertising cookies to link to social media networks such as Facebook, LinkedIn, Instagram, Twitter and other widgets. They will use any information about your visit to the Fidelity website to recognize you, set a cookie or employ other tracking technologies, then deliver targeted advertising to you. The information collected is anonymous but may include details such as your IP address. By using our website, you agree to these cookies being placed on your device. You can opt-out of these cookies at any time by checking your settings with the relevant social media platform or within your browser. Your interactions with these features are governed by the privacy policies of those companies. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences; for example:

• Facebook advertising preferences
• LinkedIn advertising preferences
• Instagram advertising preferences
• Twitter advertising preferences

We may also share certain anonymized information with our third-party advertising partners (such as a hashed email address or other anonymized and encrypted “remarketing” lists) to help identify you across sites and across devices and to show you relevant ads, generate similar audiences and to show dynamic ads. As noted above, for social media companies, you can adjust your advertising preferences using the links above. The social media companies that interact with our site, and all of the other third-party advertising services that we use, are detailed in the chart that is available at the end of this policy. We endeavour to keep this chart up to date but may remove or add service providers from time to time. Please contact us if you have any questions about our current services.

We, and our third-party service providers, use cross-device linkage so that the content that you view on one device can result in you receiving relevant advertising on another device, and also to allow us to perform analytics and assess the effectiveness of our advertising. We do this by collecting information about each device you use when you use our website and mobile applications. We may also work with third-party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices.

Fidelity has engaged the following service providers, who may use advertising or targeting cookies; you can opt-out of vendor-specific cookies by clicking on the relevant links below:

You may request access to your personal information and question its accuracy and completeness. We will respond to your request within 30 days of receiving it.

You may withdraw your consent for us to use your personal information for secondary marketing purposes, either by using the unsubscribe option that we provide in electronic communications, or by contacting us at any time to request that we do not use your personal information for this purpose.

You may also withdraw all or part of your consent for us to use your personal information, subject to certain legal restrictions. If you withdraw consent, however, we may be limited in the services or products that we provide to you. Please contact us to learn more.

Protect your data: Be aware of look-alike websites and other scams. If you suspect that a website or email claiming to be from Fidelity is fraudulent, please report it to cyber.defence.canada@fidelity.ca.

We welcome your privacy questions.

Investors or advisors:

Email: Privatewealth@fidelity.ca

If you are not satisfied with the results of your email or phone call, contact

Chief Privacy Officer

Email: privacy@fidelity.ca
Telephone: 1 800 263-4077
Fax: (416) 307-5349

or by mail at:

Attention Chief Privacy Officer
Fidelity Investments
483 Bay Street, Suite 300
Toronto (Ontario)
M5G 2N7