Privacy Policy

The Tower Group's Privacy Policy has been developed as an extension of our commitment to combine the high standards for service with the highest level of integrity in dealing with our clients. The Policy guides how we collect store and use information about clients and prospects, and it will be periodically assessed against new technologies, business practices and our customers' changing needs.

We are committed to providing quality financial products and services in a manner that fosters trust and confidence among our clients. We adhere to the following principles when dealing with personal information:

• Maximize fairness in our use of personal information
• Minimize intrusiveness
• Protect privacy and confidentiality
• Maintain accurate records
• Provide accessibility to our privacy policies and customer information when appropriate
• Comply with the applicable laws and regulations in the jurisdictions in which we do business

Our Policy recognizes two kinds of personal data that deserve varying levels of protection. Personally-Identifiable Information includes, for example, e-mail addresses, billing information, and employment status. A subset of that category, Sensitive Data, deserves additional safeguards. Sensitive Data includes, by way of example, Social Insurance Numbers, personal financial data (such as specific salary, net worth or individual portfolio information) and information about specific medical conditions.

Our Privacy Policy is more than just a legal obligation. When you become a Tower Group client, you share important personal information with us. You do this so we can serve you better and knowing we would honour and respect your privacy.

What is "personal information"? "Personal information" is information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. Personally-Identifiable Information will only be collected to the extent that The Tower Group deems reasonably necessary to serve a legitimate business purpose.

Collecting, using and disclosing your personal information. We collect, use and disclose personal information for one reason: to serve you better. Knowing you better helps us understand your financial needs, communicate effectively with you, and provide you with the services and products you want. We collect, use and disclose your personal information to:

• Verify your identity
• Determine your eligibility for financial products and services
• Assess and underwrite insurance and reinsurance risks
• Determine prices, fees and premiums
• Determine the suitability of your investments
• Comply with the law
• Comply with tax requirements

Personal information may be collected, used or disclosed for any of these "Identified Purposes" set out above. If your personal information is not needed for one of the Identified Purposes, we will not use or disclose it without obtaining additional consent from you. Customers and prospects will be notified (usually at the point where Personally-Identifiable Information is collected) as to the uses the business unit may make of the Personally-Identifiable Information collected from them. In very limited and exceptional circumstances, Canadian federal privacy law permits the use or disclosure of personal information without an individual's consent. For example, consent is not required if personal information is used or disclosed in an emergency that threatens an individual's life, health, or security.

How do we gather your personal information?

• From you, on applications for insurance and investment products or on other forms filled out through telephone, e-mail, face-to-face interviews; for example your name, address, telephone number, e-mail address, occupation, financial and banking information, and health information
• From your interactions with us; for example through your payment history and underwriting
• From government and other entities, that have information on your driving records
• From government and other entities, that have information on your driving records
• From consumer reporting agencies; for example your credit history

Your Consent
Your knowledge and consent are required before we may collect, use or disclose your personal information. If any of the personal information that we collect is sensitive, such as health information, we will obtain additional written or oral consent from you before collecting, using or disclosing the information.

How do you provide us with your consent?
We accept any of the following as your consent for The Tower Group's existing use and future collection, use and disclosure of your personal information for the Identified Purposes:

• Your receipt of this Personal Information Policy
• Your unrestricted provision of information to The Tower Group
• Your express written or oral consent as obtained through an application process
• Your consent as provided by your authorized representative, such as a legal guardian or power of attorney

How you can withdraw your consent.
You may withdraw your consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note, however, that withdrawing your consent may affect our ability to continue to provide you with the advice, products and services that you have or would like to receive.

To withdraw your consent, you should contact our Privacy Officer, Kelly Taylor, (403) 265-3771. Suite 300 1167 Kensington Crescent NW, Calgary Alberta T2N 1X7. Unless we hear otherwise from you, you are giving to us your consent for the collection, use and disclosure of personal information as provided in this Policy for the Identified Purposes.

How long do we keep your personal information?
Your personal information is retained only as long as we need it to effectively provide products and services to you, and for a reasonable length of time thereafter in case we need to meet any potential obligations or legal or government requirements. The Tower Group shall use care when storing or destroying your personal information in order to prevent unauthorized access.

How do we protect your personal information?
Whether in electronic or paper-based format, The Tower Group maintains strict security systems to safeguard your personal information from unauthorized access, disclosure or misuse. As well, when we no longer need your personal information, we take as much care to destroy it confidentially, through a shredding service, as we do when storing it.

In the event that we transfer your personal information to a third party for processing (for example, need some examples like off-site server, ISP provider, book-keeper. Lawyer and or Accountant), we contractually require any person or organization providing products or services on our behalf to protect our customers' confidentiality in a manner consistent with our own internal measures, or as required by law.

Your right to access your personal information.
You have a right to access your personal information that we have in our possession or control. Procedures have been developed through which customers and prospects can, upon request, review and correct the Personally-Identifiable Information that has been collected from them by The Tower Group. These procedures may not, however, compromise the security, integrity and privacy of either The Tower Groups' own proprietary databases or databases licensed from third party companies.

How do you access your personal information?
Please make your request in writing to Kelly Taylor, The Tower Group's Privacy Officer, stating as specifically as possible which personal information you are requesting.

We will endeavour to respond to such requests as soon as possible, and will advise you if for some reason we cannot respond right away. The Tower Group may charge you a reasonable fee for providing access to your personal information, but only after first advising you of the approximate cost.

Keeping your information accurate.
The Tower Group strives to ensure that the personal information we have on file about you is as accurate and up-to-date as necessary for the Identified Purposes for which it is to be used. If any information needs to be updated or amended to reflect a change in your situation, we make every effort to update our records. We shall amend personal information that is materially inaccurate or incomplete and, where appropriate, shall endeavor to advise other parties having access to the information in question.

If you have a complaint related to this privacy policy statement please contact us at the below address. If your complaint is justified, we will take the necessary steps to amend our policies and practices if necessary.

For more information, to file a complaint, to make enquiries, or to opt out of all or parts of this Policy, please contact:

Kelly Taylor
1220, 340 12th Avenue SW, Calgary AB T2R 1L5
Telephone: (403) 265-3771 Fax: (403) 265-3751
E-mail address: ktaylor@thetowergroup.ca
Internet: www.thetowergoup.ca