Privacy

Pacific & Western Bank of Canada (the "Bank") knows the importance of keeping your personal information confidential. We have developed a Privacy Policy that describes how the Bank will endeavour to protect the privacy of your personal information. Our Privacy Policy is intended to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA") and applicable provincial privacy laws.

This Policy does not apply to personal information related to a potential, current or former employment or contractor relationship with the Bank.

Personal information is information that identifies you as an individual. It includes not only such things as your age and gender, but also your personal financial records and identification numbers, such as your social insurance number. Subject to applicable laws, personal information does not include the name, title or business address or telephone number of an employee of an organization when used to contact them in their capacity as an employee of such organization, nor publicly available information, as defined in PIPEDA. While the Privacy Policy does not apply to information about corporations, partnerships or other forms of legal association, the Bank protects the confidentiality of such information in accordance with the Bank's other policies and applicable law. The Privacy Policy does apply to information about business customers carrying on business as sole proprietors to the extent that such information identifies an individual human being.

a)to open, establish, maintain and administer your accounts;
b)to confirm and conclude contractual arrangements;
c)to tailor our services and advice to your particular financial situation, goals and needs;
d)to coordinate benefits and administer programs with our program partners when you apply
for or use a product whose benefits are provided by third parties and are an automatic
benefit of such products. For example, when you use a private label credit card at Home
Hardware Stores Limited (HHSL), your personal information will be disclosed to HHSL as
necessary to administer this program;
e)to process orders for services, credit or products including through third party payment
systems or networks;
f)to respond to inquiries from you and to comply with your requests;
g)to assess your creditworthiness and ongoing eligibility for various financial products and
services, such as credit, by regularly obtaining information from and exchanging
information with credit reporting bureaus;
h)to file documents on your behalf with governmental authorities;
i)to comply with the requirements of applicable laws, regulators and governmental
authorities;
j)to register investments with tax authorities;
k)to process and settle payments;
l)to advertise, offer and provide additional products, services and solicitations of the Bank
and any of its affiliates or other parties that the Bank believes may be of interest to you.
Subject to obtaining appropriate consent, marketing offers may be made through various
channels, including direct mail, telemarketing and electronically, using contact information
obtained in connection with your accounts, as updated from time to time.
If you prefer not to receive solicitations (including telemarketing) from the Bank, you may
call the PWB Privacy Officer using the contact information below or, with respect to email
or other electronic solicitations, by unsubscribing;
m)to conduct market research, including customer surveys, in order to evaluate the needs,
wants and satisfaction levels of our customers, to determine their eligibility to receive other
products and services to meet those needs and to analyze and manage our business;
n)to provide and administer services related to your account and monitor your purchases,
account and credit balances, fees paid and payable and payment history;
o)to verify your identity as an authorized user concerning any accounts, and to implement,
carry out and maintain security measures aimed at protecting our customers from error,
identity theft, fraud and unauthorized access to accounts;
p)to comply with legal or regulatory requirements (including those related to security);
q)to enable our affiliates, employees, suppliers, contractors and other third parties who need
this information in order to set up, manage or maintain a business relationship with us and
administer your accounts, for the ultimate purpose of us providing a service to you;
r)to report to our affiliates;
s)to protect our legal rights and property;
t)to collect a debt or enforce another obligation owed by you to the Bank;
u)to protect the safety of one or more individuals in an emergency or where otherwise
necessary;
v)to explore, negotiate or complete a business transaction, such as the grant of a security
interest in or the sale of some or all of the shares or assets of the Bank to a third party; and
w)any other reasonable purpose to which you consent.

Except as required for the foregoing, or where required or permitted to do so by applicable law or regulation, the Bank does not use or disclose personal information to third parties without your prior notice and/or consent.

We may collect and maintain personal information in the course of our activities, including, for example:

a)your name, address, telephone number, email address or other information to contact or
identify you;
b)copies of government issued identification as required by law in order to verify your
identity;
c)financial information about your income, financial position, use of credit, investment
portfolio, tax filings and taxable activities;
d)information about your use of your bank accounts;
e)information about your financial goals, risk tolerance and investment preferences;
f)information about the goods or services provided to or by you;
g)information about your financial transactions with us, including bills, credit history and
payment preference;
h)information about our agreements with you;
i)credit, personal and employment information about you from credit reporting bureaus;
j)information from communications with you, including your feedback and requests for
customer care; and
k)where required by law to do so (for example, in connection with reporting of investment
products), your social insurance number.

2. Payment Processing

We may use a third party to process payments for our goods and services.

3. Foreign Service Providers

We occasionally use service providers that are based outside Canada. Where we hold an account for you with such a service provider, we may authorize that your personal information may be collected, used, disclosed or stored by such service providers in the United States or elsewhere. Your personal information may be subject to the laws of these other countries, including that, in certain circumstances foreign courts, law enforcement agencies, regulatory agencies or security authorities may be entitled to access your personal information..

4. Consent

If you choose to voluntarily submit personal information to us, we will consider that you have consented to our collection, use and disclosure of this personal information for purposes reasonably related to your providing the information and for the purposes set out in this Policy.

Where your personal information is held by a third party, and we require this personal information in order to accomplish a purpose for which you have previously given your consent or in order to perform services that you have requested, we will consider that you have consented to our collection of such personal information for such purpose.

Where we use the services of third parties in our business they may provide us with your personal information. In such a situation, we will make reasonable efforts to have such parties assure us that this provision of your information is permitted.

Subject to the above, we will usually ask for your consent when we collect your personal information. Sometimes this may happen after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not disclosed in this Policy or elsewhere to you, we will make efforts to let you know about that purpose before use or disclosure.

You may modify or revoke your consent at any time, with reasonable notice, subject to applicable laws and contracts signed by you, by sending a written message to our Privacy Officer using the contact information set out below. In some circumstances, a modification or revocation of consent may limit or prevent us from providing or continuing to provide products or services to, or acquiring products or services from, you. For example, if you withdraw your consent to our collecting and disclosing information about your use of credit with credit bureaus, we may not be able to provide you with any products or services that require access to credit or impact upon your credit score.

We assume, unless you tell us otherwise, that by continuing to deal with us after having had this Policy made available to you that you consent to the collection, use and disclosure of your personal information as set out and for the purposes described in this Policy, where such consent is required by law.

5. Accuracy and Completeness

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate, up to date, and complete. This may involve requesting further information or updates from you. We do request that you advise us in writing of changes to your personal information so that our records may remain current.

6. Retention and Destruction

We store your personal information in the Province of Ontario and the States of Arizona, Montana, Nebraska and Pennsylvania. We may, for legal or business purposes, retain personal information for as long as is reasonable to meet the purposes for which it was collected or as otherwise permitted or required by law or regulation. Upon expiry of an appropriate retention period, bearing in mind legal and reasonable business requirements, personal information will either be destroyed in a secure manner or made anonymous. You should be aware that there may be legally required minimum retention periods or destruction requirements, which we must and do observe.

7. Security of Personal Information

We have made commercially reasonable arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information using physical, administrative and technical security measures.

8. Requests for Access to Personal Information

You may ask our Privacy Officer in writing at any time for:

a)access and/or corrections to your personal information, if any, under our custody or
control;

b)information about the purposes for which your personal information under our custody or
control has been and is being used by us; and

c)the names of persons or entities to whom, and the circumstances in which, your personal
information has been and is being disclosed by us.

Requests Must Be in Writing:

We do require that all such requests be in writing and email is not considered to be in writing in this situation. We reserve the right to require sufficient information and detail from the individual in question in order to properly identify you, confirm your right to access the information, locate the information and provide a response.

Fees:

We may charge fees for requests for personal information where it is reasonable to do so and permitted by applicable law.

Limits on Rights to Information:

Your ability to access your personal information in our custody or under our control is not absolute. Applicable law or regulation may permit or require us to withhold some of this information or the information may have been disposed of in accordance with our policy on retaining records.

9. Responses to Requests for Access to Personal Information

Our response to requests for access to personal information will in all cases be in writing, and will confirm whether we are providing all or part of the requested information, whether or not we are allowing access or providing copies, and, if access is being provided, when that will be given.

We reserve all our legal rights to not provide access to personal information. Where we may do so, we will endeavour to tell you why we are denying access to you.

10. Amendment of Policy

We reserve the right to amend this Policy from time to time as required and without notice by posting an updated Policy on our website and indicating that a change has been made. Any such amendments will be effective as of the date that the amended Policy is posted on our website.

11. Contacting or Communicating with Us

If you have any questions with respect to our policies concerning the handling of your personal information by the Bank and/or our foreign service providers, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:

2002 − 140 Fullarton Street
London, ON N6A 5P2
Toll free telephone: 866-979-1919

We will comply with applicable law in taking steps to answer your questions and keeping you informed of how we are responding to any issues that you have raised. If our response does not satisfy you, you may have a right to bring the matter before The Office of the Privacy Commissioner of Canada (OPC). You may contact the OPC by writing to them at Place de Ville, 112 Kent Street, 3rd floor, Ottawa, Ontario K1A 1H3, or by calling that office toll-free at 1-800-282-1376..

12. Interpretation

This Policy is to be interpreted so as to be consistent with applicable Canadian federal laws and is not intended to grant rights or impose obligations beyond those which exist in such applicable laws.