Privacy Policy

Protecting your personal information — Compliance with Quebec’s Law 25

1. Our commitment

At Pérennité Gestion de Patrimoine inc., protecting your personal information is a priority. We are committed to respecting your privacy and to applying industry best practices as well as the applicable regulations.

This policy describes the personal information we collect, how we use it, the protection measures we apply, and your rights regarding it, in accordance with the Act to modernize legislative provisions as regards the protection of personal information (Law 25).

2. Personal information we collect

In the course of providing our services, we may collect the following categories of personal information:

2.1 Identity information

• First and last name, date of birth;
• Social insurance number (SIN);
• Identity documents (driver’s licence, passport);
• Address, phone number, email.

2.2 Financial information

• Income, assets, liabilities, net worth;
• Bank accounts, existing investments;
• Tax returns;
• Risk tolerance, financial goals.

2.3 Professional information

• Employment, employer, industry;
• Family status, dependants;
• Designated beneficiaries.

2.4 Sensitive information

In certain circumstances, we may also collect health information (for insurance products) or other sensitive information that is strictly necessary to provide our services.

3. Purposes of collection

We collect your personal information solely for the following purposes:

• Provide financial advice tailored to your situation;
• Open and manage your investment accounts;
• Apply for insurance products on your behalf;
• Meet our regulatory obligations (AMF, CRA, CIRO);
• Communicate with you about our services;
• Detect and prevent fraud;
• Improve the quality of our services.

We do not collect any information beyond these purposes without your explicit consent.

4. Consent

The collection, use and disclosure of your personal information rely on your free and informed consent. This consent may be:

4.1 Explicit

Given in writing or verbally, for example when opening a client file.

4.2 Implied

Arises from the context of the relationship, for example when you provide us with information to obtain a specific service.

You may withdraw your consent at any time, subject to legal and contractual restrictions. Withdrawing consent may, however, affect our ability to provide our services.

5. Disclosure to third parties

Your personal information may be disclosed to the following third parties, solely for the intended purposes:

5.1 Business partners

• MICA Capital inc. — for managing investment accounts;
• Insurance companies — for underwriting products;
• Custodial financial institutions (Olympia Trust, Fidelity, etc.);
• Technology service providers (FutureVault for secure storage).

5.2 Regulatory authorities

• Autorité des marchés financiers (AMF);
• Canadian Investment Regulatory Organization (CIRO);
• Canada Revenue Agency (CRA), Revenu Québec;
• Any other body required by law.

No personal information is sold, rented or traded for commercial purposes with third parties.

6. Retention and destruction

Your personal information is kept for as long as necessary to fulfill the purposes for which it was collected, and to meet our legal and regulatory obligations.

For reference:

• Active client files: for the entire duration of the business relationship;
• Closed client files: a minimum of seven (7) years after the end of the relationship;
• Complaint files: a minimum of five (5) years after they are closed.

Once these periods expire, the information is destroyed securely and irretrievably.

7. Security of information

We put in place reasonable physical, technical and organizational security measures to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification.

These measures include, among others:

• Encryption of sensitive data;
• Restricted access on a “need-to-know” basis;
• Strong passwords and two-factor authentication;
• Ongoing training of employees and representatives;
• Regular auditing and review of practices.

8. Your rights

Law 25 grants you several rights regarding your personal information:

8.1 Right of access

You may ask to review the personal information we hold about you.

8.2 Right of rectification

You may request the correction of any personal information that is incomplete, inaccurate or ambiguous.

8.3 Right to portability

You may request that your personal information be provided to you in a structured, commonly used technological format.

8.4 Right to withdraw consent

You may withdraw your consent to the collection, use or disclosure of your personal information at any time.

8.5 Right to file a complaint

You may file a complaint with the personal information protection officer or with the Commission d’accès à l’information du Québec.

9. Privacy incidents

In the event of an incident affecting your personal information and presenting a serious risk of harm, Pérennité is committed to:

• Promptly taking the necessary corrective measures;
• Notifying you as soon as possible;
• Notifying the Commission d’accès à l’information du Québec, in accordance with the law;
• Keeping a register of privacy incidents.

10. Personal information protection officer

In accordance with Law 25, Pérennité has designated a personal information protection officer:

admin@perennitegp.com

819-360-5651

Pérennité Gestion de Patrimoine inc.

178 boul. Gréber, Unit 101

Gatineau (Quebec) J8T 6Z6

11. Commission d’accès à l’information du Québec

If you are not satisfied with how we handle your personal information, you may contact:

Commission d’accès à l’information du Québec

Phone (Quebec City): 418-528-7741

Phone (Montreal): 514-873-4196

Toll-free: 1-888-528-7741

Website: cai.gouv.qc.ca

12. Changes to this policy

This policy may be amended to reflect regulatory, technological or operational changes. The most recent version will always be available on our website. Significant changes will be communicated to you.

Effective date: July 24, 2026

Last revised: July 24, 2026

Version: 1.0