Privacy Policy

1. Introduction

Numis Trust Company Inc. (“Numis Trust”, “we”, “us”, or “our”) is a regulated Special-Purpose Trust Company headquartered in Calgary, Alberta. We are supervised by Alberta Treasury Board and Finance (ATBF) under the Loans and Trust Corporations Act. In the course of providing custodial, fiduciary, and related trust-company services, we collect and use personal information to operate our business, comply with applicable laws, and deliver services to clients and visitors.

This Privacy Policy explains how we collect, use, disclose, safeguard, and retain personal information. It is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Alberta privacy legislation.

We provide services to individuals and institutions in Canada. We do not market or provide services to residents of California or other jurisdictions requiring region-specific notices such as the CCPA. If our service footprint expands, we will publish a supplemental jurisdiction-specific notice.

2. Scope

This Policy applies to all personal information collected, used, or disclosed by Numis Trust in the course of our commercial activities. It also applies to personal information processed on our behalf by service providers under contract.

Personal information may be collected for purposes including:

• Client onboarding and compliance with regulatory obligations
• Employment applications and HR administration
• Responding to enquiries from clients, prospects, or the public
• Registration for Numis Trust events
• Administration and logging of activity on our website and digital platforms
• Security monitoring of premises, systems, and information assets, including CCTV and access logs
• Any additional purpose permitted by law or otherwise disclosed at the time of collection

We may store or process information outside Canada where required for operations or through contracted service providers.

3. Principles

Numis Trust follows established privacy principles, including accountability, transparency, limited collection, limited use, safeguards, accuracy, openness, access, and compliance.

4. Collection, Use, and Disclosure

• We collect only the personal information reasonably required to deliver services, meet legal duties, operate our business, or fulfil the purpose disclosed at the time of collection.
• Whenever practical, we collect information directly from the individual.
• We use and disclose personal information only for the identified purpose, a purpose consistent with it, or as otherwise permitted or required by law.
• Consent is obtained when required. If we intend to use or disclose information for a new purpose, additional consent is obtained unless an exemption applies.
• Any disclosure to third parties occurs under agreements requiring appropriate security, confidentiality, and data-protection controls.

5. Safeguards

Numis Trust protects personal information using administrative, technical, and physical controls appropriate to the sensitivity of the data. These measures are aligned with our Record Keeping Policy and include:

• Access controls and authentication measures
• Encryption of sensitive information in transit and at rest
• Secure storage for physical records
• Monitoring and audit logging
• Vendor oversight and contractual security requirements

6. Retention and Disposal

Personal information is retained only as long as necessary to meet the purpose for which it was collected or as required by law. Retention periods and disposal requirements are defined in the Numis Trust Record Keeping Policy. When information is no longer required, it is securely destroyed or anonymized.

7. Accuracy and Corrections

We make reasonable efforts to ensure personal information is accurate, complete, and up to date. Individuals may request correction of personal information under our control by contacting the Privacy Officer. We may require sufficient information to verify identity before making changes.

8. Access to Personal Information

Individuals may request access to their personal information held by Numis Trust. Upon receiving a written request, we will respond within 30 days, subject to permitted extensions under PIPEDA.

Access may be limited where information contains references to other individuals, is subject to legal privilege, relates to investigations, or is otherwise exempt under law. If access is denied, we will provide reasons.

9. Complaints and Inquiries

Numis Trust investigates all privacy-related complaints promptly and confidentially. Individuals may submit complaints or questions in writing to our Privacy Officer.

If we cannot resolve a complaint, individuals may contact the Office of the Privacy Commissioner of Canada.

10. Changes to This Policy

Numis Trust may update this Policy periodically to reflect operational, legal, or regulatory changes. The effective date will be posted on our website. Material changes will be communicated where required by law.

11. Definitions

Personal Information

Information about an identifiable individual, including identifiers, contact details, government-issued numbers, financial information, employment details, communications with Numis Trust, and any other information defined by law.

Service Provider

A third-party organization engaged to process or store personal information on behalf of Numis Trust under contract.