Fisher Investments Canada Privacy & Cookie Policy

(This version of the Policy is in effect as of October 2022)

General

Fisher Asset Management, LLC (“Fisher Investments Canada”, “we” or “us”) is committed to protecting the privacy and confidentiality of your personal information. This Privacy & Cookie Policy sets out how Fisher Asset Management, LLC, which does business as Fisher Investments Canada and Fisher Investments, collects, stores, uses and discloses personal information (as defined below) concerning current and prospective clients, employment applicants and employees who are residents of Canada, as well as visitors to our Canadian websites (collectively, “Individuals” or “you”).

At any time that you provide us with personal information or otherwise interact with us, you are protected by the rights and safeguards contained in this Privacy & Cookie Policy and you explicitly agree to its terms. Depending on the sensitivity of the personal information and any standards or requirements established by applicable law, Fisher Investments Canada may also seek additional consent from Individuals for the collection, use or disclosure of their personal information through account opening documentation and other written agreements.

This Privacy & Cookie Policy also explains how we use cookies and similar technologies on our Canadian websites and subsites.

Any changes to this Privacy & Cookie Policy will be posted at https://www.fisherinvestments.com/en-ca/privacy. You can also access this Privacy & Cookie Policy via our homepage and from the bottom of every page by clicking on the appropriate link in the footer. We encourage you to periodically review this Privacy & Cookie Policy and any revisions thereto to ensure that you are familiar with the most current version.

What personal information Fisher Investments Canada collects

When used in this Privacy & Cookie Policy, “personal information” means any information about an identifiable individual. This may include, for example, your name, contact information, email-address, employment history, payroll information and information relating to your account with us, including your identity and the services you use. It may also include other types of more technical information collected about Individuals who visit our Canadian websites, but only when this information can identify you as an individual. Personal information that is aggregated and cannot be associated with an identifiable individual is not considered to be personal information.

Fisher Investments Canada may collect the following personal information concerning Individuals:

• Fisher Investments Canada requires that Individuals who request informational materials supply personal information, including name, address, telephone number and email address prior to receiving such materials; this personal information enables us to provide you with the information you request.
• Fisher Investments Canada collects relevant personal information on applications and CVs from prospective employees via our careers website.
• Fisher Investments Canada collects other personal information that a prospective client, client, prospective employee, or employee may provide, such as financial statements or other information necessary to analyze a prospective client’s financial situation. This information may be provided orally or in writing by various means, including mail, phone, electronic message, online form, or in person.
• Fisher Investments Canada may place ads on publishers’ websites or within email content, either directly through the publisher of the website or via a third party. As a result of Individuals interacting with the advertising content, ad server companies may collect information about Individuals such as domain type, IP address and clickstream data. This information is only identifiable by IP address and is not linked to any other personal information.
• Our websites use cookies and other tracking technologies such as pixels, tags, and web beacons to collect technical information, such as the IP address, browser used to view the website, operating system, resolution of screen, location, language settings in browser, the site directing to our site, keywords searched, the number of page views, inferences drawn from any personal information, etc. Please see Cookie Policy below.
• Fisher Investments Canada may, with the consent of the Individuals concerned, collect other personal information, including: birth date and birth place, gender, education, occupation, employment history and information, information about activities, memberships, licences, certifications or awards, benefits information, marital status, citizenship, visa information, identification numbers, financial situation, account numbers, personal interests, income, family information, banking details, compensation and payroll information, leave of absence information, dependents or beneficiaries (including name, address, email and phone), emergency contacts, background check information and health information.

How Fisher Investments Canada uses personal information collected

Fisher Investments Canada may combine personal information collected by it and use it for the following reasons:

• To provide investment advisory and portfolio management services for clients and prospective clients.
• To meet legal and regulatory requirements and allow Fisher Investments Canada to meet contractual requirements relating to the products and services offered to clients.
• For internal record keeping purposes.
• To provide informational materials expressly requested by Individuals.
• To improve Fisher Investment Canada’s websites, products and services.
• To authenticate the identity and preserve the privacy of Individuals contacting Fisher Investments Canada by telephone, electronic means or otherwise.
• Subject to the right to withdraw consent to Marketing Communications and Commercial Electronic Communications as set out in this Privacy & Cookie Policy, for marketing purposes, including direct marketing.
• Subject to the right to withdraw consent to Marketing Communications and Commercial Electronic Communications as set out in this Privacy & Cookie Policy, Fisher Investments Canada or its authorized representatives may, where permitted by law, follow up by email, phone, or mail with Individuals who expressly request informational materials, notably, in order to:
  • provide information about Fisher Investments Canada, its services as well as recent developments and other information that Individuals may find interesting; or
  • invite Individuals to participate in market research.
• For market optimization, including analyzing and improving our marketing campaigns, subject to the right to withdraw consent, by using the information in the How to Access and Correct Information section of this Privacy & Cookie Policy below.
• To recruit and evaluate prospective employees for positions.
• To monitor and manage the employment relationship with its employees, including monitoring the advice process, recording and monitoring certain telephone calls, processing payroll and providing benefit programs.
• To supervise employees, including monitoring emails, voicemails and other activities as recorded on computer, telecommunications and security systems.
• For internal training.
• As otherwise permitted by law.

Marketing Communications and Commercial Electronic Communications

Individuals may at any time withdraw their consent to marketing communications and to commercial electronic communications as follows:

• Mail marketing and telephone marketing. Individuals who prefer Fisher Investments Canada not use their personal information to contact them by mail or telephone for marketing purposes may advise us by using the information in the How to Access and Correct Information section of this Privacy & Cookie Policy below.
• Commercial Electronic Communications. Individuals can opt-out of receiving marketing emails by clicking the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send to you. Please note that even if you opt-out of such communications, we may still need to contact you with important information about your account.

How Fisher Investments Canada shares personal information collected

Fisher Investments Canada will not sell or lease personal information to third parties. However, we may share your personal information as follows:

• Third party service providers. Fisher Investments Canada may share information with vendors, service providers, agents and representatives, including, without limitation, custodians that hold Individuals’ assets managed by Fisher Investments Canada, dealers who execute trade order instructions for Individuals who are clients, companies that carry out sanctions and anti-money laundering checks, information technology security providers, direct marketing agents and services providers, legal advisers and auditors. Fisher Investments Canada provides such service providers with a limited amount of information necessary in order for such service providers to provide the work or services required. They are contractually prohibited from using the information for purposes other than to facilitate and carry out the work or services they have been engaged to provide. Fisher Investments Canada will strive to protect personal information disclosed to third parties by contractual agreements requiring that those third parties adhere to appropriate confidentiality and security protections.
• As permitted or required by law. From time to time, Fisher Investments Canada may be compelled to disclose personal information in response to a law, regulation, court order, subpoena, search warrant, government investigation or other legally valid request or enquiry. In these circumstances, Fisher Investments Canada will protect the interests of its clients by making reasonable efforts to ensure that orders or demands comply with the laws under which they were issued, and that it discloses only the personal information that is legally required. Fisher Investments Canada also reserves the right to report to law enforcement agencies any activities that it believes, in good faith, to be unlawful or where required or permitted by law. Fisher Investments Canada may release certain personal information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property and safety of others and itself, in accordance with or as authorized by law.
• Business transactions. Fisher Investments Canada may disclose personal information to a third party in connection with a sale or transfer of business or assets or reorganization or financing of parts of its business.

Transfer of Personal Information Outside of Canada

Fisher Investments Canada is a US company located in the United States. Accordingly, Fisher Investments Canada transfers information to the United States. This information may be subject to US laws and accessible to US government, courts or law enforcement or regulatory agencies. Information may be held at the following Fisher Investments Canada locations:

• 5425, 5525 and 5700 NW Fisher Creek Drive, Camas, Washington 98607, USA
• 13100 Skyline Boulevard, Woodside, California 94062, USA
• 1450 Fashion Island Boulevard, Suite 300, San Mateo, California 94404, USA
• 6500 International Parkway, Suite 2050, Plano, Texas 75093, USA
• 3109 W Martin L King Jr Boulevard, Suite 600, Tampa, Florida 33607, USA

While Fisher Investments Canada uses reasonable measures, when possible, to favor Canadian service providers, your personal information may in some circumstances be transferred, processed and/or stored by service providers in foreign jurisdictions, and may therefore be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. Fisher Investments Canada will strive to protect personal information disclosed to such foreign service providers by contractual agreements requiring that they adhere to appropriate confidentiality and security protections.

How to access and correct personal information

Individuals may contact Fisher Investments Canada at any time to request access to personal information Fisher Investments Canada maintains about them or to correct any inaccuracies in such information. Fisher Investments Canada can be contacted by mail, email or telephone as follows:

Fisher Asset Management, LLC

trading as Fisher Investments

ATTN: Data Protection Officer

6500 International Parkway

Plano, Texas 75093

United States of America

privacy@fi.com

1 (650) 851 3334

In each case, please ensure that full name and address are provided in exactly the form in which they were originally provided to Fisher Investments Canada to avoid any possible confusion with a different Individual.

Any questions or privacy-related complaints with respect to the collection, use, disclosure, or storage of personal information by Fisher Investments Canada can be forwarded to Fisher Investments Canada’s Data Protection Officer using the contact details above.

Security

In order to protect against unauthorized access or disclosure, Fisher Investments Canada has put in place reasonable physical, electronic and managerial procedures that are designed to safeguard and secure personal information. Fisher Investments Canada uses encryption when collecting or transmitting sensitive personal information, including when transmitting such information over the Internet.

Other Websites

The Canadian websites of Fisher Investments Canada may contain links to enable Individuals to visit other websites of interest easily. However, once Individuals have used these links to leave our websites, Individuals should note that Fisher Investments Canada does not have any control over other websites. Therefore, Fisher Investments Canada cannot be responsible for the protection and privacy of any information that Individuals provide while visiting such sites and such sites are not governed by this Privacy & Cookie Policy. Individuals should exercise caution and review the privacy and cookie policies applicable to the website in question.

Cookie Policy

A cookie is a small text file with an identification tag that is created and downloaded to an Individual’s computer (or other device) when accessing webpages that use them. Cookies allow a website to, among other things, store and retrieve information about an Individual’s online activity, browsing habits, or computer (or other device).

Cookies can be categorized by who places them:

• First-party cookies: These cookies are downloaded to an Individual’s computer (or other device) from a server or domain managed by the publisher of the website whose service the Individual is requesting.
• Third-party cookies: These cookies are downloaded to a computer (or other device) from a server or domain that is not managed by the publisher of the website, but by another entity that may be seeking data obtained through cookies.

Cookies can also be categorized by their duration:

• Session cookies: These cookies are designed to collect and store data while the Individual accesses a website. They are often used to store information for the duration of a visit to the website (e.g., what account you are logged into). Once an Individual leaves the website, the session cookie is deleted.
• Persistent cookies: These cookies store data on a computer (or other device) for the duration of the period set within the cookie’s file, which is determined by the entity controlling the cookie, and can range from a few minutes to several years, or until manually deleted.

Lastly, cookies can be categorized by the function they serve. Fisher Investments Canada uses the following types of first and third-party cookies:

1. Functionality Cookies

Fisher Investments Canada uses functionality cookies to keep track of whether or not an Individual has consented to have other types of cookies placed on his/her computer (or other device) and, if the Individual has consented, to note when consent was obtained. Functionality cookies do not collect any personal information. Enabling functionality cookies may be necessary to access the full content of website material.

2. Personalisation Cookies

Personalisation cookies allow a website to remember information that changes the page’s appearance or behaviour, such as, for example, the language selected for viewing the page.

Fisher Investments Canada uses third party personalisation cookie services, and these companies may have access to information collected by the cookies.

3. Analytics Cookies

Analytics cookies analyse how Individuals browse a website and enable Fisher Investments Canada to measure the number of visitors to its websites, as well as to measure and analyse how Individuals interact with the websites. This information is used to improve the websites and the products or services offered.

Fisher Investments Canada uses third party analytics cookie services, and these companies may have access to information collected by the cookies.

4. Behavioural Advertising Cookies

Fisher Investments Canada serves advertisements on various websites using third-party companies. If an Individual visits a website or clicks on one of Fisher Investments Canada’s advertisements, behavioural cookies will be placed on the Individual’s computer (or other device).

Behavioural cookies allow Fisher Investments Canada to manage and optimise its digital marketing (e.g. banner ads, pages offering informational brochures, email campaigns, etc.). Behavioural cookies may be used to build a profile to provide an Individual with content more relevant to his or her interests. They adapt advertising and the content the Individual sees on other websites based on his or her browsing habits, including how the Individual navigates websites, as well as how the Individual interacts with internet advertising.

Fisher Investments Canada uses third party behavioural cookie services, and these companies may have access to information collected by the cookies.

How to Manage Cookies

To learn more about behavioural advertising cookies and to opt in or out of multiple advertising networks at once, you can visit the website Your AdChoices.

Some advertising networks do not participate in the Your AdChoices service. To opt out of some of these networks, please visit the consumer opt-out page of the Network Advertising Initiative.

As explained above, cookies help you to get the most out of the websites that make use of this technology. Disabling cookies may affect the functionality of many of the websites you visit. If you do disable cookies, performance and functionality will be affected. If you wish to delete, disable, or re-enable cookies, you may do so through your browser as follows:

• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Safari: http://www.apple.com/ca/support/mac-apps/safari/
• All other browsers: Please look for a ‘help’ function in the browser or contact the browser provider.

Changes to Privacy & Cookie Policy

From time to time, Fisher Investments Canada may use information for new, unanticipated uses not previously disclosed in its Privacy & Cookie Policy. If its information practices change at some time in the future, Fisher Investments Canada will post the policy changes to https://www.fisherinvestments.com/en-ca/privacy to notify Individuals of these changes and provide the ability to opt out or unsubscribe from these new uses. If Individuals are concerned about how information is used, they should check Fisher Investments Canada’s website periodically.