1. Introduction

Wagner, Livock & Associates Financial Services Inc. ("WLA," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you entrust to us. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in connection with our website at wagnerlivock.com (the "Site") and, more generally, in the course of operating our business and providing our financial and advisory services.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable Canadian privacy laws. This policy reflects the ten fair information principles that form the foundation of those laws.

By using the Site, or by providing personal information to us, you acknowledge that you have read and understood this policy. If you do not agree with it, please do not use the Site or submit information through it.

This policy addresses personal information collected through the Site and in the general conduct of our business. Where we act as an advisor, broker, intermediary, or administrator in connection with group benefit programs, group retirement and savings programs, or other services, additional privacy terms may apply under the relevant plan documents, provider and carrier agreements, and engagement letters. Where those terms apply, they govern the information collected for those purposes.

2. Accountability and our Privacy Officer

WLA is responsible for the personal information under its control. We have designated a Privacy Officer who is accountable for our compliance with this policy and with applicable privacy law, including personal information transferred to third parties for processing on our behalf. You may reach our Privacy Officer using the contact details in Section 16.

3. The personal information we collect

We collect only the personal information we need for the purposes described in this policy.

• Information you provide to us directly. When you contact us or submit a form on the Site, we may collect your name, the name of your organization, your business role or title, your email address, your telephone number, and the content of your message or enquiry. If you apply for a position through the Site, we may collect the information contained in your application, such as your resume, cover letter, contact details, and employment history. If you subscribe to receive materials from us, we collect the details you provide for that purpose.

• Information collected automatically. When you visit the Site, certain information is collected automatically through server logs and cookies, including your Internet Protocol (IP) address, browser type and version, operating system, device information, the pages you view, the dates and times of your visits, the site or source that referred you, and general location inferred from your IP address.

• Information from other sources. On occasion we may receive personal information from third parties, for example when someone refers you to us, or from the service providers that help us operate the Site and our business.

• A note on sensitive information. The public Site is not intended for the collection of sensitive personal information, such as financial account numbers, government identifiers, or health information. Please do not submit sensitive information through web forms or by ordinary email. Where sensitive information is genuinely required to deliver our services, we collect it through secure and appropriate channels under separate agreements.

4. Cookies and similar technologies

Our Site is hosted on the Squarespace platform, which uses cookies and similar technologies to operate the Site, remember your preferences, keep the Site secure, and understand how the Site is used. Cookies are small files placed on your device.

The technologies we use generally fall into these categories: strictly necessary cookies that are required for the Site to function and cannot be switched off; functional cookies that remember your choices; and analytics or performance cookies that help us understand how visitors use the Site so we can improve it. We may also use analytics tools to measure Site traffic and performance.

You can control and delete cookies through your browser settings, and you can set your browser to notify you when cookies are being placed. If you disable certain cookies, some parts of the Site may not function as intended. Where a cookie consent banner is presented on the Site, you may use it to manage your preferences.

5. Why we collect and use personal information

We identify the purposes for which personal information is collected at or before the time of collection. We collect and use personal information to:

• respond to your enquiries, requests, and communications;

• provide, administer, maintain, and improve the Site and our services;

• send you materials, updates, or information that you have requested;

• consider and process applications for employment;

• understand how the Site is used, and to maintain its performance, integrity, and security;

• comply with our legal, regulatory, and professional obligations; and

• establish, exercise, or defend legal claims, and otherwise protect our rights, our clients, and the security of the Site.

We do not use personal information for purposes that are materially different from those identified without obtaining your consent, unless permitted or required by law.

6. Consent

We obtain your consent to collect, use, and disclose your personal information, except where the law permits or requires us to act without it. The form of consent we seek, whether express or implied, depends on the sensitivity of the information and the circumstances. By submitting information through the Site, you consent to our handling of that information as described here.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawing consent may limit or prevent us from providing certain services or responding to your requests. We will explain the likely consequences before acting on a withdrawal.

Where we send commercial electronic messages, we do so in accordance with Canada's Anti-Spam Legislation (CASL). You may unsubscribe from such messages at any time using the mechanism provided in the message or by contacting us.

7. How we disclose personal information

We do not sell your personal information. We may disclose personal information in the following circumstances:

• Service providers. We share information with third parties that perform services on our behalf, such as website hosting and platform services, analytics, email delivery, and information technology support. These providers are authorized to use personal information only as necessary to provide their services to us and are bound by appropriate confidentiality and security obligations.

• Professional and business partners. Where relevant to the services you have engaged us for, and under appropriate terms, we may share information with insurers, plan providers, plan administrators, or our own professional advisors.

• Legal and regulatory. We may disclose information where required or permitted by law, regulation, legal process, or the request of a regulatory or governmental authority, and to meet our professional obligations.

• Business transactions. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be disclosed as part of that transaction, subject to appropriate confidentiality protections.

• With your consent. We may disclose information for any other purpose with your consent.

8. Service providers and information stored outside Canada

Some of our service providers, including our website platform provider (Squarespace, Inc.) and certain analytics and email providers, are located in, or store and process data in, the United States or other countries. As a result, your personal information may be processed and stored outside Canada, where it may be accessible to courts, law enforcement, and regulatory or national security authorities under the laws of those jurisdictions.

When we transfer personal information to a service provider for processing, whether in Canada or abroad, we use contractual and other reasonable measures to require that the information receive a comparable level of protection to that described in this policy. You may contact our Privacy Officer to ask about our practices regarding service providers located outside Canada.

9. How long we keep personal information

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected, or as required to meet legal, regulatory, professional, or contractual obligations. When personal information is no longer required, we take reasonable steps to securely destroy, erase, or anonymize it.

10. How we protect personal information

We maintain physical, organizational, and technological safeguards designed to protect personal information against loss, theft, and unauthorized access, disclosure, copying, use, or modification, appropriate to the sensitivity of the information. These measures include restricted access, secure hosting, confidentiality obligations for our people and providers, and internal policies and training.

No method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping any credentials confidential, and we ask that you not send sensitive personal information to us by unencrypted email.

11. Keeping information accurate

We make reasonable efforts to keep personal information as accurate, complete, and up to date as is necessary for the purposes for which it is used. You can help us by letting us know when your information changes.

12. Your right to access and correct your information

Subject to the exceptions permitted or required by law, you have the right to request access to the personal information we hold about you, to ask how it has been used and to whom it has been disclosed, and to request the correction of information that is inaccurate or incomplete.

To make a request, please contact our Privacy Officer. We may ask you to verify your identity before we act on a request. We will respond within the timeframes required by applicable law, which under PIPEDA is generally thirty days, and we will explain any refusal and your options. Where the law permits, a reasonable, cost-based fee may apply, and we will advise you of any such fee in advance.

13. Children's privacy

The Site is intended for a professional and business audience and is not directed to children. We do not knowingly collect personal information from individuals under the age of majority in their province or territory. If you believe we have inadvertently collected such information, please contact our Privacy Officer and we will take appropriate steps to delete it.

14. Third-party links

The Site may contain links to websites and resources operated by third parties. We provide these links for convenience and do not control, endorse, or assume responsibility for the content or privacy practices of those third parties. We encourage you to review the privacy policies of any third-party site you visit.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we do, we will revise the "Last updated" date above, and the updated policy will take effect when it is posted on the Site. Where changes are material, we will take reasonable steps to bring them to your attention. Your continued use of the Site after an update constitutes acceptance of the revised policy.

16. How to contact us

If you have questions, concerns, or requests regarding this policy or your personal information, or if you wish to exercise your rights, please contact our Privacy Officer:

Privacy Officer Wagner, Livock & Associates Financial Services Inc. 2-379 Queen Street South, Kitchener, Ontario N2G 1W6 Telephone: (519) 570-4633 Toll-free: 1 (800) 567-0822 Email: WLA@wagnerlivock.com

We will investigate and respond to your questions and concerns. If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada Website: priv.gc.ca Telephone: 1-800-282-1376