ABOUT US INVESTOR INFORMATION CONTACT Privacy Policy Privacy Statement ICPEI Holdings Inc.[1] (“ICPEI Holdings”, “we, “us” or “our”) is committed to safeguarding your personal information. The purpose of this Statement is to inform you and describe how we collect, use and disclose personal information in Canada. Our Privacy Statement takes into account Canadian legislative requirements, industry standards and privacy principles. This Statement does not apply to information about our employees or to information that is not personal information. What is personal information? Personal information is information that can be used to explicitly identify you or contact you. This includes information such as your name, e-mail address, mailing address, phone number, birth date, or any specific information about you requested in order to provide you with insurance coverage or to investigate an insurance claim. Information that, by itself, cannot be explicitly linked with your identity is not considered personal information. Collection, use and disclosure of personal information ICPEI and our representatives and agents collect, use and disclose personal information for the following purposes: Maintaining communications with customers and brokers; Servicing, billing and administration of policies and claims; Underwriting your policy application including changes or renewals; Investigating and settling claims; Detecting and preventing fraud, suspicious claims or other illegal activities; Compiling statistics for analysis of our business and underwriting research and modeling; Performing administrative tasks such as accounting and information system activities; Reporting to regulatory and/or insurance entities; Notifying you from time-to-time of certain products or services offered by Echelon; Responding to your inquiries regarding your account(s) and other services; and Acting as required or authorized by law enforcement agencies. Outside agents and representatives of ICPEI Holdings that collect, use or disclose personal information on our behalf do so in compliance with this Statement and only for the purposes set out in this Statement. Sharing personal information with others ICPEI Holdings does not disclose any personal information about you to third parties except as described below or as required or permitted by law. General Disclosure within ICPEI In providing services to you, ICPEI may share your personal information with its affiliated companies. Affiliated companies will only use, retain and disclose personal information for the purposes identified in this Statement. Disclosure to Third Parties From time-to-time and as needed, ICPEI Holdings may disclose your personal information to outside agents or service providers that perform services on our behalf, for example insurance brokers, insurance agents, reinsurers, information technology, mailing providers, appraisers, data processing, private investigators, adjusters and lawyers, or similar service providers. Outside agents or service providers that collect and use personal information are subject to ICPEI’s confidential policies and are governed by this Statement and applicable privacy legislation. Personal information may be used by ICPEI Holdings and disclosed to third parties connected with the proposed or actual financing, securitization, insuring, sale, assignment or disposal of all, or part, of ICPEI Holdings or our business assets for the purpose of evaluating and performing the proposed transaction. ICPEI Holdings may disclose personal information as necessary to meet legal, regulatory, insurance, audit and security requirements and as otherwise with your consent or as permitted or required by law. Disclosure Outside of Canada Personal information may be collected, used, disclosed, transferred, stored or processed outside of Canada for the purposes described in this Statement, and may be subject to legal requirements in foreign countries applicable to us or the third parties described above, for example lawful requirements to disclose personal information to government authorities outside of Canada. Consent Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express (for example, orally, electronically or on a form you may sign describing the intended uses and disclosures of personal information) or implied (for example, when you provide information necessary for underwriting or claims adjustment). Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney). Generally, by providing us with personal information, we will assume that you consent to our collection, use and disclosure of such information for the purposes identified or described in this Statement. You may withdraw your consent to our collection, use and disclosure of personal information at any time, subject to contractual and legal restrictions and reasonable notice. If you decide to withdraw your consent to certain uses of your personal information, we may no longer be able to provide our products or services. Where we have provided, or are providing, insurance coverage to you, your consent will be valid for so long as necessary to fulfil the purposes described in this Statement or otherwise at the time of collection, and you may not be permitted to withdraw consent to certain necessary uses and disclosures (for example, but not limited to, maintaining reasonable business and transaction records and disclosures to Canadian and provincial government entities as required to comply with laws). ICPEI Holdings collects, uses and discloses your personal information with your consent, except as permitted or required by law. We may be required or permitted under statute or regulation to collect, use or disclose personal information without your consent, for example to comply with a court order, to comply with local or federal regulations or a legally permitted inquiry by a government agency, or to collect a debt owed to us. Safeguards ICPEI Holdings has reasonable security measures, appropriate to the sensitivity of the information in our control, in place to protect personal information against loss and theft, as well as unauthorized use, disclosure, copying or modification. Authorized employees and third parties will have access to personal information in order to fulfill their employment requirements but we limit access to personal information to those employees and third parties on a “need to know basis” in accordance with this Statement. ICPEI Holdings assumes no liability for the interception, alteration or misuse of information transmitted to us over the internet or misdirected by mail. Retention and Destruction ICPEI Holdings will only retain your personal information for as long as we have a relationship with you or as required by law. Once the retention period expires, your personal information will be destroyed, made anonymous, and or archived to a secure site. Access to your information Upon written request and upon confirmation of your identity, you may request a copy of the personal information we have on hand at any time. ICPEI Holdings will respond to all requests within 30 days. If an extension is required, we will inform you accordingly. Where a request for disclosure is denied, we will provide you with an explanation for the denial. ICPEI Holdings makes every reasonable effort to keep your information accurate and up to date. If you believe that our information is incomplete or needs updating please contact us and we will work with you to make the necessary updates. Your right to access or to change personal information may be subject to legal requirements. Updates to our Privacy Statement ICPEI Holdings reserves the right to modify this Statement at any time. If there is any significant updates to this Statement, ICPEI Holdings will post a notice of the change on its Web site. You are encouraged to regularly review the Statement for changes. If we intend to use or disclose personal information for purposes materially different than those described in this Statement we will make reasonable efforts to notify affected individuals. Contact If you have any questions about this Privacy Statement, you may contact: Chief Compliance Officer ICPEI Holdings Inc. 200 – 2800 Skymark Avenue Mississauga, ON L4W 5A7 [1] This Statement applies to ICPEI Holdings Inc., and all of its related and affiliated companies operating in Canada, including, but not limited to, the Insurance Company of Prince Edward Island. Reference to ICPEI Holdings in the Statement is reference to all related and affiliated companies in Canada. 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