In this document, you and your mean the individual who is a customer or potential customer of a member of the Sun Life Financial group of companies in Canada and we, us and our mean the members of the Sun Life Financial group of companies in Canada, who include Sun Life Financial Inc., Sun Life Assurance Company of Canada, Sun Life Financial Trust Inc., Sun Life Financial Advisory Inc., Sun Life Financial Realty Advisors Inc., Clarica Financial Services Inc., Clarica Investco Inc., and other affiliates of Sun Life Assurance Company of Canada, in Canada.

Our commitment to protecting your privacy, our policy

Collecting personal information about you is essential to our ability to offer you high-quality investment, retirement and insurance products and to provide you with on-going service relating to your lifetime financial needs. We take great care to keep your personal information which we collect accurate, confidential and secure.

Our Policy sets high standards for collecting, using, disclosing and storing personal information. Sun Life Financial's Canadian Privacy Policy is complemented by our Privacy Code and by procedures to manage your personal information.

If you have any questions about Sun Life Financial's Canadian Privacy Policy and Privacy Code, please contact our Canadian Privacy Officer at (416) 408-8850 or by email at "privacyofficer@sunlife.com".

Sun Life Financial's Privacy Policy For Canada

How we collect, use and disclose personal information
We will protect your personal information
Your right to access your personal information
For more information

How we collect, use and disclose personal information

We ask you for only the information we need

We collect only the information we need for the purposes we have identified to you.

Our files are kept for the purpose of providing and servicing financial and insurance products and services that we believe are right for you, over your lifetime.

We will not sell your personal information.

Why we need the information

Generally, we need to collect personal information to:

• understand your needs,
• determine your eligibility,
• continue to offer you the full range of products and services that we believe meet your changing needs and to service such products and services,
• meet regulatory or contractual requirements relating to the services and products provided to you.

We will make sure you understand why we need the information by using clear, understandable language when we identify the purpose.

We will obtain your permission

We collect, use or disclose your personal information with your permission.

Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative.

You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice.

Where medical information about you is collected or released, we will obtain your consent to do so. We will not share it with other members of the Sun Life Financial group of companies.

Before we make information available to third parties, other than an agent or service provider who needs it, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we want to share with them and why.

We will limit how long we keep information

We will keep your personal information as long as it is necessary, including updating the product or service or as required by law.

When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.

We will protect your personal information

We are responsible for your information

We are responsible for all personal information in our possession, including information transferred to a third party service provider or agent, so that we can provide you with a product or service.

All employees, agents and authorized service providers of Sun Life Financial are required to protect the confidentiality of your personal information.

How we protect information

Access to your personal information is restricted to those of Sun Life Financial's employees, agents and authorized service providers who need it to do their jobs.

We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a "need-to-know" basis, and technological measures such as the use of passwords and encryption. While we endeavour to protect all information, the most sensitive information, such as medical information, receives the highest level of protection.

Your right to access your personal information

Your rights

You have the right to ask whether we hold any personal information about you and to see that information, as provided by law. Where we have obtained medical information about you from a third party, we will release this information only through your physician.

You also have the right to know:

• how we collected your personal information,
• how we are using it, and
• to whom it may have been disclosed.
  

How to request an update or correction

If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it.

If you show that your personal information is inaccurate or incomplete, we will make the necessary changes.

If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.

How to register complaints

You may register a privacy-related complaint by contacting Sun Life Financial's Canadian Privacy Officer. We will explain Sun Life Financial's Canadian complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.

For more information

For more information, please contact Sun Life Financial's Privacy Officer in Canada at (416) 408-8850 or by email at privacyofficer@sunlife.com.

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Sun Life Financial's Privacy Code For Canada

Principle 2 - Identifying Purposes

The purposes for which personal information is collected shall be identified before or at the time the information is collected.

Principle 3 - Consent

The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.

Principle 4 - Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention

Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.

Principle 6 - Accuracy

Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.

Principle 7 - Safeguarding Information

Personal information will be protected by safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness

Members of the Sun Life Financial group of companies will make readily available to their customers specific information about our policies and procedures relating to the management of their personal information.

Principle 9 - Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Handling Customer Complaints and Suggestions

Individuals can address any complaint regarding compliance with the above principles with our Privacy Officer.

privacyofficer@sunlife.com

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