Service Providers Outside Canada Policy

The Wawanesa Life Insurance Company ("Wawanesa") operates in an increasingly global business environment. To remain competitive in this environment, it is occasionally necessary to enter into arrangements for specialized services, such as information processing, that are provided, directly or indirectly, by businesses in other countries. These arrangements allow us to take advantage of business options that enhance our services to you, while reducing costs. From time to time, these arrangements require that we transfer your personal information out of Canada.

How we protect your personal information

In the event that we transfer your personal information to a service provider, we are responsible for ensuring that the service provider's handling of your personal information complies with applicable privacy law. This responsibility applies to personal information that we transfer to service providers located in Canada as well as to those located in other countries. Accordingly, before transferring personal information to any service provider, we contractually require the service provider to

1. protect the information in a manner that is consistent with our Personal Information Protection Policy and security practices, as well as applicable law; and
2. use the information only for purposes that we have authorized, and for which you have provided your consent.

When transferring personal information to service providers, we provide only the information necessary to perform the services for which we have engaged them. We do not transfer information for purposes other than those for which we have obtained your consent.

Just as personal information held in Canada by Wawanesa is subject to disclosure to Canadian law enforcement and other authorities in accordance with Canadian law, service providers outside Canada are bound by the laws of the jurisdictions in which they are located. These laws may require them to disclose personal information to the courts, law enforcement agencies, or national security authorities of those jurisdictions.

Service providers that we engage

The types of service providers that we engage may include

• reinsurance companies;
• information processing and storage providers;
• programming, printing, mailing and distribution services;
• paramedical, inspection and investigative firms;
• medical, psychiatric and dental consultants;
• the Medical Information Bureau;
• rehabilitation specialists;
• lawyers; and
• claims examiners.

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Purposes for transferring personal information outside Canada

We may transfer your personal information to service providers outside of Canada for one or more of the following purposes:

• communicating with you;
• underwriting risks on a prudent basis;
• investigating and paying claims;
• detecting and preventing fraud;
• offering and providing products and services to you;
• compiling statistics and analyzing business results;
• receiving payments on account of insurance premiums, investment contributions, policy loan repayments and mortgage payments;
• depositing funds into your account;
• approving and administering mortgages;
• acting as required or authorized by law; and
• processing or storing information in connection with any of these purposes.

Where we transfer your information

Most of the service providers that we use outside of Canada are located in the United States. However, given the global nature of information processing, your personal information may subsequently be relocated to any other country. For instance, a service provider in the United States may enter into an agreement with another service provider located in a different country concerning the services for which we engaged it. As a result, all or part of your personal information may be transferred to that other country. To ensure that your personal information continues to be protected in such circumstances, we contractually require our service providers to ensure that any service providers to whom they transfer our customer's personal information will maintain a comparable level of protection of that personal information.

Contact Information

If you have any questions or concerns about the collection, use, disclosure or storage of personal information by service providers outside Canada on our behalf, please contact the individual accountable for our personal information protection compliance:

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