GFA offers an almost unparalleled combination of extensive industry contacts, in-house expertise, forward-thinking innovation and comprehensive personal service. People are the backbone of GFA. Our employees are leaders in their fields. They bring extensive product knowledge, broad industry education and a dedication to thoughtful and innovative solutions.

We have instituted the highest standards possible for staying at the forefront of our industry and serving our customers. As we climb towards the future, we intend to take those standards even higher. By providing expert guidance, GFA aims to become a trusted advisor to their clients. – We work hard to ensure our clients’ requirements are met.

THE NEED FOR TRUST

Trust comes with confidence. The more you know about us, the more confident you can feel about dealing with GFA. Similarly, the more we know about you, the better we can serve you.

Because it is important that we keep your trust, we will only ask for information we need, and when we ask you for information, we’ll let you know why we need it.

Subject to legal and contractual requirements, you can refuse to consent to our collection, use or disclosure of information about you, or withdraw your consent to our further collection, use or disclosure of information at any time by giving us reasonable notice in writing.

If you refuse or withdraw your consent to the collection, use or disclosure of information about you, we may not be able to provide or continue to provide you with some products, services or information of value to you.

THE NEED FOR ACCURACY

While GFA tries to ensure that the information we hold about you is accurate, complete and up-to-date, it is in your obligation to inform promptly of a change of name, address or any other relevant information.

If you believe that personal factual information in your records may be inaccurate, we make it easy for you to access, verify and update it. If information has been provided to third parties, we will convey the corrected information to them, if necessary.

If we do not agree to change your personal information, you may challenge our decision. We will make a record of this challenge and, if necessary disclose the challenge to third parties who also possess the information.

THE NEED FOR ACCESS

To review the personal information, which GFA has about you, simply notify our management team. Basic personal information can be verified on the spot, at no charge. If you wish to review more extensive information, you’ll be asked to provide details regarding the nature of the information you wish to check.

The information will be obtained from our files and will normally be provided within 30 days of your request. There may be a charge for retrieving this information, in which case you will be notified in advance and may, if you like, withdraw your request. You may also challenge the reasonableness of the charge.

Sometimes we may not provide you with information about you that is within our control. This can occur if your right of access is constrained pursuant to the provisions of the Federal Laws in place. For example, we will not provide you with personal information in our control if:

It would reveal personal information about another party and your personal information cannot be separated. The information is subject to solicitor/client or litigation privilege. The information is used for the detection and prevention of criminal activity and dealings in the proceeds of crime. If we deny your request for access to your personal information, you will be told why, unless prohibited by law. You may challenge that decision.

Once you have the information, all you have to do is check it for accuracy and let us know if there are any corrections required. We will correct our records or make note of any differences. If information has been provided to third parties, we will convey the corrected information or the note of any differences to them, if necessary.

A DECLARATION OF CLIENT PRIVACY RIGHTS: PUTTING THE CLIENT FIRST

We at GFA are committed to holding our client’s personal information in strict confidence, and we shall not disclose any such information unless authorized by our clients, required by law to do so, or required to do so in conducting negotiations with underwriters. Our Privacy Code builds on this commitment.

Principle # 1 GFA is Accountable

GFA is accountable for all personal information in its possession or custody, including any personal information disclosed to third parties for processing or other administrative functions. GFA has established policies and procedures to comply with this declaration, and has designated a privacy officer to be accountable for compliance.

Principle # 2 GFA will Identify Purposes

GFA will identify the purposes for which it collects personal information, before or when the information is collected.

Principle # 3 GFA and the Client’s Consent

A customer’s consent can be expressed, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions by requesting us to do so in writing.

Principle # 4 GFA Limits the Collection of Personal Information

GFA limits the amount and type of personal information it collects.

Principle # 5 GFA Limits the Use, Disclosure and Retention of Personal Information

GFA will use or disclose personal information only for the reasons it was collected, unless a customer gives consent to use or disclose it for another reason, or it is permitted or required by law.

Under certain exceptional circumstances, GFA may have a legal duty or right to disclose personal information without the customer’s knowledge or consent to protect the interests of the public interest.

GFA will keep personal information only as long as necessary for the identified purposes for which it was collected.

Principle # 6 GFA will keep Personal Information Accurate

GFA will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected.

Customers may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.

Principle # 7 GFA Safeguards Client Information

GFA protects personal information with safeguards appropriate to the sensitivity of the information.

Principle # 8 GFA makes its Information Policies Available to its Clients

GFA is open about the policies and procedures it uses to manage personal information. Customers have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.

Principle # 9 GFA makes Personal Information Accessible

When customers make a request in writing, GFA will within a reasonable time tell them what personal information it has, what it is being used for, and to whom it has been disclosed.

When customers request it in writing, GFA will give them access to their personal information. GFA will respond to the written request in a timely fashion. In certain situations, however, GFA may not be able to give customers access to all their personal information. GFA will explain the reasons for this lack of access and any recourse the customer may have, except where prohibited by law.

Principle # 10 GFA is committed to Addressing Client Complaints and Concerns

Customers may challenge GFA’s compliance with this declaration. GFA has policies and procedures to receive, investigate, and respond to customer complaints and questions.

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