Last updated March 2026

This Privacy Policy (“Policy”) describes how Great-West Lifeco Inc. (“Great-West Lifeco”, “us”, “we” and “our”) handles personal information when you visit our website, through the ownership of and transactions dealing with our securities, and through other interactions related to you. We may update this Policy from time to time. Updates are effective on the date shown on this Policy.

Personal information is information that either on its own or combined with other information allows an individual to be identified. Examples include your name and address, as well as more sensitive personal information such as government issued identifiers and financial account information.

Find out more about:  

• How we collect and protect personal information
• How we use personal information 
• How we share personal information 
• How we protect personal information
• Your privacy rights and how to manage them

We collect personal information directly from you throughout our relationship with you. For example, we may collect personal information through paper or electronic applications and other forms filled out by yourself or someone you’ve authorized, on the telephone, through email or through cookies on our website. For more information about our use of cookies and similar technologies, please see our Cookie Policy.

We may also collect your information from third parties such as our stock transfer agent, our affiliates, our subsidiaries, our service providers and other third parties.

We’ll only collect the information we need

When we collect personal information from you, we'll tell you why we need it. We’ll only collect personal information where necessary and for the purposes identified.

Types of personal information we collect

Depending on the product, service or relationship, we may collect the following types of personal information. We’ve included some categories and examples of the personal information we collect:

• Identification information – such as name, address, telephone number, email address, date of birth, social insurance number (SIN), Social Security Number or other Taxpayer Identification Number, information on other government issued identification, sex, citizenship, marital status
• Financial and shareholder information – such as banking information and information about your shareholdings
• Employment and professional information – such as your title and where you work, business contact information, employment history, skills, associations, professional designations  
• Use of our website – information collected through cookies, browsing preferences, IP address. See our Cookie Policy for more information.

Some of the information we collect may contain sensitive personal information about you.

Personal information may be used to:

• Verify your identity
• Communicate with you, for example responding to requests you submit using our Contact Us form, sending securityholder communications, and sending updates when you sign up to receive email alerts from us  
• Administer your securities ownership and related transactions, including paying dividends ·        
• Help us provide, analyze and optimize our business processes
• Help us make decisions, which may include the use of artificial intelligence (“AI”)
• Improve your experience by providing relevant information and updates including information about shareholder meetings and earnings calls        
• Optimize our website
• Provide personalized and interactive content. For more information on how this works, refer to our Cookie Policy.
• Evaluate, prepare for, complete or otherwise facilitate a business reorganization, merger, acquisition, sale or restructuring that we, our subsidiaries or affiliates decide to enter into
• Keep records, including using your SIN for tax reporting
• Meet our legal obligations, such as:
  • to prevent criminal activity, fraud, misrepresentation, or cyber crime
  • responding to requests to provide your information to law enforcement, courts, and/or other authorities inside and outside of Canada
  • complying with tax requirements

Using your personal information for data analysis and analytics

We may use data analysis and analytics technologies, such as artificial intelligence (AI) to improve our business operations and offerings. For example, these technologies help us identify and automate repetitive tasks, optimize how we manage our workflow, personalize our communications, and protect our business from fraud and financial crime. 

The use of these technologies involves large amounts of information, including personal information. When we use your personal information for this purpose, wherever possible we remove parts of your information, such as your contact information, so you can’t be identified. We’ll always handle your personal information in a respectful manner.

We only share your information with those who need it to administer your ownership of our securities and related transactions and to provide you with information on services you already have, that you’ve requested, or that may be available to you. We may also share your information to others with your consent or as otherwise allowed.

We may share personal information with our service providers, which can include:

• Stock transfer agents including Computershare
• Technology suppliers
• Legal services
• Print and mail services
• Record storage companies
• Event platform and service providers

We may also share personal information with:

• Your authorized agents
• Insurance or reinsurance companies
• Financial institutions
• Government departments and agencies
• Buyers or other interested parties regarding the sale of our business assets in connection with a merger, acquisition, sale, restructuring or similar transaction
• Emergency services providers to protect the health and safety of individuals
• Law enforcement, regulators, courts, and/or other authorities inside and outside of Canada to comply with applicable laws, prevent or address criminal activity, fraud, misrepresentation or cyber crime
• Other organizations as required or authorized by law

Personal information may be shared outside your province of residence or outside Canada as part of day-to-day business, in which case your information may be subject to the law of the other jurisdiction, including any law permitting or requiring disclosure of the information to government agencies, courts and law enforcement in that jurisdiction.

Protecting personal information

Great-West Lifeco maintains safeguards to protect personal information. We’ve implemented measures to protect personal information that are appropriate based on the sensitivity of the information.

Great-West Lifeco limits access to personal information to:

• Employees of Great-West Lifeco and its subsidiaries and affiliates or authorized contractors who need access to your information to do their jobs
• Other people you have authorized (examples include a power of attorney or other personal representative or agent)
• Service providers

All employees and contractors are provided information security, privacy, and code of conduct training reinforcing the importance of protecting personal information.

Accountability for protecting personal information

We take protecting personal information seriously. We have technical and organizational safeguards to protect personal information against
loss and unauthorized access, use or disclosure.

Everyone who works at Great-West Lifeco, as well as people and companies that act on our behalf, are responsible for protecting personal information.

Our Chief Privacy Officer monitors compliance with this Policy.

How our service providers protect personal information

Service providers can only collect, use or share personal information for purposes we allow.

We make sure our service providers act in a way that’s consistent with this Policy and applicable laws. They must contractually agree to comply with reasonable standards for the protection and confidentiality of personal information, which includes protecting their systems against unauthorized access and applying security standards that meet or exceed our own standards.

How long your information will be kept

We’ll only keep your information for as long as we need it, or for as long as is required by our policies and/or applicable laws. Where appropriate, we may anonymize personal information to protect it and to minimize the amount of personal information we retain.

When it comes to your personal information at Great-West Lifeco, you have the following rights:

• The right to access your personal information 
• The right to correct your personal information if it’s inaccurate or incomplete
• The right to delete your personal information
• The right to change your consent options
• The right to ask us about our privacy practices
• The right to ask about any decision we made using automated processing. This includes being able to submit observations about the decision-making process to us.
• The right to have your personal information transferred to you.

You can exercise your privacy rights by writing to Great-West Lifeco or submitting our Contact Us form as outlined at the bottom of this Policy. You can also withdraw or change your consent to receive emails by unsubscribing from messages you receive from Great-West Lifeco.

We’ll respond to your privacy rights request within the required timeframe. If we need more time, we’ll let you know. There may be instances where we’re unable to fulfill your privacy request, subject to certain restrictions or laws. If this happens, we’ll let you know as soon as possible.

If you choose to remove your consent, there may be situations where we’re not able to provide you with certain services you have requested. In certain situations, we may still retain your personal information in order to comply with our legal or regulatory obligations, to establish, exercise or defend our rights or legal claims, and for other legitimate purposes.

Please note that even if you have indicated your choice not to receive certain information and updates, you’ll continue to receive information about your securities. You may also see information and offers about other products and services on our website.