Personal Information Policy and Legal Notice

At Acumen Capital Finance Partners Limited (“Acumen”), we respect your privacy and the confidentiality of your personal information. We are committed to keeping the personal information you share with confidential. The use of such information will only be for the purpose for which it was collected. This Personal Information Policy explains how Acumen and its affiliated companies collect, use, disclose and protect the personal information we obtain. References to “Acumen” are to the corporate entity Acumen Capital Finance Partners Limited and include its subsidiary Acumen Estate and Insurance Advisory Ltd., depending upon the context.

We may amend our Personal Information Policy from time to time to accommodate changes in our services, technology or as a result of a legal development. We encourage you to check back and review our Personal Information Policy periodically. Each time you submit personal information or use our services, you agree to be bound by the current terms of our Personal Information Policy.

Important Principles For Your Protection

Our Personal Information Policy applies to individuals and consists of the following key principles:

Collecting and Using Personal Information – Either before or when we collect personal information about you, we will explain how we intend to use it. We will limit the personal information we collect to what we need for those purposes, and we will use it only for those purposes. We will obtain your consent if we wish to use your personal information for any other purpose or before collecting personal information from, or providing personal information to, parties not affiliated with Acumen.
Disclosing Personal Information – We may provide your personal information to other persons, but only as disclosed herein, where we have your consent, or where we are required or permitted to do so by law.
Protecting Personal Information – We will protect the personal information we obtain about you with appropriate safeguards and security measures. We will retain your personal information only for the time it is required for the purposes we explain or as otherwise required by law.
Access to and Accuracy of Your Personal Information – We will give you access to the personal information we retain about you. We will make every reasonable effort to keep your personal information accurate and up-to-date.
Accountability and Openness to Your Privacy Concerns – We will explain your options of refusing or withdrawing consent to the collection, use and release of your personal information, and we will record and respect your choices. We will investigate and respond to your concerns about any aspect of our handling of your personal information.

Why We Ask for Your Personal Information

We ask you for information to establish and serve you as our client. Personal information obtained from you will be used by Acumen to protect and administer your accounts, records and funds; to comply with certain laws, regulations and regulatory policies; to help Acumen improve products and services offered to you; and to understand your financial needs. The information we ask for depends on the products or services you request and in most cases are required by law or the policies of the regulatory organizations to which we are subject. Your social insurance number, for example, is required for products that earn investment income, in order to comply with the Canada Revenue Agency’s income reporting requirements. Health information may, for example, be required for some insurance products to ensure you are eligible for coverage.

With your consent, we may share your personal information, where not prohibited by law, within the Acumen group of companies for the purposes of referring life insurance, disability insurance, annuities and other specific insurance products or estate planning and services to you. Sharing such information will help us serve you better and determine whether any products or services we provide through our affiliated companies are suitable for you. Sharing your personal information also helps us determine your financial needs because it allows us to review what products of Acumen you have and how you use them. Please note, however, that we will not share health information that may have been provided in connection with any insurance product for other purposes. With your consent, we may use certain information to provide you with information about Acumen and its products and services. This consent is optional, and you can decide to withdraw it at any time. Please refer to the Understanding Your Options section.

We only collect the information we need and only use it for the purposes explained to you. When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your personal information. If we wish in the future to use it for another purpose, we will ask you for your consent at that time. We will only ask for the information we need for that particular product or service. We will indicate clearly which information would help us to serve you but is optional for you to provide.

How We Collect Personal Information About You

We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties. Obtaining additional personal information about you from parties outside of Acumen helps us assess your eligibility for our products and services. For credit or margin purposes, for example, we may need to know your creditworthiness. We may contact references you have provided or credit reporting agencies to verify information that you have given us or to give us information on your credit history. We will not do this without your consent, but please remember that if you do not give your consent we may not be able to provide the particular product or service you have requested.

When We Release Your Personal Information

Under no circumstances do we sell client lists or personal information to others. We release your personal information to parties outside Acumen only under the following circumstances:

With Your Consent – We will disclose your personal information with your prior consent.
Trusted Contact Person (TCP) – If you have designated a person as your TCP, we will disclose such personal information as we deem necessary using our best subjective judgment.
To Facilitate Trading in Securities – We give a limited amount of information, only as necessary, to our service providers and agents such as our data processing agent or securities clearing agent, for the purposes of facilitating transactions in your account.
When Required or Permitted by Law – In certain circumstances, the law may require or permit Acumen to disclose your personal information without your knowledge or specific consent. For example, such information may be disclosed if required to comply with a subpoena, warrant, or court order, or if requested by a government institution which has the lawful authority to obtain the information.
For Regulatory Purposes – From time to time we may disclose your personal information to securities regulatory and oversight organizations to which Acumen is subject, such as the Investment Industry Regulatory Organization of Canada for the purposes of an audit or investigation relating to your relationship with Acumen or Acumen’s business generally.
Protection of Public Interest – We may disclose information to the authorities to serve a clear public interest and fulfill our public duty – such as to protect against fraud, money laundering or other criminal activity.

In exceptional circumstances it may be necessary that we disclose your personally identifiable information if we believe, in good faith, that disclosure is otherwise necessary or advisable to protect Acumen’s interests. We will seek to ensure that any proposed disclosure is required in the circumstances and then ensure that we disclose only the information that is required.

Understanding Your Options

We will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record and respect your choices. In many cases, you are free to refuse or withdraw your consent at any time. You may do so by contacting your advisor or by contacting the Acumen Privacy Officer at Suite 800, 500 4^th Ave SW Calgary, AB T2P 2V6. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent and record your options. With few exceptions, you can change your options at any time.

How We Protect Your Information

Acumen uses third party providers of information technology and data processing services that may store and/or process your personal information inside or outside of Canada. Your personal information may be disclosed in response to valid demands or requests from government agencies under applicable law in those jurisdictions.

We will protect your personal information with appropriate safeguards and security measures. We have security standards to protect our systems and your personal information against unauthorized access and use. We use our best efforts to ensure our suppliers and agents, as part of their contracts with Acumen, are bound to maintain your confidentiality and may not use the information they obtain for any unauthorized purpose. When we provide information in response to a legal inquiry or order, we ensure that the order is valid, and we disclose only the information that is legally required.

All employees of Acumen are familiar with the procedures that must be taken to safeguard client information. And to us, protecting the confidentiality of your personal information is part of our jobs. We review our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate.

We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed or required, we have procedures to destroy, delete, erase or convert it to an anonymous form.

Your Right to Access Your Information

We will give you access to the information we have about you. Most of this information is in the form of your transaction records which can be obtained by contacting an Acumen Privacy Officer in writing at our head office address: Suite 800, 500 4^th Ave SW Calgary, AB T2P 2V6. If you require other information, simply contact your advisor that handles your account. We will advise you in advance if a charge will be required for conducting the search, and we will respond to your request promptly but in any case, within 30 days.

Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Acumen or cannot be disclosed for other legal reasons. If you have any questions regarding decisions made, we will tell you the reasons for those decisions. Also, we do not ordinarily maintain disclosure records for regular or routine actions, updating of credit information, if required, or account balance deficiencies.

Keeping Your Information Accurate

We will make reasonable efforts to keep your personal information accurate and up-to-date. Having accurate information about you enables us to give you the best possible service. You can help by keeping us informed of any changes such as if you move or change telephone numbers. If you find any errors in our information about you, let us know and we will make the corrections as soon as reasonably possible.

LEGAL NOTICE

Through accessing this Web Site and pages thereof you agree to be bound by the terms and conditions set forth below. Should you, after reading this “Legal Notice”, disagree with the applicable terms please do not access the site in the future. Your use of the site and its pages constitutes implied agreement to these terms.

All products and services provided by Acumen are subject to the respective agreements and applicable terms governing their use. This site is for reference purposes only and is not intended to provide any form of advice. Please contact the appropriate Acumen professional directly before acting on any of the information on this web site.

The content of the pages of this Web Site is the property of Acumen and it is intended only for the utilization of the user. Credit should be given to Acumen for all references to materials published on this site originally.

The information contained in this Web Site is drawn from sources believed to be reliable, but the accuracy and completeness of the information is not guaranteed, nor in providing it does Acumen assume any liability. This information on this site is subject to change and Acumen assumes no obligation to update the information or advise on further developments relating to these securities. Acumen does not assume expressed or implied responsibility for any errors and/or omissions and direct/indirect loss or damage resulting therefrom. Please consult Acumen directly for complete and up-to-date information on products and services.

The information contained in the Web Site is directed only at, and any securities and financial services being offered are available only to, persons resident and located in Alberta, British Columbia, Manitoba, Ontario, Quebec, Nova Scotia and Saskatchewan and other such other jurisdictions where they may be legally offered. Nothing on this web site shall constitute an offer or solicitation to anyone in any jurisdiction where such an offer or solicitation is not authorized or to any person to whom it is unlawful to make such a solicitation. Any legal disputes regarding the site shall be settled through the governance of applicable Canadian laws.

Acumen, its affiliated companies and their respective directors, officers and employees and companies with which they are associated may, from time to time, hold the securities mentioned on this site.

Acumen makes no representations whatsoever about other web sites that you may access. Acumen does not control or endorse the information, security practices or privacy policies of any web site not belonging to Acumen. Visiting such web sites is at your own risk. No information, material or content referred to, included on or linked to or from Acumen’s web site should be considered an endorsement of any third party’s products or services.

While every effort is made to ensure that any software provided on this web site is suitable for use on a wide variety of computer systems, you should take reasonable and appropriate precautions to scan for computer viruses and ensure compatibility of the software with your specific computer system.

E-mail communications over the Internet, no matter how protected or encrypted, may not be secure and may not be confidential. Acumen is not responsible for any e-mail communication sent by you to Acumen or sent by Acumen to you from being intercepted, read or distributed to unknown persons. Any confidential information sent by you to Acumen is at your own risk.