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Privacy Policy

Our investors' privacy is very important to us. Tonus Capital Inc. ('TCI') is committed to protecting your privacy and keeping your personal information confidential. We are pleased to provide you with our Privacy Policy, which describes how we collect, hold, use and, when needed, disclose your personal information when we do business with you.

TCI complies with the requirements of Part 1 and Schedule 1 of Canada's Personal Information Protection and Electronic Documents Act ('PIPEDA') and similar provincial privacy legislation.

What is personal information?

Personal information is any information about you as an identifiable individual, including information with respect to your name, address, telephone number, social insurance number, birth date and account holdings, and the name, address and social insurance number of your spouse and beneficiary.

Using your Social Insurance Number

TCI is required by law to use your social insurance number when submitting tax reports to the Canada Revenue Agency. TCI may also disclose your social insurance number to third parties engaged to provide income tax reports.

Privacy on the internet

We recommend that you do not send us sensitive or confidential information by ordinary email, as unencrypted email is generally not secure. We are equally concerned about your privacy on the internet; this Privacy Policy applies in its entirety to anything you might do while visiting our web site.

How we collect your personal information

We collect and store your personal information when you open an account with us. We collect your personal information directly from you. Your personal information may be collected from the subscription agreement, account application or any other form that you submit to us, contracts you enter into with us, your transactions with us, or meetings and telephone conversations with you.

When you complete the account application form, you are providing personal information to TCI, including, where applicable, personal information concerning your spouse and beneficiary, in order to perform an investment transaction. TCI collects this personal information, holds it in your client file, uses it and, when needed, discloses it for the purposes identified in this Privacy Policy.

Why we ask you for your personal information

We ask you for your personal information to establish and serve you as our client. Personal information obtained from you will be used by TCI to protect and administer your account, to comply with certain laws, regulations and regulatory policies and to help TCI improve services offered to you.

In addition, we may use your personal information for executing your transactions, verifying and correcting your personal information and providing you with confirmations, tax receipts, proxy mailings and financial statements in order to service and administer your account.

The information we request is in most cases required by law or by the policies of the regulatory authorities to which we are subject. We will limit the personal information we collect to what we need for those purposes for which it is intended, and we will use it only for those specific purposes.

Third Party

We may provide your personal information to other persons, only to the extent that we have your consent or when we are required or permitted to do so by law.

TCI may transfer your personal information for the purposes identified in this Privacy Policy to our service providers, such as account statement preparation companies, courier companies and document storage companies. When TCI transfers personal information to our service providers, we ensure by contractual means that the personal information transferred is used only for the purposes for which the service provider is retained.

TCI may disclose your personal information to third parties where required by law, such as disclosure for tax purposes to the securities commissions and the Canada Revenue Agency.

Your Privacy

If you wish to withdraw your consent to permit TCI the authority to disclose your personal information, please contact us. We will explain your options of refusing or withdrawing your consent to the collection, use and disclosure of your personal information, and we will record and respect your choices.

Your decision to withdraw your consent to permit TCI the authority to disclose your personal information may prevent TCI from providing services to you, as the disclosure of your personal information to third parties is an integral component of the services that TCI makes available to you.

How do we safeguard personal information?

We will protect your personal information with appropriate safeguards and security measures. We will store your personal information only for the time it is required and for the purposes it is intended, or as otherwise required by law. We adopt security standards to protect our systems and your personal information in accordance with Canadian privacy legislation. Such securities measures include passwords to restrict access to our office records and restricted physical access to prevent theft or misuse. We carefully safeguard your personal information against any unauthorized access. We limit access to your personal information to only those employees and/or other authorized persons who need to know the information to enable us to provide services to you.

All TCI employees are familiar with the procedures that must be taken to safeguard client information. For TCI, protecting the confidentiality of your personal information is part of our job. TCI employees are responsible for ensuring the confidentiality of all personal information to which they have access. Each year, every TCI employees is required to sign a code of conduct that contains policies and procedures to follow with regard to the protection of personal information.

Where is your personal information kept?

Your personal information may be kept in electronic or paper format in TCI's office. Your personal information may also be stored at a secure offsite storage facility, or transferred to other locations for disaster recovery purposes.

Your right to access your personal information

We will provide you access to your stored personal information. Under Canada's Personal Information Protection and Electronic Documents Act and similar provincial privacy legislation, you are entitled to access, through a formal written request, the personal information contained in your client file. We will ask you for specific details, such as your account number. We will respond to your written request within 30 days.

Please contact the Privacy Compliance Officer, Tonus Capital Inc., 1501 McGill College Avenue, Suite 2090, Montreal, Québec, H3A 3M8.

Keeping your information accurate

We will make every reasonable effort to keep your personal information accurate and up-to-date. Accurate, up-to-date information about you enables us to provide you with the best possible service. You can help by keeping us informed of any changes, such as a change of address or a change in telephone number. If you find any errors in our information about you, let us know and we will make the corrections as soon as practicable in order that we may convey the updated information to anyone we may have misinformed. TCI appreciates your business and promises to handle your questions and input regarding your personal information in a prompt and courteous manner.

Your concerns matter to us

Your comments and concerns are important to TCI. If you have any questions or concerns about privacy and confidentiality, or any other concerns about the way a request for information was handled, please contact our Privacy Compliance Officer directly in writing at Tonus Capital Inc., 1501 McGill College Avenue, Suite 2090, Montreal, Québec, H3A 3M8.

If after contacting our Privacy Officer your question or concern has not been resolved, you may contact the Office of the Privacy Commissioner of Canada or the office of your provincial privacy commissioner if you are a resident of Québec.

Office of the Privacy Commissioner of Canada

Commission d'accès à l'information du Québec