Privacy Policy

This policy outlines how Bloom Burton Securities Inc. (“Bloom Burton”) complies with provincial and federal regulations governing clients’ information including the Privacy Act and the Personal Information Protection and Electronic Act (PIPEDA).

PIPEDA is the Canadian federal privacy legislation established in January 2004. Under PIPEDA no business may collect, use or disclose personal client information without clearly defining the purpose of such collection, use or disclosure and obtaining informed consent. The collection, use or disclosure is limited to purposes that a reasonable person would consider appropriate in the circumstances. The legislation further regulates the protection, retention and destruction of client information. PIPEDA offers clients the right to access their information upon request and challenge the information that is being retained.

DEFINED TERMS

“Individual” means any identifiable individual. For legal entities such as companies, partnerships, or trusts, this includes information about any authorized person, partner, or trustee, as appropriate.

“Personal Information” is any information about an Individual. Bloom Burton recognizes the sensitivity of Personal Information and ensures that it should only be collected and retained for legitimate purposes and be handled with care and respect. In providing our Services it will be necessary to collect and use Personal Information about our clients.

“Services” means any brokerage or financial product or service offered by us.

“You” and “your” means each person, whether an individual, corporation, partnership or trust, who has made application to us for or signed an application in respect of any Service offered by us, including any co-applicants, guarantors or personal or corporate representatives such as directors or officers.

COLLECTION AND USE OF PERSONAL INFORMATION

Bloom Burton is committed to respecting your privacy rights. Our Privacy Policy ensures that all of your Personal Information is handled properly with procedures in compliance with all federal and provincial requirements. To the best of our ability it will remain confidential and secure. Bloom Burton shall not collect, use, or disclose any Personal Information about any party, including you, without that Individual’s knowledge and consent, except as herein provided or as may be specifically permitted or required by applicable law.

Bloom Burton collects different types of Personal Information including but not limited to: name, contact information, financial information, and personal email. Client information may be in paper or electronic form.

Bloom Burton will collect and retain Personal Information for a number of purposes including to: determine a client's identity, provide services to clients, administer client accounts, establish and manage relationships (including conducting client evaluations and assessments), provide client communications and other commercial reasons.

The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the Individual may later consent. Bloom Burton does not sell or rent client information - under any circumstances. We do not transfer collected information to competitors.

Consent

Consent for the collection, use, and disclosure of Personal Information may be express or implied, physical or electronic, given in writing, orally, or by toggling a check-off box, or by inference from the Individual’s conduct, such

as (without limitation) by use of our website or request for services. The purpose of collection of Personal Information is for the sole purpose of providing services and in order to adequately communicate information.

Consent may be expressed in writing, orally or implied directly by the client. In most cases consent is obtained via provision of business cards, written agreement, applications, registration to events and/or by attendance. All client information collected by Bloom Burton will be kept confidential and shall not be disclosed to any third party, except for the specific reasons expressly identified or if the client has provided express consent.

Consent to use personal information may be withdrawn by a client at any time.

Personal Information Posted by the Individual

From time to time, Bloom Burton may offer interactive services which allow an Individual to share information on its website or through an online portal. These features may permit an Individual to publish Personal Information about himself or herself or about another individual, although Bloom Burton does not encourage any Individual to share any Personal Information publicly online. By submitting such information, the Individual represents:

· that the Individual consents to its collection, retention, and public disclosure by Bloom Burton in accordance with this Privacy Policy; and

· that the Individual has obtained the same consent from any other Individual whose Personal Information is being posted, as applicable.

Bloom Burton does not monitor, or moderate information submitted or posted by the users of our website and accepts no responsibility or liability for any content, including without limitation, Personal Information, posted in this way.

It is important for Bloom Burton to keep client information accurate in order to provide quality service and minimize the potential for misuse. We strive to keep client information correct, complete and up to date. Clients are requested to advise Bloom Burton of any changes to client information, as Bloom Burton is not liable for errors that cannot be corrected without client input. Should an inaccuracy be found, we will act efficiently to correct it at no cost to the client.

If an Individual believes that his or her Personal Information has been posted by a third party without consent, that Individual should contact our Chief Privacy Officer to notify us so that the complaint may be investigated, and the content removed if it is appropriate to do so.

PERSONAL ACCESS

Individuals are entitled to access and review their Personal Information held by Bloom Burton by making a request to the Privacy Officer. However, an Individual’s right to access is not absolute and may be subject to legal restrictions such as if providing access to the personal information would impede a criminal investigation or result in the disclosure of other protected information.

Bloom Burton may also deny an Individual’s request to access if granting access would have an unreasonable impact on other people’s privacy or where the requested information cannot be severed from the balance of the record in which it is contained. Access will not be provided to information that has been destroyed or is too costly to retrieve. We will make a reasonable effort to respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.

It is important for Bloom Burton to maintain accurate Personal Information about an Individual in order for us to provide efficient and effective delivery of information. Individuals may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information that Bloom Burton holds about them.

Bloom Burton will respond to requests for access in writing within 30 days of receipt. Corrections will be made within a reasonable timeframe.

DISCLOSURE

Disclosure to Agents and Third Parties

To provide our services, Bloom Burton may need to disclose Personal Information to certain third party agents or service providers, including but not limited to our carrying broker, Haywood Securities Inc. Personal Information may also be provided to Bloom Burton’s professional advisors in connection with our business operations, for example, where Bloom Burton’s undergoes a fundamental business change such as a sale, financing, merger, or a transfer of all or a portion of our business or assets. In any such case, Bloom Burton shall ensure that any such parties accessing your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information.

Bloom Burton shall not otherwise disclose Personal Information to third parties for commercial or other reasons, except as may be specifically required to comply with applicable laws. Except as may be specifically provided in this Privacy Protection Policy, Bloom Burton will obtain an Individual’s consent prior to disclosing any Personal Information or otherwise using Personal Information for purposes other than those for which it was explicitly or implicitly given.

Disclosure in Compliance with Law

Bloom Burton may also disclose Personal Information to establish or exercise our legal rights or defend against legal claims or in connection with an emergency that warrants use or disclosure of the information.

It may also be necessary for Bloom Burton to disclose Personal Information to law enforcement officials, regulatory bodies, government agencies; law enforcement agencies; securities commissions; law societies; other self-regulatory organizations (“SROs”); or under a court order. Express consent will not be required if needed for: audit, statistical or record-keeping purposes; a legal reason or request by securities or legal regulatory authorities or SRO; to collect a debt owed by the client; to a legal professional for the purposes of obtaining legal advice; and pursuant to a court order. Should Bloom Burton be asked to produce confidential information by any such entity, we will comply. In some cases, Bloom Burton may provide information on its own initiative if there are reasonable grounds to believe crime or a violation of applicable regulation is involved.

Such Personal Information includes: the client’s given name, surname, date of birth and gender; and/or, contact information including the client’s mailing address, phone number, and email address, as applicable.

Use or Disclosure for Research Purposes

In order to improve our processes and services, Bloom Burton may from time to time make use of aggregated and non-identifying information (“Aggregated Data”) for research purposes. Such purposes include, without limitation, better understanding the needs and wants of our clients and users. Bloom Burton may disclose such Aggregated Data, which will not personally identify any Individual, to our affiliates, agents, service providers and business partners for these purposes.

From time to time, Bloom Burton may request an Individual’s consent to use or disclose Personal Information for research purposes. This may include, without limitation, invitations to complete surveys or participate in studies to be conducted by Bloom Burton or a third party. Bloom Burton will not use or disclose Personal Information for such research purposes without the Individual’s express consent, which may be withheld or denied without consequence to the Individual.

RETENTION AND SECURITY

Retention Timeframes

Client information will only be used for the purposes for which it was collected. Bloom Burton may share client information with authorities for regulatory or tax reporting purposes. Information may also be shared with legal bodies, SROs and other authorities for reasons previously discussed. Client information may also be shared with external service providers or strategic partners/affiliates (upon verbal consent by the client).

Bloom Burton will not retain any Personal Information longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided or as may be required by any Federal or Provincial record keeping requirements,

whichever is longer. This may involve the retention of your Personal Information for a period exceeding your actual relationship with Bloom Burton. Once Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or rendered anonymous.

Security

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical and technical safeguards.

Threats to Personal Information include loss, misuse, theft, inadvertent disclosure, and improper modification. At all times, Bloom Burton employs reasonable physical, technical, organizational, and digital precautions to safeguard your Personal Information. Bloom Burton restricts access to Personal Information to authorized personnel who are appropriately trained to handle Personal Information.

CANADA’S ANTI-SPAM LEGISLATION (CASL)

CASL regulates commercial electronic messages, including without limitation, emails, newsletters, updates, and offers and text messages (a “CEM”). In compliance with CASL, Bloom Burton will not send CEMs without the express or implied consent of an Individual. Any Individual who wishes to revoke their consent may opt out of receiving future CEMs by following the conspicuous unsubscribe mechanism contained in each CEM in accordance with CASL or by contacting the Privacy Officer as described below. Any such opt-out will not apply to any communications that are required by law.

LINKS TO OTHER WEBSITES

Like many other websites, our website contains links to other third-party websites, which are not governed by this Privacy Policy. These links are provided for your convenience only. Please be aware that these third-party websites are governed by separate privacy policies. Bloom Burton and our affiliates are not responsible for the privacy practices of other third-party websites. We encourage you to be aware when you click these links and leave our site. Your use of these third-party links is at your own risk.

SOCIAL MEDIA

Individuals may interact with Bloom Burton through various social media platforms. Although these platforms are a unique and interactive way to communicate with all types of users, all communications on these third-party platforms are public and not subject to this Privacy Policy. As a result, Bloom Burton cannot protect the information, including Personal Information, which an Individual chooses to post on such third-party platforms. Please ensure that you read and respect the guidelines for each of these third-party platforms.

QUESTIONS OR CONCERNS

If you have any questions about our privacy policies and practices and how they relate to you, please contact our Chief Privacy Officer by telephone at (416) 640-7575, by e-mail at compliance@bloomburton.com or by mail to Bloom Burton Securities Inc., Suite 300, 65 Front St. East, Toronto, Ontario M5E 1B5, Attention: Chief Privacy Officer.

Clients who remain dissatisfied with the results can bring the complaint to the attention of the federal Privacy Commissioner who is the ombudsperson for complaints under PIPEDA at: Officer of the Privacy Commissioner at 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3, Attention: The Privacy Commissioner of Canada. The request must be made in writing and include full contact details and as much detail as possible about the complaint.

We may amend this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise. We will post the revised Privacy Policy on our website.