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PRIVACY POLICY

INTRODUCTION

At MAVENSMOOR (the "Firm", "we", or "us"), your privacy is important to us. We are committed to protecting your personal information and maintaining your trust. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

By working with us, visiting our website, or providing personal information, you agree to the practices described in this policy.

WHAT IS PERSONAL INFORMATION?

Personal information means information about an identifiable individual. This may include:

  • Your name, address, and contact details
  • Date of birth and Social Insurance Number (SIN)
  • Financial and investment information
  • Employment and income details
  • Investment preferences and risk tolerance

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information directly from you when you:

  • Open or maintain an account with us
  • Provide documents or forms for regulatory compliance
  • Contact us by phone, email, or through our website
  • Participate in surveys or subscribe to newsletters

We may also collect personal information from third-party sources, including financial institutions, credit agencies, or background check providers, with your consent.

Additionally, we may collect non-identifiable technical data (e.g., browser type, IP address) from your use of our website to improve functionality and user experience.

WHY WE COLLECT AND USE YOUR INFORMATION

We use your personal information to:

  • Open, manage, and service your investment account
  • Comply with legal and regulatory obligations (e.g., OSC, CRA)
  • Communicate with you about account activity or services
  • Prevent fraud and manage operational risks
  • Conduct limited marketing, with your consent

You may opt out of marketing communications at any time.

WHEN WE MAY SHARE YOUR INFORMATION

We may share your personal information in the following cases:

  • With service providers (e.g., custodians, auditors) under confidentiality obligation
  • With professional advisors such as legal counsel or consultants, where necessary and bound by confidentiality
  • With regulators such as the Ontario Securities Commission (OSC) and Canadian Investment Regulatory Organization (CIRO), as required by law
  • To comply with legal requests or enforce our rights
  • During a business transaction such as a merger or acquisition

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

HOW WE SAFEGUARD YOUR INFORMATION

We implement reasonable physical, technological, and organizational safeguards to protect your personal information, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication procedures
  • Restriction of access on a "need-to-know" basis for authorized personnel only
  • Ongoing monitoring and security assessments

While no system can guarantee absolute security, we continuously evaluate and enhance our safeguards.

HOW LONG WE KEEP YOUR INFORMATION

We retain personal information only as long as necessary to fulfill legal, regulatory, and operational requirements. For example, we follow applicable retention periods under OSC, CRA, and anti-money laundering legislation. Once no longer required, personal information is securely destroyed or anonymized.

ACCESSING OR CORRECTING YOUR INFORMATION

You may request access to your personal information and ask for corrections if it is inaccurate or incomplete. Please contact us using the details below. We will respond in accordance with applicable laws.

WEBSITE TRACKING AND COOKIES

Our website may use cookies and tracking technologies to improve website performance and understand user behavior. You may adjust your browser settings to manage or disable cookies, though some features may not function properly without them.

CONSENT

By using our services or providing personal information, you consent to the collection, use, and disclosure practices outlined in this policy. Where required by law, we will obtain express consent. In some cases, implied consent may be appropriate. You may withdraw your consent at any time, subject to legal and contractual obligations.

CROSS-BORDER DATA TRANSFERS

Some of our service providers may store or process data outside of Canada. Data will only be transferred or stored outside of Canada if absolutely necessary to support critical operations (e.g., secure cloud storage, technology platforms). In such cases, we ensure that your personal information receives comparable levels of protection in accordance with Canadian privacy laws and regulatory expectations.

ACCESS TO FULL PRIVACY POLICY

This client-facing summary is intended to provide a clear overview of how we handle personal information. Upon request, you may obtain a copy of MAVENSMOOR Inc.'s full Privacy and Confidentiality Policy, which outlines our internal governance framework and detailed privacy controls.

POLICY UPDATES

We may update this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory developments, or operational needs. Any updates will be posted on our website with a revised "Last Updated" date.

If we make material changes that affect how your personal information is handled, we will notify you directly using appropriate means (e.g., email or written communication), where required by law or where appropriate based on the nature of the change.

CONTACT US

If you have any questions about your privacy or this policy, or if you wish to access or correct your personal information, please contact us at:

MAVENSMOOR Inc.

Email: compliance@mavensmoor.com

Phone: (888) 841-5536

THE LEDGER