Introduction and Intent

This Privacy and Data Policy describes how Hoovest Financial Inc. (“HFI“) collect, use, store, and disclose your personal information when you work with or interact with HFI.

Collecting information

In order to provide our services to you, we may ask you to provide certain personal information. This this Privacy and Data Policy, we refer to any information that can uniquely identify an individual as “Personal Information”. We list examples of personal information and why we collect it below. Personal Information is collected from yourself or an authorized individual with expressed consent such as a close family member.

Personal Information

Examples of Personal Information are personal contact information, employment information, financial and banking information, investment statements, tax returns, debt statements, copies of wills, powers of attorney, insurance policies, employment benefits, retirement benefits, legal documents and information regarding your investment knowledge, objectives, strategies, needs and values.

Uses of information

We request this information to provide our services to you, keep you up to date on services, to comply with applicable securities and other laws, to verify your identity, to protect against fraud, and as otherwise stated to carry on provision of agreed services to you or authorized by law.

Consent to give information

By engaging us to provide investment management services to you or submitting information to us in connection with our services, you are indicating your consent to our collection, use and disclosure of your personal information in the manner described below. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to us, but then you or we might not be able to proceed with intended interactions or transactions or otherwise receive the full benefit of our services. Consent can be implied or direct.

Our disclosure of your personal information

We may disclose your personal information in the following limited circumstances:

(a) Disclosure to agents and service providers. We may provide your personal information to our agents and service providers, such as the financial institution that holds your investment assets in custody, but only where it is reasonably necessary to do so in connection with the provision of our services.

(b) Disclosure required or authorized by law, etc. We may disclose your personal information

(i) to a government institution that has asserted its lawful authority to obtain the information,

(ii) where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity,

(iii) to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information,

(iv) to comply with court rules regarding the production of records and information, (v) to our legal counsel, or

(vi) as otherwise required or authorized by law.

Retention

Your Personal Information will be retained as long as HFI provides services to you or you ask us to destroy or erase your Personal Information.

Storage of data

Your Personal Information may be stored and processed in any country where we have affiliates or service providers. By using our products or services, you consent to the transfer of information to countries outside of Canada — including the United States — which may provide different data protection rules. Our service providers and other third parties with whom we share information may perform activities outside of Canada. As a result, your information may be used, stored or accessed in other countries and be subject to the laws and regulations of those jurisdictions or countries, such that those countries’ governments, courts, or law enforcement agencies may access your personal information. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries.

We currently employ the cloud services of Amazon, Docusign, Adobe, Salesforce, Hubspot, Daylite CRM, Microsoft, and Google, which store data outside of Canada.

Changes

We may update this Privacy and Data Policy from time to time in order to reflect changes to our practices or for other legal or regulatory reasons.

Interpretation of this Privacy and Data Policy

Any interpretation associated with this Privacy and Data Policy will be made by compliance. This Privacy and Data Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including’ without limitation.

This Privacy and Data Policy does not create or confer upon any individual any rights, or impose upon HFI any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual’s personal information. Should there be, in a specific case, any inconsistency between this Privacy and Data Policy and such privacy laws, this Privacy and Data Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.