PLEASE READ THIS PRIVACY STATEMENT CAREFULLY.

This Privacy Statement sets out how Marrelli Trust Company Limited and its affiliates collect, use, disclose, and otherwise manage personal information.

Personal Information

Personal Information is information that identifies an individual personally or is associated with an identifiable individual. Personal information may include name, address, home telephone number, marital status, assets, liabilities, income, and other information of a personal nature relating to race, religious beliefs, political opinions, and affiliations.

Collection and Use of Personal Information

MTCL may collect personal information in connection with your security holdings in a client company. This information may include your name, contact information, social insurance number, date of birth, identification information, banking or financial information, and security holder information (such as how you hold your security position and if there are any conditions on your holdings). We use this information to identify you, maintain the shareholder registers or other records of our client companies, pay dividends, interest or other distributions, and complete corporate mailings so that our client companies can fulfill their corporate and regulatory duties and obligations.

The Marrelli Group is responsible for the personal information that is collected and retained. To ensure this accountability, we have developed this policy and trained our employees about our policies and practices.

What Personal Information We Collect

Under Canadian privacy legislation, “personal information” is generally defined as information about an identifiable individual, or information that allows an individual to be identified.

We may also use this information to fulfill contractual obligations that we may be engaged from time to time to perform and to meet applicable securities regulations and other legal requirements.

We may also receive personal information from our client companies or brokers, which we use to provide various compliance and other services on their behalf. We may also collect personal information in connection with these services. For example, we may collect your personal information if you call a whistleblowing number that we host for one of our client companies.

MTCL may collect personal information when you contact us with a question, comment or request, for example, to change your address, transfer shares, or replace a dividend cheque. You may be asked for information that identifies you (such as your name, address, and phone number) along with additional information we need to help us promptly answer your question or process your request (such as your security holder information).

How Do We Collect Personal Information?

We may obtain personal information directly from you, your broker, lawyer, employer, credit bureaus, financial institutions with which you have a relationship, a client company, or as otherwise permitted by law.

Consent

We collect, use, and disclose personal information with the permission of the individual to whom such personal information relates, except in certain limited circumstances defined by privacy laws. For instance, by becoming a security holder of a company served by MTCL you consent to the collection, use, and disclosure of your personal information to maintain the security holder registers of the company and to otherwise meet applicable securities regulations and other legal requirements.

Disclosure of Personal Information

We will only disclose an individual’s personal information with the individual’s consent, or where MTCL is legally required or permitted by law. Given the type of service we provide to our client companies, MTCL will be required to provide, in the ordinary course of business, personal information about security holders to the client company, their counsel and to third parties in accordance with securities and corporate law and regulations.

Service Providers:

We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf. Your personal information may be maintained and processed by our third-party service providers in other countries, and your personal information may be subject to the laws of that jurisdiction. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for any other purposes.

Sale of Business:

We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of MTCL or as part of a corporate reorganization or other change in corporate control.

Legal:

MTCL may be required to disclose information to government regulatory authorities or self-regulatory organizations, in accordance with applicable securities or other laws. MTCL and our service providers may also be required to provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by applicable Canadian, the US or other law. We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims or as otherwise permitted by law.

Retention of Personal Information

MTCL will only retain an individual’s personal information for as long as is reasonably necessary to fulfill the purposes for which it is collected or is required by law.

Accessing Your Personal Information

An individual has the right to access, update, and correct inaccuracies in his or her personal information subject to legal restrictions. To protect your privacy, we will take reasonable steps to help verify your identity before providing you with access to your personal information.

Information About our Website

Our Site gathers information about visitors that is not personally identifiable. This information includes the type of Internet browser and operating system you are using, IP (Internet Protocol) addresses, and other related information such as page requests and average time spent on our website. Please note the information will only be gathered while a visitor is on the Site. No information is gathered about other third party sites the visitor has accessed. The information collected is analyzed to help us understand trends and patterns and to improve the content, design, and user experience of our Site.

In individual sections of the Site, MTCL may invite you to contact us, request information, or complete a registration form. In these cases, we request contact and other related information. If you chose to provide this information, we would use it only to contact you as required, or to register you to access individual sections of our website or for specified events.

Cookies:

Our website uses “cookies.” A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. You may set your web browser to notify you when you receive a cookie. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features of our site.

Tracer Tags & Web Beacons:

Some areas of the website may also use “web beacon” technologies. Web beacons work in conjunction with cookies and let us know what portions of our Site are of interest to our visitors and to help us provide you with tailored information from our website. If you turn off cookies, web beacon technologies will still detect anonymous visits, but the notices they generate cannot be associated with other information that is collected and is disregarded.

Third-party links:

Our website may contain links to other websites that MTCL does not own or operate. Also, links to our website may be featured on third party websites on which we advertise. Except as described in this Privacy Statement, we will not provide any of your personal information to these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement or referral to the linked sites. The linked websites have separate and independent privacy statements, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility.

Customer Testimonials/Case Studies/Reviews

We post customer testimonials/comments/reviews on our website, which may contain information about the customer. We obtain each customer’s consent via email before posting the customer name and testimonial.

Privacy Officer

If you have any concerns about personal information maintained by MTCL or if you wish to access, correct or update your personal information, please direct your query to:

Harvey Tan
htan@marrellisupport.ca

Marrelli Trust Company Limited
The Canadian Venture Building
82 Richmond Street East, 1st floor
Toronto, Ontario M5C 1P1
Canada

Legal Disclaimer

Emails from MTCL and affiliates are confidential, may be privileged and are intended for the exclusive use of the addressee(s). Any other person is strictly prohibited from disclosing, distributing, or reproducing them. If the addressee cannot be reached or is unknown to you, please tell the sender immediately by return e-mail, delete the e-mail and destroy all copies of the email and any attachments. The views expressed in emails are not necessarily those of MTCL and its affiliates. Emails are also subject to copyright and must not be reproduced or adapted without the consent of the owner.