Ekaton Wealth Management Inc. (hereinafter referred to as 'Ekaton') is fully aware of the responsibilities it has under the Personal Information Protection and Electronic Documents Act (hereinafter referred to as 'PIPEDA') when handling personal information during the course if its business activities. This privacy policy is designed to inform clients and employees (collectively referred to as 'Persons') when and how Ekaton will collect, use and disclose their personal information.

The policy is designed to address any Persons concerns or practices relating to the 10 principles referred to in PIPEDA. This policy is intended to be generic, and may not cover all possible circumstances for collection, use and disclosure. Unusual cases of information collection, use and disclosure will be addressed on a case by case basis, with all relevant parties being informed, should such a situation arise.

1. Accountability

Ekaton will be responsible for personal information in its possession, including information that has been transferred to a third party for processing.

Ekaton has appointed a Privacy Officer to oversee PIPEDA compliance when collecting, using and disclosing personal information. This officer will be accessible both within the organization and to clients to address all issues relating to privacy and information disclosure policies. Any individual who wishes to challenge Ekaton's personal information handling procedures should contact the Privacy Officer at 519-964-0100 or by email at peter@ekaton.ca. Every complaint will be investigated and where a complaint is found to be justified, Ekaton will take appropriate measures, including amending our policies and procedures, when necessary.

2. Identifying purposes

Ekaton will identify and document its purposes before collecting and using Persons personal information. We will not use or disclose this information for any other purpose other than those for which it was collected.

Ekaton may collect, use and/or disclose personal information about the Persons from time to time. For example, Ekaton may collect information about the Persons such as their name, mailing address, telephone number, e-mail address, when they register to become a client or start their employment at Ekaton.

Personal information collected by Ekaton is used for one or more of the following purposes:

• To verify identity;
• in order to operate the persons account;
• To provide the persons with information respecting Ekaton's services; to improve our services;
• To properly discharge Ekaton's regulatory responsibilities with respect to suitability assessment and other securities rules;
• To properly discharge Ekaton's obligations under federal anti-money laundering and suppression of terrorism legislation;
• To administer payroll and conduct various other administrative duties associated with being an employee of Ekaton.

Any time Ekaton collects personal information from the Persons, it will notify the Persons of the specific purposes for such collection, at or before the time of collection, and obtain the appropriate consent from the Persons.

3. Consent

Generally, the Persons knowledge and consent are required to collect, use or disclose personal information. Exceptions to this principle are provided for in PIPEDA and other relevant regulations and legislation.

By submitting personal information to Ekaton, the Persons agree that Ekaton may collect, use and disclose such personal information as described in, and in accordance with this Policy and as permitted or required by law.

Persons may refuse or withdraw their consent to certain of the identified purposes in this Policy by contacting Ekaton's Privacy Officer. If the Persons refuse or withdraw their consent to certain purposes, we may not be able to establish or maintain a relationship with the Persons or provide the Persons with services or information that may be of value to the Persons, especially if this information is required by the Ontario Securities Commission or other regulatory bodies.

4. Limiting collection

Ekaton will only collect personal information that is required to meet identified purposes. Ekaton will only use fair and lawful means, as stated within our policies and procedures in order to collect this information.

Ekaton will limit the personal information collected from the Persons to that information absolutely necessary to conduct business in compliance with necessary regulations and laws, to contact you in an efficient manner, operate and improve services provided to clients. Unnecessary information will not be collected, used, disclosed or retained.

5. Limiting use, disclosure, and retention

Ekaton will only use or disclose personal information for purposes identified to the individual, unless further consent is obtained. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.

Disclosure of your information will only occur in accordance with your consent or by legal duty. Your consent will be obtained at time of collection, or in advance of any new uses that may arise.

6. Accuracy

You are entitled to have complete and accurate information on file with Ekaton. You may verify your personal information and if necessary, request in writing, an amendment to your personal information, by contacting the Privacy Officer.

7. Safeguards

Ekaton holds the security of your information in the highest regard. Ekaton and the Privacy Officer will implement policies and procedures to ensure security of all forms of documents and information relevant to client privacy. Ekaton will guard against loss and theft, as well as unauthorized access, disclosure, copying, use and modification, regardless of the format in which it is held. Level of safeguards will be appropriate to the degree of sensitivity of any information collected.

Security measures will encompass physical, technological and organizational security. Security measures include but are not limited to; policies and procedure for access, use and disclosure by employees; electronic security software and hardware or digital files; properly secured paper files; alarm systems.

8. Openness

Ekaton and the Privacy Officer will be open and transparent with the collection, use and disclosure of your information. All relevant policies will be easily accessible and understandable. In the event of a breach of privacy, you are entitled to know:

• If and how you have been affected;
• What was the date of the incident?
• When was the incident discovered?
• How was it discovered?
• What was the location of the incident?
• What was the cause of the incident?

9. Individual access

Clients may request, in writing, to access their personal information. All requests relating to individual access can be referred to the Privacy Officer.

You have the right to know if Ekaton has any information about you. You have the right to access this information. Ekaton will inform the client whether the organization holds personal information and provide an account of the use that has been made of this information, as well as identify any third parties to which the information has been disclosed. The client has the right to have their personal information corrected if they demonstrate the inaccuracy or incompleteness of their personal information.

10. Challenging compliance

The client has the right to challenge Ekaton's compliance with any aspect of PIPEDA. Compliance challenges can be referred to the Privacy Officer, who can be contacted at 519-673-2854 or at peter@ekaton.ca, or to the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.