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Privacy Policy

Last revised on 20 June 2022
 

This Privacy Policy describes how your personal information is collected, used, and shared when you visit https://numusfinancial.com/ (the “Site”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://numusfinancial.com/

 

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.
 

Types of Data Collected

 

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • City, Country
  • Cookies and Usage Data

Usage Data

We may also collect information about how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.


Data Retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.


Tracking & Cookies Data

We use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.
Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies.

  • Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website or other websites.
  • Google’s use of advertising cookies enables it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet.
  • Users may opt out of personalized advertising by visiting Ads Settings. (Alternatively, you can direct users to opt out of a third-party vendor’s use of cookies for personalized advertising by visiting www.aboutads.info.)

If you have not opted out of third-party ad serving, the cookies of other third-party vendors or ad networks may also be used to serve ads on your site, which should also be disclosed in your privacy policy in the following manner:

  • Notify your site visitors of the third-party vendors and ad networks serving ads on your site.
  • Provide links to the appropriate vendor and ad network websites.
  • Inform your users that they may visit those websites to opt out of the use of cookies for personalized advertising (if the vendor or ad network offers this capability). Alternatively, you can direct users to opt out of some third-party vendors’ uses of cookies for personalized advertising by visiting www.aboutads.info.

Because publisher sites and laws across countries vary, we’re unable to suggest specific privacy policy language. However, you may wish to review resources such as the Network Advertising Initiative for guidance on drafting a privacy policy. For additional details regarding cookie consent notices, please refer to cookiechoices.org.

 

Advertising and Analytics

When you access and use the Services and other websites, we may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our customers) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies). If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/

We use Facebook Custom Audiences to deliver advertisements to Website Visitors on Facebook based on email addresses that we have collected. You may learn more about Facebook Custom Audiences by visiting https://www.facebook.com/help/381385302004628 , and you may learn how to opt-out of receiving advertisements from Cvent based on your email address by visiting the section below titie “Choices about How We se and Disclose your Information”. We also may use information associated with Visitor social media accounts, such as demographic and other information about an individual’s title, industry or organization, to improve our marketing efforts if that individual connects those social media accounts to a Website profile. 

We may use the information we have collected from you to enable us to display advertisements from our Customers to their target audience of users. As one example, meeting space providers may purchase advertisements which are presented selectively through the Cvent Supplier Network to meeting planners who have previously awarded a minimum volume of meetings business to that provider or to competing venues in the target metropolitan area. Even though we don not disclose Personal Information for these purposes, if any End-User clicks on or otherwise interacts with an advertisement, the advertising Customer may assume that the End-User meets its target criteria. 

Facebook Custom Audience Ads

We may display interest based-ads to you when you are using Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on your shopping experience with us. We don not share any of your personal information, including your shopping history with Facebook. The tool allows us to convert your email address to a unique number that Facebook uses to match to unique numbers Facebook generates from email addresses for users. 
I would like to opt OUT of Facebook Custom Audience ads.

Facebook Conversion Tracking Pixel

With your permission, our website utilizes the Conversion Tracking Pixel service of Facebook Inc., 1601 S.California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users afte they are redirected to a provider’s website by click on a Facebook Advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you on this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under https://www.facebook.com/about/privacy. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes. 
Only user overs 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians. 

Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/

 

You can opt out of targeted advertising by:

COMMON LINKS INCLUDE:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Use of Data

Numus Financial uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Numus Financial will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure Of Data

 

Legal Requirements
Numus Financial may disclose your Personal Data in the good faith belief that such action is necessary:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Numus Financial
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability
Security of Data
If you have any questions about this Privacy Policy, please contact us.

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

 

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purposes.

Sharing your Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. We use Google Analytics to help us understand how our visitors use the Site — you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

 

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics – Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.

 

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

All matters concerning orders between you and any third party vendor, including but not limited to loan terms, mortgage terms, purchase terms, payment terms, warranties, guarantees, maintenance, and delivery, are solely between you and the third-party vendor. thepuzzlenerds.com does not endorse, warrant, or guarantee any product or service offered through this web site or any related communications such as email or newsletter and will not be a party to or monitor any transaction between you and third-party providers of products or services.

You should always exercise appropriate caution and perform due diligence when transacting with any vendor, as you alone are responsible for your decision to transact with any third party vendor of loans, mortgages, services, or products. You will not consider thepuzzlenerds.com, nor will thepuzzlenerds.com be construed as a party to such transactions, whether or not thepuzzlenerds.com may have received some form of revenue or other remuneration in connection with the transaction. thepuzzlenerds.com will not liable for any costs or damages arising out of, either directly or indirectly, you or any other person involved or related to any transaction with a third-party vendor.

 

Children Policy

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

Code of Conduct

While using thepuzzlenerds.com you agree to comply with all applicable laws, rules, and regulations. In addition, you specifically agree not to:

  • Use the site for any unlawful purpose.
  • Transmit any content or information that is unlawful, fraudulent, abusive, libelous, defamatory, obscene, or otherwise objectionable, or infringes on our or any third party’s intellectual property or other rights.
  • Transmit any content or non-public information about companies without the authorization to do so or any trade secret of any third party.
  • Transmit any content or information such as advertisements, solicitations, chain letters, pyramid schemes, investment opportunities, or other unsolicited commercial communication except as otherwise specifically permitted by us.
  • Engage in spamming or flooding.
  • Transmit any software or other materials that contain any virus, worm, time bomb, Trojan horse, or other harmful or disruptive components.
  • Modify, adapt, sublicense, translate, sell, reverse engineer, decompile, or disassemble any portion of the site.
    Harvest or collect information about site visitors or members without their express consent.
  • Restrict or inhibit any other visitor or member from using the site, including, without limitation, by means of “hacking” or “cracking” or defacing any portion of the site.
  • Remove any copyright, trademark, or other proprietary rights notices contained in the sites.
  • Frame or mirror any part of the site without our prior written authorization
  • Use any robot, spider, site search/retrieval application, or other manual or automatic device or process to retrieve, index, data mine, or in any way reproduce or circumvent the navigational structure or presentation of the site or it’s contents.
  • Express or imply that any statements you make are endorsed by us, without our prior written consent.
    You alone are responsible for the content and the consequences of your communications. thepuzzlenerds.com reserves the right to terminate your site usage privileges immediately and without notice, if it becomes aware and determines, in its sole discretion, that you are violating any of the Terms and Conditions of Use.

numusfinancial.com reserves the right, but in no way shall we be obligated or required, to delete any inappropriate, objectionable, or offensive material from our site. We intend to fully cooperate with any law enforcement officials and/or agencies in the investigation of any person or persons who violate these Terms of Use or any law.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us.

By email: info@numusfinancial.com
By visiting this page on our website: https://numusfinancial.com/contacts/

Questions and Contact Information:

If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at this email or by mail at:
Numus Financial
[Re: Privacy Compliance Officer]
108 2261 Lakeshore Boulevard West
Etibicoke, Ontario, M8V 3X1

1 Privacy of Client Information
In addition to securities legislation, Numus is subject to federal privacy legislation, specifically the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”). Every business that carries on “commercial activities” (a term that is defined broadly and includes Numus’s business operations) is subject to the application of PIPEDA as it relates to the collection, use and disclosure of personal information (information about an identifiable individual, with the exception of the name, title, business address and business telephone number of an employee of an organization). Numus is required to comply with PIPEDA in all of its business practices that involve personal information about individuals.
2 Principles of PIPEDA
The following are the principles of fair information practices incorporated into PIPEDA.The following set of guidelines, based on the ten principles in Schedule 1 to PIPEDA, supplement Numus’s Privacy Policy.

Principle 1 – Accountability

All Personnel are responsible for Client and Investor information (and confidential information about Numus) to which they have access as a result of their relationship with Numus and for compliance with Numus’s Privacy Policy. The Privacy Officer is responsible for Numus’s compliance with PIPEDA. The CCO serves as Numus’s Privacy Officer.

All inquiries or concerns regarding the use of Client or Investor information, including information that has been transferred by Numus to a third party, must be directed to the Privacy Officer.

Principle 2 – Identifying Purposes

The purposes for which Client or Investor information is collected and used must be identified, documented and disclosed to Clients at or before the time their information is collected.

Numus is only permitted to collect, use, disclose and retain this information to the extent necessary to fulfil the purpose for which the information was collected.

Before Numus may use this Information for a purpose not previously identified to the Client or Investor, the new purpose must be identified and unless the use is required by law, consent must be obtained before the information may be used for the new purpose.

Principle 3 – Consent

Knowledge and consent of Clients and Investors is required for the collection, use and disclosure of their information. Consent under PIPEDA is only valid if it is reasonable to expect that the individual to whom the organization’s activities are directed understands the nature, purpose and consequences of the collection, use and disclosure of one’s personal information.

The consent obtained by Numus will generally be express consent, with notice of the purposes of collection and other relevant information being provided in account opening forms and subscription agreements through the Privacy Policy.

Subject to restrictions imposed by law or under a contract and reasonable notice, consent may, at any time, be withdrawn by a client and Numus must inform them where there are implications of withdrawing or refusing their consent.

PIPEDA provides certain exemptions from the consent requirements in the context of a breach of the law, fraud detection or prevention, and communications with next of kin or a government institution where the individual has been, may be or is the victim of ‘financial abuse’.

Principle 4 – Limiting Collection

As mentioned above, Client and Investor information is not to be collected indiscriminately. The amount and the type of Information collected must be limited to that which is necessary for the purpose of the collection identified by Numus.

Principle 5 – Limiting Use, Disclosure, and Retention

In general, Client Information should only be disclosed for the purpose for which it was collected, with the express consent of the Client or Investor, or as required by law. If there is any doubt, Personnel should speak to the Privacy Officer prior to disclosing the information. As mentioned, Numus may on occasion be required by law to disclose Client Information to taxation and regulatory authorities and agencies.

Client and Investor Information will be retained for seven years following the end of the relationship. After which, all documentation will be destroyed in a manner commensurate with its sensitivity unless there are legal requirements that require its retention.

Numus transfers Client and Investor information to service providers under contract to Numus that provide accounting, legal, tax preparation and like services. Numus remains responsible for such information while it is in the hands of third party service providers and protects the information (and Numus) through contractual requirements for its service providers to afford the information the same level of protection as it is given by Numus.

Principle 6 – Accuracy

Client and Investor information must be as accurate, complete, and up to date as necessary for the purposes for which it is to be used and will only be routinely updated where necessary for those purposes.

Principle 7 – Safeguards

Client and Investor information will be protected against loss, theft, unauthorized access, use, disclosure, copying, or modification by safeguards appropriate for sensitive information. The information (and confidential information of Numus) will be retained in a designated secure area or electronic database.

Personnel are individually responsible for ensuring the confidentiality, appropriate use and protection of all information to which they have access.

Principle 8 – Openness

Clients and Investors have a right to access Numus’s Privacy Policy which includes information about its management of their information, including contact information for the Privacy Officer, and the means by which they may gain access to and request the correction of his or her information being held by Numus.

Principle 9 – Individual Access

On request, a Client or Investor shall be informed of whether or not Numus is holding his or her information, the use to which it has been put by Numus and the organizations or individuals to which it has been disclosed or the type of organizations to which it may have been disclosed where more precise information is not available.

Requests for access must be made in writing and access to their own information will be provided except where doing so would likely reveal personal information about a third party that cannot be severed from the Client’s or Investor’s information. Access may also be withheld where:

  • the information is protected by solicitor-client privilege;
  • providing access would reveal confidential commercial information;
  • providing access could reasonably be expected to threaten the life or security of another individual;
  • the information was collected without consent because obtaining consent could have compromised the availability or accuracy of the information and the information is required for investigating the breach of a contract, federal or provincial law; or
  • the information was generated in the course of a formal dispute resolution process.

Numus will endeavour to respond to requests for access within 30 days unless responding in that time frame would unreasonably interfere with its business or it needs information to make a decision on access that is not available in that time frame. In such cases, Numus may extend the time for responding to an access request by 30 days or the period that is required to convert the information into an alternative format (for example, to download it onto a CD). Numus will give notice to the Client or Investor where it requires an extension and include the reasons for the extension and an advisement that they may make a complaint to the Office of the Privacy Commissioner of Canada (“OPC”) in respect of the extension. It is important for Numus to respect the timelines as a failure to respond to an access request within the time lines will be deemed to be a refusal of the request.

Numus will inform the Client or Investor in writing if it refuses his or her request for access, setting out the reasons for the refusal and the right of the Client or Investor to complain to the OPC. Information that is the subject of a complaint must be retained by Numus until the Client’s or Investor’s rights are exhausted.

Numus will process access requests. The costs of these access requests will be paid by the Client or Investor but may be waived by Numus in its sole discretion. As such, prior to proceeding with such access request, Numus will inform the Client or Investor that submits an access request of the approximate cost of the access request and will obtain approval to proceed.

Specific rules apply in regard to requests for access to information provided to government agencies for purposes including law enforcement and all such requests should be directed to the Privacy Officer.

Principle 10 – Challenging Compliance

A Client or Investor may address any concerns with respect to Numus’s compliance with the above principles or the Privacy Policy to the Privacy Officer.

Numus has procedures regarding Client or Investor complaints that Personnel must explain to Clients and Investors if concerns about Client or Investor information management are raised. The complaint process to be followed is outlined elsewhere in this Compliance Manual.

As mentioned above, Clients and Investors have the right to challenge the accuracy and completeness of their information and to have it amended as appropriate.

3 PIPEDA – Breach Reporting and Record-Keeping

Since November 1, 2018, the Breach of Security Safeguards Regulations has been enacted under PIPEDA. As of such time, in the event Numus experiences a data breach, referred to in PIPEDA as a “breach of security safeguards”, Numus will have certain specific legal obligations, including the following:

  • Numus is required to determine if the breach poses a “real risk of significant harm” to any individual whose information was involved in the breach (“affected individuals”) by conducting a risk assessment. The assessment of risk must consider the sensitivity of the information involved, and the probability that the information will be misused.
  • In the event Numus considers that a breach is posing a real risk of significant harm, it must notify affected individuals and report to the Privacy Commissioner of Canada (the Commissioner) as soon as feasible.
  • In such instance, Numus must also notify any other organization that may be able to mitigate harm to affected individuals.
  • Additionally in such instances, the firm must maintain a record of any data breach that the firm becomes aware of and provide it to the Commissioner upon request

In the event any employee suspects that Numus may have experienced a data breach (a “breach of security safeguards”) or may be vulnerable to same, the employee is required to notify the CCO. The CCO is responsible for, and unless he delegates this responsibility to an employee of Numus in a specific instance, is the only individual in the firm authorized to notify affected individuals and to file reports to the Commissioner and any other organizations. The CCO is also responsible for the record-keeping obligations referred to above. In addition to the requirements under PIPEDA and the Breach of Security Safeguards Regulations, in the event of a data breach or a potential breach of Numus’s security safeguards, the CCO will also consider what other measures should be taken by Numus and its employees in order to address potential civil liability issues and to reduce risks that any such occurrence is repeated. These measures may typically include speaking with outside counsel, IT and other industry experts, Numus’s Board of Directors, and, as may be required, Numus’s insurer(s).

In respect to the above requirements, a report to the Commissioner is required “as soon as feasible after Numus determines that a breach of security safeguards has occurred,” where the breach involves personal information under Numus’s control and it is reasonable to believe that the breach creates a “real risk of significant harm” to an individual. The Breach of Security Safeguards Regulations prescribes the content, form and manner of the reporting. The report to the Commissioner must include the following:

(a) a description of the circumstances of the breach and, if known, the cause;

(b) the day on which, or the period during which, the breach occurred or, if neither is known, the approximate period;

(c) a description of the personal information that is the subject of the breach to the extent that the information is known;

(d) the number of individuals affected by the breach or, if unknown, the approximate number;

(e) a description of the steps that Numus has taken to reduce the risk of harm to affected individuals that could result from the breach or to mitigate that harm;

(f) a description of the steps that the organization has taken or intends to take to notify affected individuals of the breach in accordance with subsection 10.1(3) of PIPEDA; and

(g) the name and contact information of a person who can answer, on behalf of Numus, the Commissioner’s questions about the breach.

A notice to affected individuals is required—unless prohibited by law—if it is reasonable to believe that the breach creates a “real risk of significant harm” to the individuals. The notification must be given “as soon as feasible after Numus confirms that the breach has occurred,” and the Breach of Security Safeguards Regulations prescribe the content, form, and manner of notification. Generally, a direct notification is required. This form of notification may be given to the affected individual in person, by telephone, mail or email, or any other reasonable manner under the circumstances. An indirect notification can be given if a direct notification would be likely to cause further harm, likely to cause undue hardship to Numus or Numus doesn’t have the individual’s contact information. The notification to the individual must include the following:

(a) a description of the circumstances of the breach;

(b) the day on which, or period during which, the breach occurred or, if neither is known, the approximate period;

(c) a description of the personal information that is the subject of the breach to the extent that the information is known;

(d) a description of the steps that the organization has taken to reduce the risk of harm that could result from the breach;

(e) a description of the steps that affected individuals could take to reduce the risk of harm that could result from the breach or to mitigate that harm; and

(f) contact information that the affected individual can use to obtain further information about the breach.

Numus is also required to “notify any other organization, a government institution, or a part of a government institution of the breach” where Numus believes that the other organization or institution “may be able to reduce the risk of harm that could result or mitigate that harm, or if any of the prescribed conditions are satisfied.”

With respect to record-keeping, Numus is required to retain records with respect to every breach of security safeguards involving personal information (and not just for breaches that are deemed to create a “real risk of significant harm”). The Breach of Security Safeguards Regulations prescribe that Numus must maintain a record of every breach of security safeguards for 24 months after the day on which the firm determines that the breach has occurred, and that the record must contain any information pertaining to the breach that enables the Commissioner to verify compliance with the reports to the Commissioner and notification to affected individuals requirements.


Schedule 1 – Privacy Policy

Numus Capital Corp.

At Numus Capital Corp.(the “Company”) we are committed to protecting your privacy and the confidentiality of personal information that is share with us by our clients. This policy sets out the information practices for the Company, what kinds of information are collected, how the information is used and with whom this information might be shared.

1 Accountability: The Company is responsible for all personal information provided by clients under its control. Employees involved in collecting, disseminating and maintaining personal information are trained in all aspects of this Privacy Policy. The Company has appointed Charles Ackerman as Chief Privacy Officer, who is responsible for the implementation of this policy. If you have any questions or concerns you may address them to him at (902) 222-6507 or cackerman@numusfinancial.com.
2

Identifying the purposes and uses of personal information: When you apply to open an account with the Company we may collect the following personal information about you, including:

(i) Your legal name, address, occupation, telephone numbers and e-mail addresses;

(ii) Your date of birth;

(iii) Your Social Insurance Number;

(iv) Identification in the form of a passport or valid driver’s licence or a recent utility bill to verify your address;

(v) Details of your financial circumstances, including your income, your assets and liabilities, any legal undertakings and guarantees, your dependants, citizenship and tax status;

(vi) Details of your investment experience, your goals and financial planning objectives; and

(vii) Your business interests that would require insider trading practices.

This information is collected and used for seven purposes:

(i) To meet the account opening requirements of a custodian or chartered bank;

(ii) To verify the basis of developing with you a client profile under which your funds will be managed by the Company;

(iii) To document which other persons or professional advisors may have access to your account information and/or provide investment instructions to us on your behalf;

(iv) To allow the Company to satisfy itself about the information its reports regularly with respect to federal legislation on money laundering, fraud and other criminal activity;

(v) To allow the Company to prepare and distribute information to Canadian federal tax authorities;

(vi) To report to certain government securities regulators, as required, about the investment practices and operating procedures of the Company and to allow such regulatory agencies to conduct periodic compliance audits of the Company; and

(vii) To manage and assess the risks posed to the Company

A variety of personal information pertaining the operations of an investment account (security purchases and sales, deposits, withdrawals and security transfers) will develop over time.

For legal entities such as businesses, trusts, partnerships or estates we will collect information about the legal structure of the entity and information about those individuals authorized to act on the entity’s behalf. Where necessary we will establish beneficial owners of any of these entities.

The Company does not sell, rent or lease its customer lists to any third party. However, the Company engages third party service providers, most notably a custodian or chartered bank, legal and accounting professionals and computer systems support. When your information is provided to these service providers the Company will require them to protect your information in a manner that is consistent with this Privacy Policy and practices. Personal information given to the Company or any of its service providers may be accessible to regulatory authorities in accordance with the laws in those jurisdictions.

If we sell the Company or enter into an acquisition or merger agreement with another company, we may release the information it has about you to prospective purchasers. We will require any prospective purchaser to protect the information provided consistent with the Company’s privacy policies and practices.

3

Consent: The client will consent in writing to the provision of such personal information to the Company. This policy shall be attached to the Numus client profile executed for the client. By retaining the services of the Company the client will have consented to the disclosure of his or her personal information to various third parties as outlined in this policy and for the purposes set out in it.

A client may withdraw or withhold his or her consent at any time, subject to any legal or contractual restrictions. Such action shall be made in writing by the client, at which time the consequences of such withdrawal or withholding of personal information will be explained by the Company.

The Company will typically collect personal information from clients in the process by which accounts are opened or client profile are reviewed. However, it will also collect information from clients through personal meetings, telephone discussions, e-mail and facsimile transmissions and also from third party service providers involved in supporting the Company’s services. Records of these interactions may be kept by the Company.

The Company may use your e-mail address to communicate with you about privacy issues you raise and may send you information about products and services it offers or may offer in the future based upon an analysis of the personal information you provided. E-mails sent over the internet are generally not encrypted.

4

Limitation of use and retention of information: The Company will collect only that personal information which is required by it to meet its regulatory, statutory and business management needs to manage a client’s financial assets according to the agreed investment policy, as outlined in this policy. The Company will retain personal information only for the purposes of this policy and for meeting government and regulatory requirements, after which it will be destroyed or rendered anonymous, as per retention policies.

A prospective client, who does not enter into a portfolio management services agreement with the Company shall have returned to him or her all relevant personal information provided to the Company.

Every effort will be made by the Company to maintain correct data and from time to time clients may be asked to verify that information.

5

Safeguards: Your personal information is maintained on our secure computer networks and office files. Your information may also be stored on a secure off-site storage facility. A variety of security measures will be in place to reduce the possibility of theft of personal information or accidental disclosure.

You may access your personal information to verify its accuracy (upon written request), to withdraw your consent to any of the foregoing collections, uses and/or disclosures being made of your personal information and may update your information by contacting, in writing, the portfolio manager(s) employed the Company that is(/are) responsible for your account(s).

Existing Clients shall be able to express any concerns, at no additional cost to the client. All relevant client concerns shall be documented and maintained in a written (and electronic) file. The Company will use commercially reasonable efforts to promptly determine and rectify the problem.

There are circumstances in which the Company may use personal information without the client’s knowledge or consent. These circumstances include: (1) when the Company has reasonable grounds to believe the information might be useful when investigating a contravention of a federal, provincial or foreign law; (2) during an emergency which threatens an individual’s life, health or security; (3) for a statistical or scholarly study; (4) when mandated to provide such information by any federal, provincial or foreign law or regulation.

The Company has a right to refuse access to personal information by a client if: (1) the information is protected by legal privilege; (2) the information was collected for purposes related to the detection and prevention of fraud; (3) the information was generated in the course of a formal dispute resolution process; (4) granting access might reveal confidential commercial information; (5) it is reasonably expected that such personal information might lead to the threatening of the life or security of another individual.

6

Updating the Privacy Policy: The Company will occasionally update this policy to reflect client feedback, regulatory changes and Company experience.