PRIVACY POLICY

Last updated: December 21, 2018

1.0  Equiton’s Commitment to Privacy

Equiton and its associate and affiliated companies (the “Company” or “Equiton”) is committed to protecting your privacy and the confidentiality of your personal information and respects the following key privacy principles when collecting, using or sharing your personal information.

1.1 Equiton’s Privacy Principles

a. Accountability.

  • Equiton is responsible for personal information under its control.

    • b. Identifying Purposes and Obtaining Consent

  • Equiton informs individuals, at or before the time it is collected, the purposes for the collection, use and sharing of personal information.

    • c.  Keeping Your Personal Information Accurate and Providing Access to Your Information

  • Equiton takes care to keep personal information as accurate, complete and up to date as is necessary for the purposes for which it is to be used.

    • d.  Limiting the Collection, Use or Sharing of Your Personal Information

  • Equiton limits the personal information it collects to what is necessary for the purposes it has identified and does not use or share personal information for purposes other than those for which it was collected except with your consent or where permitted or required by law. Personal information is only retained for as long as necessary for customer service, legal or reasonable business purposes.

    • e.  Openness and Addressing Your Concerns

  • Equiton makes available information about its privacy practices and enables you to follow up if you have questions or concerns about your privacy.

    • f.  Protecting Your Personal Information

  • Equiton strives to protect the privacy of personal information through security measures appropriate to the sensitivity of the information.

    • 2.0 Statement of Purpose

    2.1 About this privacy policy

    Equiton’s Privacy Principles, together with our Digital Privacy Statement included in the Appendix hereto and any privacy provisions in the terms of your agreements with us, form Equiton’s “Privacy Policy”. This policy applies to the collection, use, or sharing of any personal information collected by Equiton in the course of conducting its business in Canada and will continue to apply for so long as Equiton may hold your information (including after the termination of any of your services agreements with us). This policy also outlines how we protect and retain your information and the rights and choices you have regarding your personal information. If you have any questions on how we handle your personal information, please contact us using the information below. By providing us with information, you are consenting to the collection, use, or sharing of your information as set out in our privacy policy.

    2.2 Introduction

    Equiton is committed to maintaining the accuracy, confidentiality, and security of your personal information. This Policy describes the personal information that Equiton collects from or about you, and how we use it and to whom we disclose that information. All references in this Privacy Policy to “Equiton”, “we”, “us”, “our” and like terms should be interpreted accordingly.

    2.3 Policy of Compliance

    It is Equiton’s policy to comply with applicable privacy legislation.

    2.4 What is personal information?

    For the purposes of the Privacy Policy, personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

    2.5 What personal information do we collect?

    We collect and maintain different types of personal information in respect of those individuals who are potential or actual employees as well as potential or actual clients of Equiton, including the personal information contained in:

  • Resumes or applications.
  • References and interview notes.
  • Backcheck information (criminal/police records, credit checks, education verification).
  • Photographs and videos.
  • Letters of offer and employment agreements.
  • Payroll information, including cheque deposit information, wages and benefits, disability, medical or dental care.
  • Beneficiary or emergency contact information.
  • Client Identification, including social insurance numbers or driver’s licenses.
  • Client information contained in KYC and Suitability.
  • HR System, including names, date of birth, email address, addresses, marital status.
    • In addition to the examples listed above, personal information is also any other information necessary to Equiton’s business purposes, which is voluntarily disclosed to Equiton.
    As a general rule, Equiton collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).
    From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
    Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or con

    2.6 Why do we collect personal information?

    The personal information collected is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with Equiton or for the purpose of onboarding you as a client of Equiton. Such uses include:

  • Determining eligibility for initial employment, including the verification of references and qualifications;
  • Administering pay and benefits;
  • Processing employee work-related claims (e.g. worker compensation, insurance claims, etc.);
  • Establishing training and/or development requirements;
  • Conducting performance reviews and determining performance requirements;
  • Assessing qualifications for a particular job or task;
  • Gathering evidence for disciplinary action or termination;
  • Establishing a contact point in the event of an emergency (such as next of kin);
  • Complying with applicable securities, labour, or employment statutes;
  • Compiling directories;
  • Ensuring the security of company-held information; and
  • Such other purposes as are reasonably required by Equiton.

    • 2.7 Monitoring

    The work output of Equiton employees, whether in paper records, computer files, or any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by Equiton. In the course of conducting our business, we may monitor employee activities on our premises and property. For example, some of our locations are equipped with surveillance cameras. Where in use, surveillance cameras are there for the protection of employees and third parties, and to protect against theft, vandalism, and damage to Equiton’s goods and property. Generally, recorded images are overwritten on a regular basis and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to the police or other appropriate government agency or authority. This section is not meant to suggest that all employees will in fact be monitored or their actions are subject to constant surveillance. It is meant to bring to your attention the fact that such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources). When using Equiton’s equipment or resources, employees should not have any expectation of privacy with respect to their use of such equipment or resources.

    2.8 How do we use your personal information?

    We may use your personal information:

  • For the purposes described in the Privacy Policy; or
  • For any additional purposes that we advise you of and, where your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.
    • We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

    2.9 When do we disclose your personal information?

    We may share your personal information with our employees, contractors, consultants, and other parties who require such information to assist us with establishing, managing, or terminating our employment relationship with you, including parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you.

    In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of Equiton through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
    Clients of Equiton may have their personal information shared with Canadian Securities Administrators including the Ontario Securities Commission, in connection with any legal or regulatory review. Furthermore, during the course of filing a report of exempt distribution, client’s name, address, security type, number of securities, and the dollar value invested will be disclosed to the applicable Canadian Securities Administrator.
    Further, your personal information may be disclosed:
  • As permitted or required by applicable law or regulatory requirements. In such a case, we will endeavour to not disclose more personal information than is required under the circumstances;
  • To comply with valid legal processes such as search warrants, subpoenas or court orders;
  • To protect the rights and property of Equiton;
  • During emergency situations or where necessary to protect the safety of a person or group of persons;
  • Where the personal information is publicly available; or
  • With your consent where such consent is required by law.

    • 2.10 Notification and consent

    We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

    To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to Equiton collecting, using, and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time the such personal information was provided to us).
    Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to Human Resources.

    2.11 How is your personal information protected?

    Equiton endeavours to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification, or disclosure.

    2.12 Updating your personal information

    It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes. In some circumstances, we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

    2.13 Access to your personal information

    You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact Human Resources. Please note that any such communication must be in writing.

    When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
    In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why subject to any legal or regulatory restrictions.

    2.14 Inquiries or concerns

    If you have any questions about the Privacy Policy or concerns about how we manage your personal information, please contact Human Resources, the office of the CEO, or CFO by telephone at 905-635-1381 in writing or by email. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you.

    Policy Review
    The executive owner of the Privacy Policy will conduct an annual review of the policy. This is a control measure taken on a continuous basis to ensure the policy and approval processes are being applied.

    Appendix A – Digital Privacy Policy

    Equiton Capital Inc. or any of our affiliated or associated companies (“Equiton” or “we” or “us”) know that you care how your information is used, and we appreciate your trust that we will use it carefully and sensibly. This notice describes how we collect, use, store, transfer and disclose your personal information. By visiting www.env-equitonnew-equitonpr.kinsta.cloud (the “Website”), you are accepting the Digital Privacy Policy described below, as amended from time to time.

    1. WHAT PERSONAL INFORMATION DO WE COLLECT?

    Information You Provide

    We reserve the right to update or change our Privacy Policy at any time and users should check this Privacy Policy periodically. The user’s continued use of the Website after we post any modifications to the Privacy Policy on this page will constitute acknowledgment of the modifications and consent to abide and be bound by the modified Privacy Policy. We receive and store the information you provide to us. We only collect your personal information with your consent. For example, we may collect personal information such as your name and email address to help us better identify and contact users.

    Cookies & Data Logging
    Like many websites, we use “cookies.” Cookies are small programs that we transfer to your hard drive that may include an anonymous unique identifier which we may use to provide you with a customized Website experience. If you do not want us to use cookies, you can disable them. In addition, you may visit this and other websites anonymously through the use of utilities provided by other private companies.
    In addition, we automatically collect other information such as browser types, operating systems, and the URL addresses of sites clicked to and from this site. We may also collect anonymous aggregate information on what pages you access or visit. The aggregate information we collect is used for many different purposes in order to serve you better. Among these purposes are to improve the content of the Website, provide services such as technical support, and customize the content and/or layout of the Website for each individual visitor. We may also use third-party services, such as Google Analytics.
    2. HOW DO WE USE YOUR INFORMATION?
    We use personal information for the purposes stated or implied at the time of collection, including to respond to your requests, improve the Website, communicate with you, complete transactions that you initiate, to meet the legal and regulatory requirements applicable to us and to improve our business. We may otherwise use your personal information where permissible by law, for example to respond to an emergency, or in the course of an investigation into illegal behavior. We may use personal information to send marketing or promotional materials and other commercial purposes.
    3. TRANSFERS AND DISCLOSURES OF PERSONAL INFORMATION
    We will not disclose personal information to any external organization without your consent, unless we are required to do so by law.
    Third Party Service Providers
    We may employ other companies and individuals to perform functions on our behalf. Examples
    include delivering packages, sending postal mail and e-mail, and to administer accounts. Some of our third-party service providers may be located outside of Canada, and subject to the laws of foreign jurisdictions. We may transfer personal information to our third-party service providers to perform their functions, but they may not use personal information for other purposes.
    Business Transfers
    As we continue to develop our business, we may buy or sell assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the unlikely event that we are acquired, customer information will be one of the transferred assets. We may therefore disclose your personal information in the event of a corporate amalgamation, reorganization, change of control or sale.
    Law Enforcement
    If we receive a lawful court order to release account or other personal information, then we comply with the law. We will also release information when necessary to protect the life, safety or property of others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
    4. HOW DO WE PROTECT THE SECURITY OF YOUR INFORMATION?
    We take all reasonable steps to protect the security and confidentiality of your personal information. We protect personal information within our custody or control with appropriate organizational, technological, and physical safeguards. For example, we use a firewall to protect against unlawful intrusion. We limit access to your information on a need-to-know basis. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer. No system can guarantee absolute security over personal information; however, we take every reasonable precaution to assure that your data is secure.
    5. RETENTION
    We only retain personal information for as long as is necessary for the purpose for which it was collected. When we no longer are required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that which we might otherwise hold.
    6. YOUR CHOICE: OPT-IN OR OPT-OUT

    It is your choice whether to receive emails or special offers from us or others. Where applicable, we will seek your express consent to send you information, including by way of commercial electronic messages (such as emails). This consent is sought by Equiton Partners Inc. at 1111 International Blvd, Suite 500, Burlington ON, Canada, L7L 6W1 and web@equitoninternetlinux.azurewebsites.net. You can unsubscribe at any time by following the instructions in the commercial electronic message.

    If you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.
    Various websites may be linked to or from the Website. If you link to another site, your privacy
    depends on the policy of that site. We strongly urge you to check their privacy policy. Not all sites guarantee that they will not share your personally identifiable information with others.
    8. ACCESS, CORRECTION, AND ACCOUNTABILITY
    We will strive to keep all personal information in our files complete, up-to-date, and accurate.
    You or a person authorized on your behalf has the right to request to see and obtain a copy of your personal information and to request changes or corrections to inaccurate or incomplete

    information. If you have any questions or concerns with respect to your personal information or our information practices, you may contact us at inquiries@equiton.com

    We reserve the right to update or change our Privacy Policy at any time and users should check this Privacy Policy periodically. The user’s continued use of the Website after we post any modifications to the Privacy Policy on this page will constitute acknowledgment of the modifications and consent to abide and be bound by the modified Privacy Policy.