We are committed to protecting the privacy and confidentiality of our clients' personal information in our possession. We inform our clientsthe reason/s forobtainingtheir personal information and how we use same in establishing and maintaining their relationship with us. We also advise themonthe ways we keep their personal information confidentialandhowthey can inquire aboutthe personal information that we hold.

This Privacy Policy applies to the operations of PanVest and all of the services and investment products it provides to its clients. Reference throughout this Policy to "we", "our" and "us" means PanVest Capital Corporation.

Employee Responsibilities
Each and every PanVest employee is responsible for preserving the confidentiality of all personal informationtowhich they have access.At time of recruitmentwe inform employees their regulatory obligations and the business reasons for instituting the internal controls as documented in our policies and procedures. We re-enforce this aspect through ongoing employee training,periodiccommunication, monitoringadherencetothese policies and procedures and consequently,dealing with any breaches that may lead to dismissal from employment and deploying any other remedies available at law to PanVest.

PanVest has designatedits President& CEO accountable for compliance with this Policy and any questions, requests or complaints should be directed at the address below:
PanVest Capital Corporation
315 Princess Avenue
Toronto, Ontario
M2N 3S5

What Is Personal Information?
The term "personal information" refers to information that specifically identifies a client as an individual or a corporation and is provided to or collected by us. It includes information that a client provides or that we collect from other sources with clients’ permission, for example: clients’ name and address, age and gender, personal financial records, beneficiary names, identification numbers including social insurance number and employment information for corporate clients, pertinent information about their shareholders, directors, officers and key employees, along with certain financial information may be obtained.

Why do we ask for theirPersonalInformation?
We ask for their personal information for business and regulatory reasons. We communicate with our clients about latest eligible investment opportunities, regulatory changes, reports, market studies, surveys, topics and articles of interest to them, information about events of their personalinterest,activitiesand changes withinour firm and anyvalue-added servicesavailable or newly introduced products by us or our service providers and advisors.Further, we want to align our actions with our clients’ investment objectives as we understand them. We work hard to establish a lasting relationship that growsand constantly aligns with our clients’ changing financial needs.

The moreaccurately and often we know about our clients and periodically update that knowledge, the better we can serve you and simultaneously fulfill our regulatory obligations under a variety of securities legislation and associated regulation. Some of the key reasons for requesting your personal information are to:
  • verify your identity for good business practice, regulatory compliance (e.g. Anti-Money Laundering) and protect in against fraud;
  • understand your financial goals, requirements and risk appetite;
  • determinethe suitability of investment products and services for you to the extent practically feasible; this is an industry-wide obligation. In addition, companies like us are obligated by law to obtain, document and retain most of the information you provide for examination by our internal and external auditors, regulatory inspectors, risk managers and so on;
  • set up, manage and report investments and services you have requested or we may think you might find useful in future;
  • report to you in a systematic way all your financial and non-financial dealings, products and services that may be of interest to youand where we are obligated to provide by law or as a matter of good business practice.
Most of the personal information is obtained at the time of account opening and thereafter updated periodically to meet our standards of conduct, industry best practices,legalandregulatory requirements of all levels of governments, agencies, self-regulatory organizations in Canada and abroad.

At any point of time you feel hesitant in providing all or certain specific information, you can state so in writing or by calling your primary contact at PanVest. In the event we determine that not having such personal information will result in a breach, then we evaluate such situations and reserve the right to open or continue the relationship as is, or if the situation warrants, discontinue same and suspend the sale of product or service.

Obtaining, Verifying and Accessing Your Personal Information
We obtain most of your personal information directly from you. With your consent, we may obtain financial and non-financial information from other sources. You can contact us at any time if you like to review or verify your personal information, or find out to whom we have disclosed it as permitted by this policy or by law.

Keeping Your Personal Information Accurate
We are expected and committed to maintainingaccuratepersonal information about our clients and prospects for as long as it is required for business reasons, including regulatory obligation or our corporate policy. Your prompt notification of any changes, financial or non-financial factors will help us in providing you with good service.

Please advise us if you discover any amendments needed in our records. Where appropriate, including where required by law, we will communicate these changes to other parties who we believe may have incorrect information about you.

Releasing Your Personal Information
  • PanVest does not sell your personal information to third parties. Our policy prohibits that as well.
  • PanVestdoes not discloseyour personal information to third parties other than in the following circumstances or for the following purposes:
    • in connection with normal business operations to open, maintain, administer or service your account (including services rendered by third party agents, service providers or affiliates) and for internal or external audit or regulatory audit purposes and analytical purposes;
    • wherewe are required to do so by law, including to any law enforcement agency or securities regulatory authority.
By opening or maintaining an account with PanVest or using our services, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described above.

Keeping Your Personal Information Confidential
Personal information is protected at PanVest by safeguards that are reasonable to the sensitivity against loss or theft and against unauthorized access, disclosure, copying, use or modification. Safeguards include: physical protection (such as locked cabinets), use of custodial services,restricted access to premises, organizational measures such as security check of employees and use of secured transportation where warranted and technological measures (such as passwords and encryption).

In circumstances where we use third parties for providing services to us on your behalfsuch third parties are given only the information needed to perform those services. Our contracts with such companies would typically identifystandards of confidentiality we expect and request them to provide satisfactory management around risks associated with personal information.

We have procedures in place about destroying, deleting, or disposing of personal information when it is no longer required for the purposes set out in this Policy or by law or dictated by our business dealings with you.

Retention of Your Personal Information
We keep your personal information for as long as we need it to meet the purposes set out in this Privacy Policyor by legislated or non-legislated practices in the investment industry. The length of time we retain your personal information depends onour business reasons, thestatus of current relationship with us and compliancewith legal or regulatory requirements.

YourChoice
You can choose not to provide us with some or all of your personal information. You can also withdraw your consent to our full or limited use of your personal information, subject to legal requirements for the retention or use of your personal information. If you withdraw your consent we may be limited in the services, communication or sale of products that we can provide to you.

Please direct any questions, requests or complaints to the attention of: President & CEO PanVest Capital Corporation.