Langdon Equity Partners Ltd. and its affiliates (Langdon, us or we) understand and appreciate that you, as a client, potential client or a website visitor are concerned about the confidentiality and security of information we may collect about you when providing you with information, products or services. Langdon is committed to protecting your privacy and the confidentiality, integrity and security of your personal information in accordance with this Privacy Statement. This Privacy Statement is supplemented by, and should be read in conjunction with, our Online Privacy Notice which specifically addresses personal information collection, use and disclosure in the context of our online or other digital channels, including our websites.

In connection with your requests for information, the opening of accounts and the provision of products and services to you, Langdon collects and maintains non-public personal information and other confidential information about you. The types of personal information that we collect from you generally include your name and contact details (such as your email address, home address and telephone), social insurance and other tax identification numbers, banking information and other information necessary to provide our products and services.

Langdon collects and maintains personal information for the following purposes:

·       to establish the identities of clients;

·       to enable us to provide professional and responsible portfolio management, and to give clients the best possible service;

·       to assess clients’ eligibility with respect to our products and services and the suitability of an investment for a client’s portfolio;

·       to provide targeted communications about products and services offered by us and to respond to requests for information we receive from you;

·       in connection with services provided by third party service providers;

·       to protect you and Langdon from error and fraud;

·       to meet legal and regulatory requirements; and

·       for other purposes as permitted or required by applicable laws, including the enforcement of our legal rights.

Langdon may also collect, use and disclose personal information for other purposes that are disclosed to you at or before the time that such information is collected, with your consent (express or implied, pursuant to applicable laws).

Personal information is collected from the portfolio management agreements, account opening forms or other forms or information requests you have submitted, and during client meetings and telephone conversations and through electronic communication and interactions, including email and visits to our websites. Other personal information is collected in connection with your transactions with us.

Unless you otherwise advise, by providing personal information to us, the relevant documents will provide that you are consenting to the collection, use and disclosure of this information as provided herein and therein. However, you will not be required to consent to the collection, use, or disclosure of your personal information beyond what is necessary to fulfil the explicitly specified, and legitimate purposes that are identified to them in this policy or such documents, as a condition of the supply of our products or services.

Langdon may disclose your personal information to third parties, when necessary, and to any affiliates in connection with the services and products we provide, including:

·       financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of client accounts;

·       other service providers, such as accounting, legal or tax preparation services;

·       affiliates, including Pinnacle Investment Management Limited, for the purposes of maintaining distribution lists, providing marketing communications and administering client servicing;

·       securities regulatory authorities, taxation regulatory authorities, and other relevant regulatory authorities and agencies, for the purposes of complying with legal and regulatory obligations; and

·       to other third parties where permitted or required by applicable law, including in the event of a sale, merger or reorganization of all or part of our business.

Langdon may also disclose personal information on its own initiative, to the extent permitted by applicable law, if there are reasonable grounds to believe a crime or a violation of applicable laws or regulations is involved.

Langdon will not collect specific client personal information from its website visitors unless personal information is provided by the user or contact is requested. Our websites may employ standard technology to collect information about how its website is used for the purpose of improving website design. Website information is collected in many forms including by obtaining the domain name of visitors, user preferences, personal information that is volunteered and geographic location. Website visitors may occasionally receive emails from us informing them of events and services, if they have consented to receive such communications. Please refer to our Online Privacy Notice for further information.

Langdon seeks to carefully safeguard your personal information and, to that end, has established policies, procedures, guidelines and security measures to ensure that personal information is protected against unauthorized access, theft or improper disclosure.  This includes restricting access to that personal information to those employees and other persons who need to know the information to enable us to provide products and services to clients. Each Langdon officer, director, employee and consultant is subject to these policies, procedures and other measures and is responsible for ensuring the confidentiality of all personal information he/she/they may access. Personal information is maintained on our networks or on the networks of our service providers, access to which is password protected. Information may also be stored in a secure off-site storage facility. Langdon has, and will have, agreements in place with these third-party service providers to ensure the proper handling and protection of your personal information.  We believe all the above measures serve to significantly reduce the risk of significant harm to any individual. Personal information may be transferred and/or stored outsideCanada by us or our service providers, in which case it may be accessible to courts, law enforcement and national authorities in other countries.

As (and to the extent) required by law, Langdon will record any breach of security safeguards involving client personal information under its control and will report such a breach to the appropriate regulatory body and/or applicable organization if there is a real risk of significant harm to any affected individual.  This generally means the Office of the Privacy Commissioner of Canada.  We will also notify affected individuals in such circumstances. The notification to an individual will contain sufficient information to allow them to understand the significance of the breach and totake steps to reduce the risk of harm that could result from it. The notification will also contain any other information as prescribed by regulation or law.

If you have any questions or feedback about this Privacy Statement, require a copy of our Privacy Statement or have any privacy issues concerning Langdon, please contact our client services team at:

Telephone: +1(437) 703-9349

If your concerns are unresolved, you may contact our Compliance Officer at:

Attn: Chief Compliance Officer Langdon Equity PartnersLtd., 30A Hazelton Ave, Suite 400 Toronto, Ontario M5R 2E2

You may also contact our Chief Compliance Officer to submit a request to access your personal information; update, rectify or verify the accuracy of your personal information; withdraw consent to the continued collection, use and/or disclosure of your personal information, subject to legal or contractual restrictions and reasonable notice; or ask questions or make a complaint regarding this Privacy Statement and/or our collection, use or disclosure of your personal information. You should advise us of any changes to your client information as soon as practicable.

Please note that your ability to obtain products and services from us may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information as outlined above due to our inability to comply with regulatory requirements if this consent is not provided.