Keybase Financial Group

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Privacy Policy

Things you should know

At Keybase Financial Group Inc., the protection of your personal information is of the utmost importance.

We collect and use your personal information to evaluate your investment needs, to access which of our products and services will meet your needs, and to effectively manage your investments with us.

To comply with the federal and provincial privacy legislation, Keybase Financial Group Inc. has implemented the following Privacy Policy

Protecting Privacy

  • We will keep your personal and business information confidential
  • We will allow you to control how we collect, use and disclose personal information by first acquiring your consent
  • We will allow you access to the personal information we have about you
  • We will not sell your information to third parties

Our Principles

Accountability

We will be responsible for protecting all of your personal information that is in our control or is transferred to third parties with your consent. Our Privacy Officer will be accountable for ensuring our compliance with the principles described in this policy and applicable federal or provincial legislation.

Identifying Purposes

The purpose(s) for which your information is being collected will be identified, explained and documented at the time of collection.

Consent

We will obtain your consent prior to collecting, using and disclosing your personal information.  Your informed consent (expressed or implied) will be required for collection, use or disclosure of personal information (except where permitted or mandated by law).

Limited Collection

We will only collect personal information that is needed for the specific purposes of servicing your accounts and investment needs.

Disclosure and Retention

We will use and disclose your information only for the purposes we will identify, or when it is mandated or permitted by law. We will retain your personal information only for as long as it is necessary.

Accuracy

We will keep your information accurate, complete and up to date as is reasonably possible.

Safeguards

We will safeguard your information with appropriate protective and security measures.

Openness

With a reasonable time after receipt of your written request, we will provide you with specific information on our personal information management policies and procedures. We will provide you with information that is easily understandable and we will encourage you to contact us with any questions.

Access

You will have the right to review any and all personal information we have about you, except where we are required or permitted by federal or provincial law to deny your access for a specific reason.  We encourage you to verify the accuracy of your personal information and inform us in a timely manner of any corrections that need to be made.

Concerns

If you have any concerns you will be able to request that our Privacy Officer investigate the matter and respond to your concerns with a reasonable time.

  1. What is personal information

“Personal information” can generally be defined as information that identifies you as an individual. It includes, but is not limited to:

  • Your name and legal land address
    • Your age and gender
    • Your financial history
    • Your identification numbers including your social insurance number
    • Personal references you have provided
    • Your employment history
  • 2. Why we ask for your personal information?

We will only collect the information we need to provide you with our services and products. The purpose(s) for using your personal information will be explained to you so that you may provide us with informed consent.

To protect you and Keybase Financial Group Inc. from identity theft and fraud.

 To access which products and services are best suited to your investment needs.

To better understand and serve your unique financial situation and investment needs.

To set up and manage products and services you have requested.

To comply with federal and provincial legislation.

You will have the option of not providing us with personal information. However, we will not be able to provide you with the product or service you requested or that we have offered to you.

We will ensure you are aware of why we need to collect, use and disclose your personal information when you apply for any of our products and services. If we have a new purpose for using your personal information we will again seek your informed consent.

3. Where we will collect personal information from?

A majority of the information we will collect comes directly from your application for our products and services. With your consent, we may also acquire your personal information from credit bureaus, income sources and personal references you have provided. We will only request information that is relevant to the financial services applicable to you.

4. Who will we disclose your personal information to?

Generally we will not disclose your personal information without your prior and informed consent.

With your prior consent we may disclose your personal information to other third parties outside Keybase Financial Group Inc. who assist us in servicing your best interests (including your financial institution). We will only disclose to these third parties the information that is necessary to serve your investment needs. We will select third party service providers that use comparable safeguard standards to our own.  Before releasing any personal information to these third party service providers, we will require them to sign binding contracts whereby they agree to safeguard all of your personal information.

However, the law permits or requires us to collect, use and disclose personal information without your consent in certain circumstances such as:

            To assist investigation authorities or the courts

            To protect the public interest (e.g. to combat fraud or money laundering)

            To protect our interests

To protect your interests when your consent cannot be obtained in a timely manner.

We may also share your information with self-regulatory authorities when Keybase Financial Group Inc. is so required.  These self regulatory organizations ,such as the Mutual Funds Dealer Association (MFDA), require access to personal information for regulatory purposes. This includes: surveillance of trading-related activity, sales, financial compliance and regulatory audits: investigation of potential regulatory and statutory violations; regulatory databases; enforcement or disciplinary proceedings reporting to regulators; and information-sharing with authorities.

5. Will you be able to withdrawal consent?

You will be able to contact us to withdrawal your consent at any time provided there are no contractual or other legal requirements limiting such withdrawal. Your Investment Advisor or our Policy Officer will explain your options and any consequences of withdrawing your consent.

If you do not want us to share information with our affiliates or any third party service providers who assist us in servicing your account, please contact us at any time.

If you do not consent to certain uses of your personal information, or if your consent is properly and legally withdrawn, we may not be able to provide you with certain products or services.  We will thoroughly explain the consequences to help with your decision.

6. How will we safeguard your personal information?

We will use a variety of security measures to protect your personal and investment information including:

            Locked Filing cabinets and offices

            Electronic security

            Secured retention and destruction of information

Restricting employee access to files and data centres where applicable

Our Policy Officer will be responsible for the review and adjustment of our procedures. We restrict access to your personal information to the employees/agents who service your accounts. Our Policy Officer will ensure our Privacy Policy is properly administered and that our security measures are up to date and effective.

7. How will you be able to find out what personal information we have collected about you?

You will be able to make a written request to know what personal information we have concerning you. You will have to provide us with a written request that has sufficient detail to enable us, with reasonable effort, to identify you and your personal information. We will generally respond within thirty days with the information you have requested or with a detailed reasonable explaining what that information is withheld.

8. How will you be able to change or correct your personal information?

If you need to change your personal information we have on file for you, please contact your Investment Advisor.  You will have to provide us with a written request that has sufficient detail to enable us, with reasonable effort, to identify you and the personal information or correction being sought.

We will correct inaccurate or incomplete information within a reasonable time and notify you when such changes are completed.  There is no charge for correcting your information.  We will also ensure that any third party that have received your personal information from us are notified of such changes or corrections.  If there is any information that is still in dispute, we will make a note on your file.

9. How long will we keep your personal information?

Your personal information will be kept on file as long as we need it to provide you with the products and services you have requested and to meet legal and regulatory requirements.  The length of time you personal information is retailed may vary according to the product or service and the sensitivity and nature of information.  This period may extend beyond the termination of our relationship for as long as it is reasonably necessary for legal or business purposes.  After your information is no longer needed for the specific purposes identified to you, we will destroy, delete, erase or convert your personal information to an anonymous form.

10. Who will you be able to contact if you have any questions regarding our Privacy Policy?

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Privacy and Personal Information

Your information and the business you do with Keybase is kept in strict confidence.

• Only authorized personnel have access to your information.

• We collect, use and disclosure personal information that a reasonable person would consider appropriate for the circumstances.

• Our procedures and systems are designed to protect your information from error, loss and unauthorized access.

• We keep your information for only as long as it is needed and/or required by regulation.

• We monitor our compliance with applicable privacy legislation.

• You understand that Self-regulatory organizations (‘SRO’) and other regulatory authorities require access to your personal information. Regulatory authorities collect, use or disclosure such personal information obtained from regulated persons for regulatory purposes.

• You understand that in signing this document you are giving permission to your Advisor to obtain and keep on file personal information that you have provided to him/her.

• You understand that this personal information, not publicly published about you, may include but is not limited to: income tax information, account statements from other firms, including banks,

trust companies or fund companies; pension plan information; legal documents including wills, trusts, and power of attorney.

• You understand that your Keybase Advisor may use and disclose this information in order to: communicate with you in a timely and efficient manner; assess your application for investment; insurance and other services available to you by his/her firm; assess your financial situation and contact you with any other suitable products that he/she is authorized to see; evaluate claims and underwriting risks when required; detect and prevent fraud; analyze business results; and act as required or authorized by law.

• You understand that you have the right to know why an organization collects, uses or discloses your personal information; you have the right to expect an organization to handle your information reasonably and to not use it for any purpose other than the one to which you consented; you have the right to know who in an organization is responsible for protecting your information; you have the right to expect an organization to protect your information from unauthorized disclosure; you have the right to inspect the information an organization holds about you and make sure it is accurate, complete and current; you have the right to confidentially complain to an organization about how it handles your information and may escalate your complaint to the Privacy Commissioner of Canada if need be; and you have the right to remove your consent at any time by contacting your Advisor in writing.

• You understand that your Advisor will not: sell your information to anyone; or share your information with organizations outside of our relationship that would use it to contact you about their own products or services.

Your Advisor must decline to accept or administer an account if you do not consent to such intended collection, use disclosure of personal information to SROs and the use and disclosure of that information by SRO’s.

If you have any questions or concerns about the way your personal information is collected, used or disclosed by Keybase Financial Group Inc., you will be able to contact our Privacy Officer at:

Privacy Officer

Keybase Financial Group Inc.

101 – 1725 16th Avenue

Richmond Hill, ON

L4B 0B3

Phone: 905-709-7911

Fax: 905-946-9737