Privacy Policy

At Kingsdale Shareholder Services Inc. ("Kingsdale"), we are committed to respecting your right to privacy. The nature of our business involves us obtaining certain personal details and financial information related to the shareholders of public and private companies. Keeping your information confidential is vital to our goal of providing the best service possible to our clients.

This policy will help explain how Kingsdale collects, protects and uses your personal information. If you have any concerns or questions with respect to how your personal information has been dealt with, please contact our General Counsel at rmundi@kingsdaleshareholder.com.

Personal Information

Personal information is any piece of information, either factual or subjective, about an identifiable individual. But personal information does not include the name, title, business address or telephone number of an employee of an organization.

The type of personal information Kingsdale collects about an individual is related to their shareholding in one or more of Kingsdale´s clients. This may include information regarding how an individual holds their security position, i.e. registered in person, company or nominee, and if there are any conditions on their holdings.

How Do We Collect Personal Information?
Typically, Kingsdale will obtain personal information from its issuer client, from the client´s transfer agent, from the shareholder directly or from a broker representing the shareholder.

How Do We use Personal Information?
We use personal information for verifying the shareholder registers provided to us by a company´s transfer agent and public source data, so that we may be able to contact shareholders in order to inform them of upcoming decisions or transactions that may affect their investments. The information we obtain is used in connection with a current, publicly announced transaction, or in certain cases completed transactions where shareholders have failed to exchange their shares for the transaction consideration that was offered. It is not used or transmitted to anyone else for any other purposes including solicitation.

Why Do We Collect Personal Information?
We collect, use and disclose personal information about you so we can:

1. establish your identity
2. protect you and us from error and fraud
3. comply with legal and regulatory requirements

If we need your information for any other purpose, we will identify that purpose.

Consent

Canada´s privacy laws stipulate that an individual´s consent is required prior to or at the time the personal information is collected. Consent can be implied or express.

By being a registered, reporting, or non-objecting beneficial shareholder of a company, the individual has provided us his or her consent to use the information solely for the purposes of verifying an updated and accurate register of shareholders of the company.

Disclosure of Personal Information

Subject to any judgment whereby Kingsdale is compelled under law to do so, Kingsdale will not disclose your personal information to any third parties. The nature of our business is to contact you directly via the personal information that has been afforded to us by our client or a company´s transfer agent.

Retention of Personal Information

Kingsdale will retain an individual´s personal information for as long as is necessary to fulfill the purposes for which it is collected or is required by law. Records for an individual´s personal information will be shredded and/or deleted after it has been deemed no longer necessary.

Monitoring Telephone Calls

Kingsdale may monitor and record telephone calls between you and our representatives to ensure accuracy, security, service quality and for training purposes.