Privacy Policy

The financial clinic is committed to protecting the privacy and confidentiality of personal information in its possession and control. This privacy policy explains the steps we take to meet this commitment and describes how the financial clinic collects, uses, communicates and processes this information through its Web site, The Financière.com Clinic, including successive sub-pages and pages (collectively, the "website"), and through other interactions with our potential customers and clients.

This privacy policy can be updated on a regular basis to reflect changes in our personal information practices. We strongly encourage you to regularly review this privacy policy to inform you of the most recent changes to our personal information practices.

We only ask our clients for the necessary personal information.

The financial clinic must collect personal information from its clients and potential clients to provide services and meet its legal obligations. By understanding a customer's needs and wishes, as well as his or her family and financial situation, we make sure that he makes investment recommendations that are always appropriate. It is both a regulatory requirement and good business practice. The financial clinic is committed to protecting the privacy of its clients and the confidentiality of their personal information in their possession. This policy explains the steps we are taking to meet this commitment.

The information form entitled "Know your Customer" that we ask you to complete only collects the information we need for contractual, regulatory or tax purposes, including your name, address, Telephone and fax machines, your email addresses, your date of birth, your social Insurance number (for the purpose of filing income tax returns), the assets you hold and their value, your knowledge and your objectives of investment. We also collect information about your chequing account and information about an optional beneficiary (for example, the name and occupation of your spouse, and the name and age of your children and dependants).

Our Registered Retirement savings Account Application forms only collect the information necessary to register these accounts with the Government, including the social Insurance number, and the name and date of birth of Your spouse or your designated beneficiary. We do not disclose any personal, non-public information to any third party, except as provided in the act or as outlined in this policy. We also collect your responses to a risk tolerance questionnaire and other regulatory issues that we are required to collect under the Act.

We limit the use of your personal information.

The personal information we collect when you open an account is used for the following purposes:

We Help determine which portfolio is right for you and which best suits your needs

Check Your identity (and other information you have provided to us);

Open and manage your account

Send and receive your bill payments through your chequing account;

Detect and prevent fraud and other illegal or unauthorized activities;

Fill Our legal and regulatory obligations

Do What is otherwise required or permitted by applicable laws.

We collect and use personal information in other ways.

Referral Program: If you participate in our referral program (or other "invite a Friend" features (available on our web sites), we will collect the email address of each person you wish to recommend to the clinic. Financial. We will use this information to send the recipient a single email containing information about the referral program. We do not use email addresses submitted in these circumstances for other purposes without the consent of the recipient. Be sure to submit only email addresses of individuals with whom you have a family or personal connection and who would like to receive this email from you.

Commercial communications: Once in a while, we may ask for your consent to receive e-mails, SMS text messages or other communications about the products and services of the financial clinic or events that Might interest you. You can unsubscribe from commercial or promotional emails by following the unsubscribe instructions contained in each of our email communications. Note, however, that you will continue to receive emails about your account and your transactions with us. You can also unsubscribe from any commercial communication on our part by writing to support@lcfi.ca.

"Relationship Manager": If you contact a customer service agent to make a comment, file a complaint or ask a question, by email, text message, telephone or video discussion, it may be asks you for information to identify you (such as your name, address and telephone number). We could also ask you for other information that allows us to quickly follow up on your question, comment or complaint. We could keep this information to help you in the future and to improve our customer service and our offer of products and services.

Employment: If you are inquiring about a job with us or apply, you may provide us with some personal information (such as those included in a résumé, cover letter or similar documents Employment- related). We use this information to process your job application for an existing or potential position, as well as to respond to it.

How we collect personal information

Unless otherwise stated in this privacy policy, we collect your personal information directly from you. If you open an account at the financial clinic, you will need to open a broker account with ShareOwner or Virtual brokers- Custodians who offer, inter alia, operations and compensation services on our behalf. We collect personal information about you from our custodians, including business statements and cash and securities statements in your accounts, to monitor the performance of your portfolio investments and Provide you with statements as required by the securities laws.

We limit access to customer's personal information.

We record the customer's personal information electronically on computer servers to which only authorized persons have access. These authorized people have access to the servers using safe passwords only. We authorize our employees and service providers to access our customer's personal information only in circumstances where this information is necessary to fulfill job-related responsibilities.

We put in place devices to protect personal information.

The financial clinic has put in place reasonable administrative, technical and physical devices to protect the personal information it has custody and control against any access and use, modification and

communication not Authorized. Our employees are trained to keep the personal information of clients strictly private and confidential. All members of our staff are required to sign our Privacy protection document, which requires them to respect and protect the personal information of the clients. We ensure that staff leaving the financial clinic understand that they remain contractually obligated to respect the confidentiality of this information.

Your online access to some of your personal information is protected by the password of your choice. We strongly recommend that you do not communicate it to anyone. We will never ask you for this password in an unsolicited communication (such as a letter, phone call or email).

Our process of preserving the personal information of our customers and potential customers is designed to ensure that this information is never kept longer than it needs for the purposes set out in this privacy policy or For the purpose of complying with legal obligations.

We restrict the disclosure of personal information.

We will not communicate, negotiate, rent, sell or otherwise transfer your personal information without your consent, except as otherwise provided in this privacy policy.

Service Providers: We could transfer your personal information to members of our group and other third party service providers who offer various services on our behalf, such as identity verification services, Administration, printing, marketing and advertising, hosting, data analysis or accounting or technological or legal services.
Broker: When you open a brokerage account with our custodian, we provide your account information to the brokerage company concerned to simplify the application process. We also notify you of updates and changes to your account information.
Business Transactions: We may transfer any information we own about you as an asset in connection with any sale or merger carried out or projected (including transfers made in the context of a bankruptcy proceeding or In whole or in part the financial clinic or in the context of a reorganization of business, without limitation, or a sale of shares or other change in the control of the business, including for the purpose of Determine whether or not to follow up on a transaction or business relationship or to prosecute it.

Securities regulation: we [and/or our custodian] can share your name, your contact information and your holdings with the issuers of the securities you hold in your account and with other natural or legal persons, such as Require the securities laws. Such issuers may request your personal information in order to provide you with financial reports, tax documents and other relevant documents, or to comply with applicable regulatory obligations. We [and/or our custodian] may also disclose certain personal information, such as the number of shares subscribed and their purchase price, to the appropriate Canadian securities Authority, where required by law.

Legal issues: We and the members of our group in Canada, the United States and elsewhere, as well as third party service providers, could provide your personal information under a search warrant or other investigation or Legitimate order. They could also be provided to another organization for the purpose of investigating the violation of an agreement or law or in order to detect, counter or prevent a case of fraud. Finally, they could be provided as required or otherwise permitted by Canadian, U.S. or other laws and regulations (which could include legitimate access requests by the courts, enforcement agencies

The law or government authorities of Canada, the United States or elsewhere). We may also disclose personal information, if necessary, for the purpose of establishing, exercising or defending rights and investigating real or suspected personal or material loss or damage, and to prevent such losses or Such damages.

We expect our suppliers to have similar protective devices.

Our service providers receive the information they need to perform their expected functions, and we do not allow them to use or disclose personal information for marketing purposes or other purposes that are Own. Your personal information may be retained and processed by members of our group and other third party service providers in the United States or other jurisdictions. If personal information is transferred to the United States or to another foreign territory, it will be subject to the laws of that territory and could be communicated to the courts, law enforcement agencies and the authorities Government, or could be consulted by them in accordance with the laws of those territories.

We take privacy seriously.

The compliance director of the Financial Clinic, Lawrence SHAW, is responsible for ensuring that the financial clinic respects its privacy policy. It has the responsibility to introduce our employees to our privacy policies and to ensure that we respect our privacy commitments. We invite any potential customer or customer to contact him or her at the addresses or numbers listed below for further clarification. If you are wish to consult your personal information in our possession, you must apply in writing to the Director of compliance of the Financial clinic.

We will give you access to your information.

You have the right to access your personal information that the financial clinic has custody and control of, to update and correct inaccuracies, except in certain circumstances provided by law. You can update certain information you have provided to us on your profile by logging into your account and clicking on "Settings". Otherwise, if you wish to access your other personal information that the financial clinic has custody and control of, update and correct inaccuracies, you must make a written request to the Director of compliance, coordinates listed below. We may ask for some personal information to verify the identity of the person requesting access to the personal information record.

The Financial Clinic 410 – 9160 Boul. Leduc Brossard Qc, J4Y 0E3

Gold

To care: complaints
plaintes@lcfi.ca

We collect and use information about your visit to our website.

In general, you can visit our website without indicating Who you are or Submit personal information. However, we collect and/or retain the IP addresses of the All visitors of the Web site and other related data, such as the pages viewed, the type of browser, the operating system, and the average duration of your visit to the website. We use this information to understand the activity on the website and to monitor and improve the website.

Cookies and similar technologies: The website uses a technology called "cookies". A cookie is a small piece of information that the Web site can send to your browser, which can then be stored on your hard drive and that allows you to be recognized every time you return to the site. We use cookies on the pages of the Web site that you are called on to log on to or that are customizable. If you signed up for the website, cookies can tell us who you are and identify your browser as a browser that has already visited the Web site; In addition, they may be required to access your account information (stored on our computers) to deliver personalized products and services. We also use cookies to provide us and our service providers with information about your use of the website, which we can use to personalize the website or other content in accordance with your interests and your preferences (e.g. language) and improve your user experience. You can set your browser to warn you when you receive a witness or if it refuses certain witnesses. However, if you decide not to accept cookies from the website, you might not be able to take advantage of all the features.

Invisible pixels: The Web site can also use a technology called "invisible pixels." This technology allows us to understand which pages of the website you are visiting. The invisible pixels help us optimize the website and adapt it to you and other future visitors.

Web Analytics Services: We can use third party services to help us collect and analyze data on the pages visited on the website to better understand, evaluate and improve user experience and usability of the website.

Social media: We can offer you the opportunity to view our content on third-party social networking websites or through such sites, INS (plugins) and applications. By consulting it in this way, you could allow us to have access to certain information associated with your social media account (for example, your name, username, email address, profile photo, sex) for you Provide content or to run the Web site, plug-in or application. If you provide us with information through your social media account, we could use this information to personalize your experience when you visit the Web site and the third party social networking websites or use Ins and applications, and provide you with the other products or services you could ask for.

We use online advertising.

We can use the services of third parties, such as advertising data companies and advertising exchange, for the purpose of administering our advertisements on our website or other websites. These companies can use cookies or invisible pixels to get some information about your visits to our website and other websites (such as Web pages you visit and your responses to advertisements) to measure the effectiveness of our Marketing campaigns and send you advertisements that are more relevant and tailored to your situation, whether on our website or out of our website.

To learn more about these behavioral advertising practices or to unsubscribe from this type of advertisement, you can visit the Digital advertising Alliance website at www.aboutads.info/choices/or the digital advertising Association of Canada www.youradchoices.ca/choices.

We can provide links to third party websites.

Our website may contain links to other websites that do not belong to us or that we do not exploit. In addition, websites of third parties on which we post advertising may include links to our website. Unless otherwise provided herein, we will not disclose your personal information to these third parties without your consent. We provide links to third party websites to help users. These links should not be

considered as an endorsement or a recommendation of linked websites. Linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over these websites and, therefore, we reject any responsibility for the way in which companies that operate linked websites can collect, use or communicate, protect and otherwise treat Your personal information.