3iQ Privacy Policy

Scope of Policy

3iQ Corp. and our affiliates and subsidiaries ("Company" or "we") respect your privacy and are committed to protecting it by complying with this privacy policy (the “Policy”).

This Policy describes:

• how we collect, use, disclose, and protect the Personal Information of our customers and website users ("you");
• the types of information we may collect from you or that you may provide when you visit the website https://3iq.io/ (our "Website") or when you use our digital assets management services (our “Services”); and
• our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your Personal Information in accordance with this Policy, unless otherwise required by applicable law. We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This Policy applies to information we collect, use, or disclose about you:

• on this Website;
• in email, text, or other electronic messages between you and this Website;
• when you interact with us for the provision of our Services.
• offline or through any other means, including on any other Company or third-party website; and
• when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for them. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is to not use our Website. By accessing or using this Website and using our Services, you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website and Services after we make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates. We will notify you in advance of any material changes to this Policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

Information We Collect About You

We collect and use several types of information from and about you, including:

• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, social insurance number, banking information, any “know-your-client” information, including identity verification records required under applicable laws including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), regulations and policies made thereunder and other statutes and regulations that take legislative measures against money laundering, terrorist financing and against financial dealings with certain sanctioned individuals and entities, and any other identifier we may use to contact you ("Personal Information").
• Business-related information, namely, information that relates to your business duties, including:
  • your title;
  • your duties;
  • your business address;
  • your business email address; and
  • your business telephone number.
• Non-personal information that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, statistical information or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

How We Collect Information About You

We use different methods to collect your information, including through:

• direct interactions with you when you provide it to us, for example, by filling forms or corresponding with us by phone, email, or otherwise;
• automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and
• third parties or publicly available sources, for example, our business partners.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

• information that you provide by filling forms on our Website or offline. This includes information provided at the time of registering to use our Website or our Services, communicating with us or requesting further Services. We may also ask you for information when you report a problem with our Website or Services;
• records and copies of your correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes;
• details of transactions you carry out through our Website or Services and of the fulfillment of your orders; and
• your search queries on our Website.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website; and
• information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with Personal Information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Services, including by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Website according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies): a cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies: certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons: pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• to present our Website and its contents to you;
• to provide you with information, products, or Services that you request from us;
• to conduct an analysis of the suitability of a proposed investment in a fund for which 3iQ acts as a portfolio manager or investment fund manager (a “Fund”);
• to process your subscription for Fund securities, opening or servicing your account;
• to develop an Investment Policy Statement under a Portfolio Management Agreement;
• to complete books and records information for the Funds or managed accounts;
• to verify your identity;
• to fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it;
• to provide you with notices about your account, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
• to notify you about changes to our Website or any products or Services we offer or provide though it;
• to improve our Website, products or services, marketing, or customer relationships and experiences;
• in any other way we may describe when you provide the information; and
• for any other purpose, with your consent.

We may also use your information to send you communications by mail, email or telephone or to promote our Funds or other products and Services that may be of interest to you. You can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting us as set out under Contact Information section below. Please note that clients may continue to receive certain transactional or informational electronic communications from us after opting out.

Disclosure Of Your Information

We may disclose Personal Information that we collect or you provide as described in this Policy:

• To the relevant Canadian securities regulatory authorities. Your Personal Information, including the number of and purchase price for Fund securities purchased, may be disclosed and become available to the public in accordance with the requirements of applicable securities and freedom of information laws. You authorize such indirect collection of your Personal Information and acknowledge that: (i) the Personal Information is being collected indirectly by the applicable Canadian securities regulatory authority under the authority granted to it in securities legislation; (ii) the Personal Information is being collected for the purposes of the administration and enforcement of applicable Canadian securities legislation; and (iii) you have been notified of the title, business address and business telephone number of the public official in your jurisdiction.
• To our subsidiaries and affiliates and other third parties in Canada and the U.S. who provide Services on our behalf. 3iQ may use service providers to verify Personal Information (such as identity and bank account number), administer the Funds or managed accounts, send email or other communications, or manage and analyze data. In the event Personal Information is transferred to the U.S. or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Service providers are given the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes. They are also contractually bound to keep your Personal Information confidential and to comply with privacy laws.
• In accordance with applicable laws, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our customers and users is among the assets transferred.
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Policy.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information, with your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 3iQ Corp., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Transferring Your Personal Information

We may transfer Personal Information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to process the Personal Information with the same standards set out in this Policy.

We may process, store, and transfer your Personal Information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your Personal Information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation.

You are welcome to contact us to obtain further information about our policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.

By submitting your Personal Information or engaging with the Website and our Services, you consent to this transfer, storage, or processing.

Data Security

The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

Accessing And Correcting Your Personal Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes.

By law, you have the right to request access to and to correct the Personal Information that we hold about you. If you want to review, verify or correct your personal information, you may send us an email at dianaeb@3iq.io to request access to, correction, or deletion of any Personal Information that you have provided to us. We may not accommodate a request if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the Personal Information that we hold about you or make your requested changes. Applicable laws may allow or require us to refuse to provide you with access to some or all of the Personal Information that we hold about you, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

• information protected by solicitor-client privilege;
• information that is part of a formal dispute resolution process;
• information that is about another individual that would reveal their Personal Information or confidential commercial information; and
• information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at dianaeb@3iq.io.

Withdrawing Your Consent

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at dianaeb@3iq.io. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

Changes To Our Privacy Policy

It is our responsibility to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page.

We include the date the Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this Policy to check for any changes.

Contact Information

We welcome your questions, comments, and requests regarding this Policy and our privacy practices. Please contact us at:

3iQ Corp.

To the attention of the Privacy Officer
161 Bay Street
Suite 2700
Toronto, Ontario
Canada M5J 2S1

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact our Privacy Officer using the contact information listed above.