3iQ Privacy Policy

Last updated: January 14, 2022

1.

SCOPE OF POLICY

1.1

3iQ Corp (“3iQ”, the “Firm” or “we”) is committed to protecting its investors’ privacy. 3iQ has adopted this privacy policy (the “Privacy Policy”) which will apply to all Personal Information (defined below) which we gather about our clients and our directors, officers and employees in the course of conducting our business.

2.

COLLECTION AND USE OF PERSONAL INFORMATION

2.1

In the course of our provision of investment management services to clients, 3iQ collects information about such clients and their beneficial owners (“Personal Information”) including residential address, telephone number, e-mail address, social insurance number, bank account numbers and other “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.

2.1.1

Personal Information is used for the following purposes:

(a)

conducting 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”);

(b)

processing the subscription for Fund securities, opening and servicing the account;

(c)

developing an investment policy statement under an investment management agreement;

(d)

verifying identity and other information provided to 3iQ (including bank account);

(e)

if applicable, reporting the investment to the relevant securities regulatory authority;

(f)

completing books and records information for the Funds or managed accounts;

(g)

detecting and preventing fraud and other unauthorized or illegal activities;

(h)

meeting other legal and regulatory requirements;

(i)

managing 3iQ’s business relationship with clients; and

(j)

establishing, exercising or defending legal rights.

2.1.2

3iQ may use Personal Information to send client communications by mail, email or telephone marketing or to promote its Funds or other products and services that may be of interest to clients. Clients can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting 3iQ as set out under Contact Us below. Please note that clients will continue to receive certain transactional or informational electronic communications from 3iQ after opting out.

2.1.3

3iQ will not collect, process, store or otherwise use this Personal Information without consent. When obtaining client consent, 3iQ will inform clients about the purposes of collecting this Personal Information, which includes but is not limited to the below. 3iQ will only use Personal Information for the purposes for which it was collected and were communicated to the client, unless 3iQ reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose.

2.1.4

If any client wishes to get an explanation as to how the processing for the new purpose is compatible with the original purpose, they may do so by emailing or writing to 3iQ at the contact information set out below.

2.1.5

If 3iQ needs to use Personal Information for an unrelated purpose, it will collect the client’s consent if required or will notify them and will explain the legal basis which allows 3iQ to do so.

3.

HOW PERSONAL INFORMATION IS COLLECTED

3.1

3iQ collects Personal Information directly from clients (such as information provided in the subscription agreement or account-opening documents).

4.

DISCLOSURE OF PERSONAL INFORMATION

4.1

3iQ will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein.

4.1.1

Exempt Trade Report: Clients’ Personal Information, including the number of and purchase price for Fund securities purchased, may be disclosed to the relevant Canadian securities regulatory authorities and become available to the public in accordance with the requirements of applicable securities and freedom of information laws. Clients authorize such indirect collection of the 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) clients have been notified of the title, business address and business telephone number of the public official in their jurisdiction in the subscription agreement.

4.1.2

3iQ Group: Personal Information may be transferred (or otherwise made available) to other members of the 3iQ group or other branches of 3iQ.

4.1.3

Service Providers: Personal Information may be transferred (or otherwise made available) to 3iQ’s affiliates and other third parties in Canada and the U.S. who provide services on 3iQ’s 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.

4.1.4

Legal/Compliance: 3iQ, its affiliates and other service providers may provide Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, U.S., U.A.E. or other law. Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

4.1.5

Sale of Business: Personal Information may be transferred as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of 3iQ’s business or as part of a corporate reorganization or stock sale or other change in corporate control.

5.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF U.A.E.

5.1

Some countries outside the U.A.E. have legal frameworks that provide the same level of protection of Personal Information as the U.A.E. or have acceded to bilateral or multilateral agreements regarding Personal Information with the U.A.E. This allows transfers of Personal Information to be made to these countries without the need for putting additional safeguards in place. Where a country has not been identified as having an adequate level of protection, 3iQ will ensure that suitable safeguards are in place before it transfers client Personal Information to such countries.

5.2

3iQ will also ensure that the client has provided their consent for their Personal Information being transferred outside the U.A.E.

5.3

For more information about these suitable safeguards and how to obtain a copy of them or to find out where they have been made available, clients may email or write to 3iQ at the contact information set out below.

6.

SAFEGUARDS AND RETENTION

6.1

3iQ has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in its custody and control against theft, loss and unauthorized access, use, modification and disclosure. 3iQ restricts access to Personal Information on a needto-know basis to employees and authorized service providers who require access to fulfil their job requirements. 3iQ has record retention processes designed to retain Personal Information of its clients for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of a client’s relationship with 3iQ).

7.

ACCESS TO PERSONAL INFORMATION

7.1

Clients have the right to access, update and correct inaccuracies in their Personal Information in 3iQ’s custody and control, subject to certain exceptions prescribed by law. Clients may request access, updating and corrections of inaccuracies in Personal Information in 3iQ’s custody or control by emailing or writing to 3iQ at the contact information set out below. 3iQ may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.

8.

WITHDRAWAL OF CONSENT

8.1

Clients have the right to withdraw their consent to their Personal Information being collected, processed, stored, or used, and may do so at any time by emailing or writing to 3iQ at the contact information set out below. Please note that any processing of Personal Information that 3iQ undertook prior to the withdrawal of consent remains lawful.

9.

CHANGES TO THE PRIVACY POLICY

9.1

This Privacy Policy may be updated periodically to reflect changes to 3iQ’s Personal Information practices. 3iQ will provide clients with an updated copy of its Privacy Policy annually or more frequently upon request.

10.

CONTACT US

10.1

Clients may contact 3iQ’s Privacy Officer with any questions or comments about this Privacy Policy, or to obtain access, update, and/or correct inaccuracies in Personal Information, or otherwise with any question or complaint about the manner in which 3iQ or its service providers treat Personal Information at the following contact information:

10.1.1

Ashley Peters

privacy@3iq.ca

Fred Pye

Frederick T. Pye

CHAIRMAN, CHIEF EXECUTIVE OFFICER & DIRECTOR

Frederick T. Pye is the Chairman, Chief Executive Officer and Director of 3iQ Corp. He is also the Chairman and Director of 3iQ Digital Holdings Inc. Mr. Pye is recognized for creating and promoting creative and unique investment products for the investment industry.

Mr. Pye has managed private client portfolios with Landry Investment Management and various other investment dealers. Prior to this Mr. Pye was Founder, President & Chief Executive Officer of Argentum Management and Research Corporation, a company dedicated to managing and distributing quantitative investment portfolios including the first long-short mutual fund in Canada.

He was also Senior Vice-President and National Sales Manager of Fidelity Investments Canada and an integral part of the team that saw assets rise from $80 million to over $7.5 billion in assets under management during his tenure. He also held various positions with Guardian Trust Company, which listed the first Gold, Silver and Platinum Certificates on the Montreal Exchange.

Mr. Pye obtained a Masters in Business Administration from Concordia University.