3iQ Privacy Policy

Scope of Policy

3iQ Corp. (“3iQ”, “our”, “us” or “we”) is committed to protecting its users’ privacy. This privacy policy (the “Privacy Policy”) is intended to help you understand our practices regarding the collection, use, disclosure and retention of your Personal Information (as defined below). By providing us with Personal Information through our website at https://3iq.io/ (the “Website”) or by communicating with us, you agree to its processing as set forth in this Privacy Policy, and you authorize 3iQ, its third parties and service providers to process your personal information for the purposes set forth below.

As a digital asset management firm, we collect, use and disclose data, including Personal Information in order to offer you the services on our Website. If you do not consent to us collecting, using, or disclosing your Personal Information in accordance with this Privacy Policy, please do not provide Personal Information to us. Note that you may not be able to use our Website and certain features or services without sharing your Personal Information.

You may withdraw your consent at any time by contacting our Privacy Officer using the contact information provided in the “Contact Us” Section.

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Collection and Use of Personal Information

When you use our Website or communicate with us in the course of our provision of investment management services, we collect information about you and your beneficial owners (“Personal Information”). We may collect and process different types of personal information while providing our services and operating our business, including:

• Information relating to your identity, including your 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;
• Information about your activities on our Website, such as the pages you visit, your interactions with our content, or other technical information collected through analytics technologies;
• Information regarding to your marketing and communication preferences;
• Any other Personal Information you provide us.
  

Any Personal Information you provide us will be treated in accordance with this Policy. If you provide us with Personal Information about other individuals, you must notify them and obtain their consent.

We do not knowingly collect information from children under the age of 14. If you are a minor under the age of 14, please do not provide us with any Personal Information without the express consent of a parent or guardian.

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How Personal Information is Collected

We collect your Personal Information directly from you and during our interactions with you (such as information provided in the subscription agreement or account-opening documents), as well as during your interactions with our Website, subject to the data that you freely decide to transmit to us.

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How Personal Information is Used

We use your Personal Information to fulfil objectives of our Website and to provide and improve our services, including:

• delivering the products and services you have requested;
• 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”);
• processing the subscription for Fund securities, opening and servicing the account;
• developing an Investment Policy Statement under a Portfolio Management Agreement;
• verifying identity and other information provided to 3iQ (including bank account);
• if applicable, reporting the investment to the relevant securities regulatory authority;
• completing books and records information for the Funds or managed accounts;
• detecting and preventing fraud and other unauthorized or illegal activities;
• for marketing and business development purposes;
• for research and development, to carry out analysis to better understand our users’ services and marketing needs, and to better develop our offers and services;
• to respond to inquiries or other requests from visitors on our Website;
• for any other compatible secondary purpose;
• for other purposes, with your consent or in accordance with applicable laws; and
• for meeting other legal and regulatory requirements.
  

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 section below. Please note that clients will continue to receive certain transactional or informational electronic communications from 3iQ after opting out.

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How Personal Information is Shared

3iQ will not share, disclose, trade, rent, sell or otherwise transfer Personal Information, without consent except as otherwise set out herein. We will only use Personal Information for the primary purposes and applicable legitimate purposes for which it was collected, or for purposes consistent with the primary purposes.

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‍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.

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‍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. They are also contractually bound to keep your Personal Information confidential and to comply with privacy laws.

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‍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. 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.

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‍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.

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How Personal Information is Stored

3iQ has implemented generally accepted industry best-practices and standards (including 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 need- to-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).

Given the inherent risks of data transmission over the Internet, we are not responsible for data in transit and cannot be held liable for any misappropriation, interception, modification, deletion, destruction or use of data provided via our Website.

If you have reasons to believe that any Personal Information has been compromised, please contact us as set forth below in the “Contact Us” section.

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How Long Personal Information is Retained

We will retain Personal Information for as long as necessary for the purposes set out in this Policy and to comply with our legal and regulatory obligations.

For more information, you can contact us as set out in the “Contact Us” section below.

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What your Rights are Regarding your Personal Information

Under certain circumstances and in accordance with applicable data protection laws, you have the following rights:

• Access: you have te right to ask whether we hold Personal Information about you and the right to access that information.
• Rectification: you have the right to request rectification of any incomplete or inaccurate Personal Information we hold about you.
• Withdrawal of Consent: you have the right to withdraw your consent to the disclosure or use of Personal Information collected.
• Destruction: you have the right to request the destruction of the Personal Information we hold about you.
• Request for Information: you have the right to request certain information relating to decisions based exclusively on the automated processing of Personal Information.

Changes to this Privacy Policy

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. The collection, use, disclosure and processing of your Personal Information by 3iQ are governed by the current version of this Privacy Policy.

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Contact Us

If you have any questions or comments about this Privacy Policy or your Personal Information or if you wish to exercise your rights, file a complaint or obtain information about our policies and practices, please contact our Privacy Officer by e-mail at dianaeb@3iq.ca or by mail at the following address:

3iQ Corp. To the attention of the Privacy Officer
161 Bay Street, Suite 2700
Toronto, Ontario
Canada, M5J 2S1