Privacy Policy

Private sector companies and organizations in Canada that collect, use and disclose personal information in the course of commercial business must comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Personal Information means any information about an identifiable individual that is recorded in any form. Gross Securities observes the ten principals set out in PIPEDA as outlined below.

Accountability Gross Securities is responsible for personal information under its control and has designated individuals to effectively safeguard any confidential personal information that Gross Securities has on file or collects, and to deal with complaints and inquiries. If Gross Securities transfers any personal information to a third party for processing, it will use appropriate contractual or other means to provide a comparable level of protection while the information is being processed by the third party.

Identifying Purposes The purposes for which Gross Securities collects personal information shall be identified at or before the time the information is collected. Gross Securities collects personal information pursuant to its legal and professional obligations to ensure that it has all personal information about its Investors necessary and required to execute on their behalf.

Consent The knowledge and consent of the individual is required for the collection, use or disclosure of the personal information, except where inappropriate, impossible or impractical to do so. Investors must be aware and understand the purpose for which the personal information is being used for the consent to have meaning.

Limiting Collection The collection of personal information by Gross Securities shall be limited to what is necessary. The personal information being collected shall be collected using procedures that are fair and lawful.

Limiting Use, Disclosure, and Retention – Personal information obtained by Gross Securities shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will only be retained as long as necessary for the fulfillment of the purpose it was collected for in the first place.

Accuracy Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Safeguards Security measures are in place to protect personal information against loss or theft. The safeguards in place depend on the sensitivity of the personal information being protected.

Openness Gross Securities will ensure Investors have access to information pertaining to the procedures used to manage their personal information.

Individual Access – Investors may make a request in writing for access to their personal information. Gross Securities will inform the Investor of the Investors personal information it holds and provide an account of the use that has been made of this information, as well as identify any third parties to which the information has been disclosed. Reasonable access to the Investors personal information will be granted, and if the Investor demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required.

Challenge Compliance Any individual who requires more information, or would like to make an inquiry, suggestion or complaint regarding Gross Securities personal information practices or to challenge Gross Securites compliance with these principles, should contact Gross Securities at An investigation will be launched and where a complaint or challenge is found to be justified, Gross Securities will take appropriate measures, including amending its policies and procedures, when necessary.