Zelos will comply with the requirements imposed under Canada’s federal privacy law, the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and its provincial privacy law, Personal Information Protection Act (“PIPA”) as applicable.

Collecting Personal Information
(a) Zelos shall identify the purpose for which information is being collected from clients either before the information is requested or as it is being requested.
(b) Unless consent is not required by law, securities regulation, or the regulations of a self-regulatory organization, Zelos shall obtain the client’s consent to the collection, use, or disclosure of personal information.
(c) Zelos shall only collect client information by lawful means and only to the extent required to satisfy the purpose for which the information is being collected was identified.

Consent
The form of consent sought by the Firm may vary, depending upon the circumstances and the type o finformation. In determining the form of consent to use, Zelos shall take into account the sensitivity of the information.
Zelos should generally seek express consent when the information is likely to be considered sensitive.
Implied consent would generally be appropriate when the information is less sensitive. Consent can also be given by an authorized representative (such as a legal guardian or a person having power of attorney) subject for approval.

Using Personal Information
(a) The client information collected by Zelos shall be accurate and complete and as up-to-date as is necessary to fulfill the purpose for which it was collected.
(b) The client information collected shall only be used for the purposes provided in the consent and to the extent reasonable for that purpose.

Disclosing Personal Information
(a) Zelos shall only use or disclose the information collected for the purpose identified unless the client consents or where disclosure or use is required by law, securities regulation, or the regulations of a self-regulatory organization.
(b) Zelos shall make available to clients copies of the policies and practices that apply to the management of investor information by Zelos.
(c) Upon request and unless prohibited by law, securities regulation, or the regulations of a self-regulatory organization, clients will be given access to their information and shall be informed of any use made of the information or disclosure of the information to any third parties.

Protecting Personal Information
(a) All client information under the control of Zelos shall be kept confidential except where disclosure is required by law, securities regulation, or the regulations of a self-regulatory organization.
(b) Zelos shall only retain the information collected for so long as is required to satisfy the purpose identified or as required by law, securities regulation, or the regulations of a self-regulatory organization.
(c) Zelos shall protect client information with such safeguards as are appropriate to the sensitivity level of the information.