The Personal Information Protection and Electronic Documents Act (PIPEDA or the Act) regulates the way private sector organizations collect, use and disclose personal information. It does not apply to either corporate or not - for - profit organizations. Its main objective is to ensure the personal information collected is used for its stated purpose, and to safeguard such information.

PIPEDA explicitly stated purpose is: To govern the collection, use and disclosure of personal information by private sector organizations in a manner that recognizes both the right of the individual to have his or her personal information protected and the need of organizations to collect, use and disclose personal information for purposes that a reasonable person would consider appropriate.

“Personal Information” is defined as information about an "identifiable individual". This includes such things as, income, net worth, education, home address and phone number. It does not cover general contact information such as name, title, business address, business phone number.

Information that a Dealing Rep with Axcess has collected for completion of the Know Your Client (KYC) Application Form is subject to the requirements of PIPEDA. We recognize the importance of privacy and recognizes the sensitivity of personal information received by it in the conduct of its business. This policy has been prepared with this objective in mind.

The need for Personal Information: We collect Personal Information from clients to meet certain regulatory requirements, to ensure clients meet applicable exemptions as identified under securities regulations, and to help us evaluate the suitability of the securities we have transacted for your account. This information will necessarily include personal information about our clients and, in certain cases, about individuals, other than our clients (e.g. information on person with trading authority.)

Collection, Use and Disclosure of Personal Information: Where practical, We will try to collect personal information directly from the person to whom the information pertains. However, where appropriate, we may collect personal information from publicly available sources. We will collect only the personal information necessary for the purposes stated in the section titled, “The Need for Personal Information.”

PIPEDA provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.

By transacting through a Registered Dealing Rep with Axcess Capital, we consider that you have consented to our collection, use or disclosure of personal information as necessary, to properly represent you in these financial and investment matters. Where necessary to fulfil our regulatory obligations, we may collect personal information about individuals, other than our clients, in accordance with the provisions of the Act.

When we collect personal information about individuals directly from them, except in situations when their consent to the collection is deemed, we will advise them of the purpose for which the information is collected. Obtaining consent from the individual after disclosure of the purpose for which the personal information is collected, used and disclosed, is a key element of the Act. However, this obligation is not absolute.

PIPEDA also permits us to collect, use or disclose personal information about an individual in some circumstances without the individual’s consent. Such circumstances include (but are not limited) to where:

• the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timelyway;

• collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;

• the personal information is available to the public from a prescribed source; or

• the collection, use, or disclosure is required or authorized by a Federal or Provincial statute or regulation.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. PIPEDA also allows us, for legal or business purposes, to retain personal information for as long as is reasonable, but also imposes obligations upon us to ensure that procedures are in place to destroy the personal information when it is no longer required.

The transactions processed through a Registered Dealing Rep with Axcess are subject to the regulations of the various securities commissions. As part of these regulations, these securities regulators conduct reviews of the transactions completed by Axcess, and may contact you directly for information or confirmation of your investment activities conducted through Axcess. Accordingly, you should file all information received from Dealing Reps at Axcess where it is easily accessible to respond to any such inquiries.

Security of Personal Information: We recognize our professional and legal obligations to protect the confidential information of our clients and to protect the personal information we have gathered about our clients and about other individuals during the course of our business. We have implemented policies and procedures to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.