PRIVACY POLICY OF BOLDER INVESTMENT PARTNERS LTD.
Bolder and Your Privacy
Bolder Investment Partners, Ltd. considers your personal privacy to be an important part of our service to you.
We understand the need to safeguard information about you that you have entrusted to us.
As part of our commitment to you we have adopted principles designed to protect your privacy and prevent misuse
of your personal information and help you understand our commitment to your personal privacy.
References to "Bolder", "we" or "our" are to Bolder Investment Partners, Ltd., depending upon the context.
Where we use the term "personal information" we are referring to any information that identifies you as an
individual and includes information with respect to your name, address, age, gender, income, marital status,
finances, employment and trading history, together with your personal references and identification numbers
(such as a social insurance number).
Our privacy policy applies to personal clients, including individuals carrying on business alone or in partnership with other individuals.
The following sections will answer most of the important questions that you may have about how we gather, protect and
use personal information, and how we will hold ourselves accessible and accountable to you.
Bolder's Principles on Privacy
We have incorporated certain principles for the protection of personal information in our privacy policy.
Collecting and Using Personal Information
We will explain how we intend to use your personal information prior to or when we are collecting it and we will limit the
personal information we collect to what we need for those purposes. We will use it only for those purposes we have
explained to you and we will obtain your consent if we wish to use your personal information for any other purpose.
Disclosing Personal Information to Others
We may provide your personal information to other persons not affiliated with Bolder, such as regulators, service providers
or credit reporting agencies, but only where we have your consent or wherewe are required or permitted to do so by law.
Retaining and Protecting Personal Information
We will retain your personal information only for the time it is required for the purposes we explain or as otherwise required by law.
We will protect the personal information we obtain about you with appropriate safeguards and security measures.
Access and Accuracy
We will provide you with reasonable access to your personal information on record with Bolder and information about Bolder's use and
disclosure of that information. We will make every reasonable effort to keep your personal information accurate and up-to-date.
Accountability and Openness to Your Privacy Concerns
We will hold ourselves accountable to you and we will investigate and respond to your concerns about any aspect of our handling of your
personal information. We will explain the application of our privacy policy to your personal information and explain your options of
refusing or withdrawing consent to the collection, use and release of your personal information, and we will record and respect your choices.
Why Does Bolder Collect Personal Information?
We collect, retain, and use personal information about you only when we reasonably believe that it will help administer our business or
provide products, services and other opportunities to you as our client. We collect and retain personal information about you only for
specific business purposes - and we will tell you why we are collecting and retaining it on your request. The information we ask for
depends on the products or services you request and in most cases are required by law or the policies of the regulatory bodies which we are
subject. Your social insurance number is required for products that earn investment income, in order to comply with the Canada Customs and
Revenue Agency's income reporting requirements. Providing your social insurance number for credit reporting purposes is optional. If you
provide your social insurance number, we also use it to keep your personal information separate from that of other clients with a similar name,
including information we obtain with your consent through the credit approval process. Health information may be required for some insurance
products to ensure you are eligible for coverage. Health information that may have been provided in connection with any insurance product is never
shared.With your consent, we may share your personal information, where not prohibited by law. Bolder may use your personal information to provide
you with information about Bolder's products and services and other matters. This consent is optional and you can decide to withdraw it at any time.
Please refer to our section regarding your options below.
How Does Bolder Collect Personal Information?
We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties.
For credit or margin purposes, for example, we may need to know your creditworthiness. For this reason, we may contact other lenders or credit
reporting agencies to give us information on your credit history. We may also contact references you have provided to verify information that
you have given us. We will not do this without your consent, but please remember that if you do not give your consent we may not be able to
extend credit or margin services to you.
When Does Bolder Release Personal Information?
Bolder does not sell client lists or personal information to others.We do not reveal personal information about you to parties outside our affiliated
companies for their independent use unless you request or authorise it, the information is provided in order to complete a transaction initiated by
you or the disclosure otherwise is lawfully permitted or required. We may disclose information to the authorities to serve a clear public interest
and fulfil our public duty - such as to protect against fraud, money laundering or other criminal activity. We may, from time to time, be requested
to disclose information to securities regulatory and securities oversight organisations to which we are subject such as the Investment Dealers
Association of Canada, or RS Market Regulation Services Inc. for the purposes of an audit or investigation relating to specific accounts or
our business generally. In certain circumstances, Bolder may disclose your personally identifiable information if it believes, in good faith,
that disclosure is otherwise necessary or advisable to protect its interests.Sometimes it is necessary to provide personal information about you
to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare your account
statements or to provide support or services for one or more of our products. These vendors and service companies agree to safeguard confidential
information about you and your products and services with us and must abide by applicable law.
Does Bolder Provide Options?
It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from
third parties. In many cases you are free to refuse or withdraw your consent at any time. If you choose not to provide requested personal information
or consents, we may not be able to provide certain products and services to you or you may be ineligible for or be unable to use certain products and
services we provide. For example, you may refuse consent for us to do a credit check, but we may not be able to extend credit or margin services to you.
Bolder will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record
and respect your choices. If you wish to discuss your options you may do so by contacting Bolder's designated privacy officer set out below, or
contacting our Compliance Department. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.
How Long Does Bolder Retain Personal Information?
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time
we retain information varies depending on the product or service and the nature of the information and may extend beyond the end of your
relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may
arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an
anonymous form.
How Does Bolder Protect Personal Information?
Bolder stores and processes your personal information in Vancouver, British Columbia, Canada. Certain personal information about you is retained
by Bolder.We maintain security standards and procedures to help prevent unauthorised access to confidential information about you. Our security
standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity
of our personal information.We have procedures that limit employee access to personally identifiable information to those employees with a business
need to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard
operating procedures, special training programs, and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.
All our suppliers and agents, as part of their contracts with Bolder, are bound to maintain your confidentiality and may not use the information for
any unauthorised purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we
disclose only the information that is required - otherwise we will seek your consent prior to disclosing any information.
What about E-Mails?
When you send us an e-mail or when you ask us to respond to you by e-mail, we learn your exact e-mail address and any information you have
included in the e-mail. We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your
communication and our reply in case we correspond further. We will not sell your e-mail address to anyone outside of Bolder. We may use
your e-mail address to send you information about our products or services that we believe may be of interest to you. If you don't want
us to contact you with product information by e-mail, you may tell us so at any time. Remember e-mail over the Internet is generally unencrypted.
We recommend that you do not send us sensitive or confidential information by ordinary email, as unencrypted email is generally not secure.
How Do I Access My Personal Information?
You may request access to your personal information on record with Bolder and information about Bolder's use and disclosure of that information
by contacting your investment advisor or by contacting the Chief Operating Officer. We will advise you in advance if a minimal charge will be required
for conducting the search, and we will respond to your request promptly but in any case within 30 days. Please note that we may not be able to provide
information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to
Bolder, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine
actions.If you have any questions regarding decisions made about you, we will tell you the reasons for those decisions. Where relevant, we will provide
you with the name and address of the credit reporting agency from which a report was obtained.
How Do I Keep My Personal Information Accurate?
Bolder attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by
notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make
the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will
note your opinion in the file.
Who Should I Contact Regarding Privacy Issues?
Bolder has designated a privacy officer, W.R. (Bill) Wright to respond to your concerns or questions about privacy and confidentiality -
or any concerns about the way a request for personal information was handled.
To reach our privacy officer, please refer to the following in writing, at:
1450 Creekside Dr.
Suite 800
Vancouver, British Columbia
V6J 5B3
by telephone, at 604-714-2315,
or toll free at 1-877-826-5337
by facsimile, at 604-714-2301; or
by e-mail, at bwright@bolder.net.
Your concerns will be passed on to the appropriate Compliance personnel at Bolder so that further action is taken to resolve the matter, if necessary.