BRISTOL GATE CAPITAL PARTNERS INC.

Privacy Policy

At Bristol Gate Capital Partners Inc. (the “Company”) we are committed to protecting your privacy and the confidentiality of personal information that is shared with us by our Clients. The Company complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) in Canada, U.S. Securities and Exchange Commission (SEC) Regulation S-P, and other applicable regulations, which require us to adopt policies and procedures to protect personal information of Clients and to disclose to the Clients such policies and procedures. This policy sets out the information practices for the Company, what kinds of information are collected, how the information is used and with whom this information might be shared.

  1. Accountability: The Company is responsible for all personal information provided by Clients under its control. Employees involved in collecting, disseminating and maintaining personal information are trained in all aspects of this Privacy Policy. The Company has appointed a Privacy Officer who is responsible for the implementation of this policy. Any questions or concerns you have may be addressed to the Privacy Officer.
  2. Identifying the purposes and uses of personal information: When you apply to open an account with the Company we may collect the following personal information about you, including, but not limited to, social security numbers, financial information, know-your-client requirements, identification questions or documentation that allow us to fulfil our anti-money laundering obligations as they apply to us.

This information is collected and used for the following purposes:

(i) To meet the account opening requirements of a custodian or bank;

(ii) To verify the basis of our understanding of your investment goals and objectives and help us determine the appropriate investments for you;

(iii) To document which other persons or professional advisors may have access to your account information and/or provide investment instructions to us on your behalf;

(iv) To allow the Company to satisfy itself about the information it reports regularly with respect to legislation on money laundering, fraud and other criminal activity;

(v) To allow the Company to prepare and distribute information to tax authorities;

(vi) To report to certain government securities regulators, as required, about the investment practices and operating procedures of the Company and to allow such regulatory agencies to conduct periodic compliance audits of the Company; and

(vii) To manage and assess the risks posed to the Company.

Clients who have invested in Bristol Gate’s prospectus-exempt fund offerings (the “Fund” or the “Funds”) should be aware that each applicable Fund is required to file with each relevant Canadian securities regulatory authority a report setting out the Subscriber’s name and address, the class and series of Units issued, the date of issuance and the purchase price of Units issued to the Subscriber. Such information is collected indirectly by such regulatory authorities under the authority granted to them in securities legislation, for the purposes of the administration and enforcement of their governing securities legislation. By submitting a subscription for each applicable Fund, the Subscriber authorizes such indirect collection of the information by each such regulatory authority. The following officials can answer questions about the indirect collection of the information:

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A variety of personal information pertaining to the operations of an investment account (security purchases and sales, deposits, withdrawals and security transfers) will develop over time. This information could be saved on proprietary and third-party service provider systems.

For legal entities such as businesses, trusts, partnerships or estates we will collect information about the legal structure of the entity and information about those individuals authorized to act on the entity’s behalf. Where necessary, we will establish beneficial owners of any of these entities.

The Company does not sell, rent or lease its customer lists to any third party. However, the Company engages third party service providers, most notably a custodian or bank, registered investment dealers, legal and accounting professionals and computer systems support. When your information is provided to these service providers the Company will require them to protect your information in a manner that is consistent with this Privacy Policy and practices. Some of these third parties may be located outside of Canada or the U.S. Personal information given to the Company or any of its service providers may be accessible to regulatory authorities in accordance with the laws in those jurisdictions.

If we sell the Company or enter into an acquisition or merger agreement with another company, we may release the information it has about you to prospective purchasers. We will require any prospective purchaser to protect the information provided consistent with the Company’s privacy policies and practices.

To help us keep our records of your personal information accurate, we ask that you notify us of any changes or corrections to your personal information in a timely manner.

  1. Consent: The Client will consent in writing to the provision of such personal information to the Company. This policy shall be attached to the account opening documents executed for the Client. By retaining the services of the Company, the Client will have consented to the disclosure of his or her personal information to various third parties as outlined in this policy and for the purposes set out in it.

A Client may withdraw or withhold his or her consent at any time, subject to any legal or contractual restrictions. Such action shall be made in writing by the Client, at which time the consequences of such withdrawal or withholding of personal information will be explained by the Company.

The Company will typically collect personal information from Clients in the process by which accounts are opened or are reviewed. However, it will also collect information from Clients through personal meetings, telephone discussions, e-mail and facsimile transmissions and also from third party service providers involved in supporting the Company’s services. Records of these interactions may be kept by the Company.

The Company may use your e-mail address to communicate with you about privacy issues you raise and may send you information about products and services it offers or may offer in the future based upon an analysis of the personal information you provided. E-mails sent over the internet are generally not encrypted.

  1. Limitation of use and retention of information: The Company will collect only that personal information which is required by it to meet its regulatory, statutory and business management needs to manage a Client’s financial assets according to the agreed investment policy, as outlined in this policy. The Company will retain personal information only for the purposes of this policy and for meeting government and regulatory requirements, after which it will be destroyed or rendered anonymous.

A prospective Client, who does not enter into a portfolio management services agreement with the Company shall have returned to him or her all personal information provided to the Company.

Every effort will be made by the Company to maintain correct data and from time to time Clients may be asked to verify that information.

  1. Safeguards: We seek to carefully safeguard your private information and, to that end, restrict access to personal information about you to employees and other persons who need to know the information to enable us to provide services to you. Each employee of the Company is responsible for ensuring the confidentiality of all personal information they may access.

Your personal information is maintained on our secure computer networks and office files. The Company’s physical office space is secure and accessible only by authorized personnel who have keys and/or electronic access cards. Your information may also be stored in a secure off-site storage facility. A variety of security measures will be in place to reduce the possibility of theft of personal information or accidental disclosure.

You may access your personal information to verify its accuracy, to withdraw your consent to any of the foregoing collections, uses and/or disclosures being made of your personal information and may update your information by contacting the Company.

Clients shall be able to deal directly with the Privacy Officer to express any concerns, at no additional cost to the Client. The Privacy Officer may be reached by telephone at (416) 921-7076 ext 240, through e-mail at privacyofficer@bristolgate.com or by letter to the Company’s offices. All Client concerns shall be documented and maintained in a written (and electronic) file. The Company will use commercially reasonable efforts to promptly determine and rectify the problem.

There are circumstances in which the Company may use personal information without the Client’s knowledge or consent. These circumstances include: (1) when the Company has reasonable grounds to believe the information might be useful when investigating a contravention of a federal, provincial or foreign law; (2) during an emergency which threatens an individual’s life, health or security; or (3) when mandated to provide such information by any federal, provincial or foreign law or regulation.

The Company has a right to refuse access to personal information by a Client if: (1) the information is protected by legal privilege; (2) the information was collected for purposes related to the detection and prevention of fraud; (3) the information was generated in the course of a formal dispute resolution process; (4) granting access might reveal confidential commercial information; (5) it is reasonably expected that such personal information might lead to the threatening of the life or security of another individual.

  1. Use of information collected via the Internet: If you use the internet to communicate with us or access our website, certain information about your computer may be automatically generated, collected or logged by web servers. This information may include the internet protocol address assigned to your computer by the internet service provider, the type of browser you are using, the general location of your computer, and web pages visited. Our website may use “cookies” which help customize the site for visitors by storing the information that users provide. We may use this information to monitor website usage, resolve technical issues and improve website functionality.

When you voluntarily submit information through the submission form on our website, you are submitting personal information. This may include names, email addresses, phone numbers, addresses and company information. When submitting personal information through our submission form, you are expressly consenting to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

  1. Notices regarding this Privacy Policy to Clients: The Company will occasionally update this policy to reflect Client feedback, regulatory changes and Company experience. The Company will provide initial notices to Clients upon account opening and annually thereafter.