Marketing Privacy Statement

Introduction

At Kingsdale Advisors (“Kingsdale”), we are committed to protecting your privacy rights. This Privacy Statement applies specifically to personal information collected through our marketing activities, including when you download case studies, whitepapers, or thought leadership content from our website, or submit your information through LinkedIn lead generation forms. For information about how we handle personal information in connection with our advisory, proxy solicitation, depository, and other client services, please refer to our General Privacy Policy.

This Privacy Statement describes how we collect, use, store, and protect personal information obtained through our marketing channels. Kingsdale is accountable for compliance with applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada’s Anti-Spam Legislation (CASL), with respect to personal information under our control. Our employees receive training on our privacy procedures and the safeguarding of personal information.

What is Personal Information?

Personal information is any information about an identifiable individual, as defined under PIPEDA. This includes, but is not limited to, your name, email address, phone number, job title, and company name. However, personal information does not include the name, title, business address, or business telephone number of an employee of an organization in their capacity as an employee (the “business contact information” exception under PIPEDA).

Through our marketing activities, Kingsdale collects personal information when you download case studies, whitepapers, or thought leadership content from our website, when you submit your information through LinkedIn lead generation forms, when you register for seminars, webinars, or other events, when you subscribe to our newsletters, or when you email us with inquiries. The personal information we collect for marketing purposes may include your name, email address, phone number, job title, and company name.

How does Kingsdale use Personal Information?

Kingsdale collects and uses personal information obtained through our marketing channels for the following purposes:

• To provide you with information on Kingsdale’s services, thought leadership content, case studies, and events that we believe may be of interest to you.
• To send you marketing materials, newsletters, event invitations, and other updates about our services, where you have provided your express consent.

If we wish to use your personal information for any purpose not described in this Privacy Statement, we will obtain your consent before doing so. We do not sell, rent, or share your personal information with third parties for their own marketing purposes.

We have internal policies and procedures regarding the use, disclosure, and retention of personal information. Personal information collected for marketing purposes is retained for as long as you remain subscribed to our communications or until you withdraw your consent, after which it will be securely deleted or anonymized within a reasonable period, subject to any legal or regulatory retention requirements.

How does Kingsdale Collect Personal Information?

We collect personal information for marketing purposes directly from you when you voluntarily submit it through our website forms (e.g., to download case studies or thought leadership content), through LinkedIn lead generation campaigns, or when you register for our events. We do not collect personal information for marketing purposes from third-party data brokers or purchased mailing lists.

Kingsdale does not collect your personal information through marketing channels for any purpose other than those identified in this Privacy Statement.

We will not disclose your personal information collected through our marketing channels to third parties except as necessary to facilitate our marketing activities (for example, to email service providers or CRM platforms that process data on our behalf). Any such service providers are contractually required to protect your personal information and use it only for the purposes we specify. We do not disclose marketing contact information to our advisory or proxy solicitation clients.

Marketing Communications and Lead Generation

Kingsdale collects personal information, including name, email address, job title, and company name, when individuals download case studies, whitepapers, or other thought leadership content from our website, or submit their information through LinkedIn lead generation forms.

This information is stored in our customer relationship management (CRM) system and email marketing platform, which are hosted in Canada or by providers that offer equivalent privacy protections. We use this information to send you marketing materials, newsletters, event invitations, and other communications about Kingsdale's services on an ongoing basis, for as long as you remain subscribed or until you withdraw your consent.

We obtain your express consent to receive marketing communications at the point of collection — for example, through a clear and prominent checkbox or consent statement on our website download forms and LinkedIn lead generation forms. Consent to receive marketing emails is not bundled with or made a condition of accessing our content. You will always have the option to download content without subscribing to marketing communications.

In accordance with CASL, every marketing email we send includes: (a) Kingsdale’s name and contact information, including a mailing address and either a telephone number, email address, or web address; (b) a clear and prominently placed unsubscribe mechanism; and (c) a statement that the recipient may unsubscribe. You can withdraw your consent at any time by clicking the unsubscribe link in any marketing email or by contacting privacy@kingsdaleadvisors.com. Once you unsubscribe, we will cease sending marketing communications within 10 business days, as required by CASL.

We do not sell or share your contact information with third parties for their own marketing purposes.

We may use cookies, web analytics tools, and similar tracking technologies on our website to understand how visitors interact with our content and to improve our marketing efforts.

Why do we Collect Personal Information?

We collect, use, and disclose personal information through our marketing channels so that we can:

• provide you with relevant marketing and thought leadership content, event invitations, newsletters, and information about our services, where you have provided your express consent;
• comply with legal and regulatory requirements.

When you provide your personal information through our marketing channels, the purpose for collection is communicated to you at the point of collection — for example, through a consent statement on the download form or LinkedIn lead generation form. We will clearly describe what communications you can expect to receive before you submit your information.

Kingsdale will not use your personal information collected through marketing channels for any purpose other than those described in this Privacy Statement. We never sell personal information to third parties.

Kingsdale’s Actions to Protect Your Personal Information

Kingsdale safeguards your personal information through physical, organizational and technological processes and systems designed to protect your personal information from unauthorized access, disclosure, use or modification, and against loss or theft. We review and audit our security policies and procedures on a periodic basis to ensure that our systems are secure and protected.

Kingsdale stores personal information in both electronic and paper form. All of our computer systems are available only through password access to ensure that only certain individuals can access records containing personal information. Paper records are stored in locked filing cabinets in areas where physical access is restricted.

In instances where we provide personal information to affiliates or other service providers who will be acting on our behalf, we ensure that they are required to follow privacy procedures which are similar to ours and we ensure that we provide only as much personal information as is reasonably required to allow them to perform the services for which they are engaged.

If your personal information is stored or processed by service providers located outside of Canada, it may be subject to the laws of that jurisdiction, including lawful access requests by foreign government authorities. We take steps to ensure that any such transfers are subject to appropriate contractual protections.

Obtaining Your Consent

Under PIPEDA and CASL, we are required to obtain your consent before we collect, use, or disclose your personal information, subject to limited exceptions. For marketing communications sent by email (commercial electronic messages), CASL requires express consent, which means you must take a clear, affirmative action to opt in — such as checking a consent box or actively subscribing.

Express consent is obtained when you actively opt in to receive marketing communications — for example, by checking a consent box on a website download form or LinkedIn lead generation form. The consent request must clearly identify Kingsdale as the sender, describe the types of communications you will receive, and inform you that you can unsubscribe at any time. A pre-checked checkbox does not constitute express consent under CASL.

Implied consent under CASL is limited to specific circumstances, such as where there is an existing business relationship (e.g., you have purchased a service from Kingsdale within the past two years) or where you have conspicuously published your email address without indicating you do not wish to receive unsolicited commercial messages. Implied consent under CASL is time-limited and expires after two years from the last purchase or business inquiry, or six months from a business inquiry. Kingsdale primarily relies on express consent for its marketing communications.

In deciding what form of consent is appropriate for us to obtain, Kingsdale will consider the following factors:

• the type of personal information involved;
• how the personal information will be used; and
• the type of contact we will have with you.

In the event that we have no direct contact with you, we will consider whether we can infer that you have provided consent for use of your personal information.

By actively providing your express consent through our consent mechanisms (such as opt-in checkboxes on forms), you agree to receive the marketing communications described at the point of collection. If you do not wish to receive marketing communications, you may decline to opt in or unsubscribe at any time.

You have the right to withdraw your consent to receive marketing communications at any time, without any negative consequences to you. If you withdraw consent, we will stop sending marketing communications within 10 business days. To withdraw consent, you may click the unsubscribe link in any marketing email or contact our Chief Privacy Officer at the contact details below.

Maintaining Accurate Records

Kingsdale takes a number of actions to ensure that your personal information is accurate and up-to-date. However, should your personal information change, we also rely on you to inform us of the change. Circumstances may arise where, due to incorrect personal information on file, we are unable to perform certain services. For example, we may have difficulty mailing you cheques or other documents, or reaching you with relevant updates, if you have changed your address or email and this information has not been updated in our records.

Responding to Requests for Information

Under ordinary circumstances, we are able to provide you with access to personal information we have on file for you. We will provide you with this information within a reasonable time. Please note that before we can provide this information to you we are required to verify your identity. Therefore, if you would like to receive access to the personal information on file for you, please provide us with a written request for such information at privacy@kingsdaleadvisors.com and include confirmation of your identification and proof that you are entitled to this information. Once we have confirmed your identity, we will provide you with access to this information and will let you know how this information has been used and who it may have been disclosed to. Should you find an error in your personal information, we encourage you to contact us so that we can correct the information.

In certain cases, we may be unable to provide you with access to personal information which we have on file. This may occur if:

• The information cannot be disclosed for legal reasons. For example, it may have been collected during the investigation of a legal matter or cannot be disclosed because of a non-disclosure agreement.
• Providing you with access to this information would reveal personal information or confidential information about another party if we are unable to separate your personal information.
• The personal information is protected by solicitor-client privilege.

If we are unable to provide you with access to your Personal Information, we will let you know why we were unable to grant your request, unless we are prohibited by law from disclosing such information. Should we refuse your request to provide you with access to your Personal Information you have the legal right to challenge our decision.

If you are not satisfied with our response to your privacy concern, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.

Privacy at Kingsdale

Kingsdale has created this Privacy Statement to outline our marketing privacy practices and to inform you of our commitment to managing and protecting your personal information in accordance with PIPEDA, CASL, and applicable privacy legislation. This Privacy Statement is available on our website at www.kingsdaleadvisors.com. We will review and update this Privacy Statement periodically to reflect changes in our practices or applicable law, and will post the updated version on our website with the effective date noted.

If you have any questions or concerns about this Policy or about privacy at Kingsdale, please contact our General Counsel and Chief Privacy Officer by phone, fax, mail or email, and we will address your concerns to the best of our ability.

Please note that privacy laws provide for certain limited exceptions to matters included in this Policy. At times, these exceptions will affect our privacy practices. For example, at times, Kingsdale may collect, use or disclose your personal information if one of the following situations arises:

• If the personal information is deemed “publicly available” under relevant privacy legislation. For example, if the personal information appears online or in a public document, like a telephone directory.
• If the collection and use of your personal information is clearly in your best interests and for some reason consent cannot be obtained from you in a timely way. This situation may arise if we are retained to locate you in order to help reunite you with unclaimed assets.
• If a situation arises where we are required to disclose personal information by law. For example, if we are required to provide information to the Canada Revenue Agency for tax purposes.

From time to time, we may update this Privacy Statement to reflect changes in our practices, applicable privacy legislation, or industry standards. Any material changes will be posted on our website, and where required, we will notify you and seek renewed consent.

Responding to your Privacy Concerns

We encourage you to contact us with any questions or concerns you may have with respect to this Policy or our internal privacy policies and procedures. All questions will be investigated and responded to promptly.

For any inquiries and requests regarding your Privacy, please feel free to contact our General Counsel and Chief Privacy Officer by phone, fax, mail or email.

Contact Details

G: 416.644.4031
TF: 1.888.683.6007
F: 416.867.2271
TF F: 1.866.545.5580
E: privacy@kingsdaleadvisors.com

You may also visit our website at www.kingsdaleadvisors.com to obtain additional contact information.

If you are contacting us regarding a privacy concern, please provide your name, address, preferred method of communication, the nature of your question and any relevant details, including previous communications you may have had with us regarding your concerns. Any personal information you provide to us when you contact us will help us to better research and respond to your inquiry. Any personal information you provide to us when you contact us with your concern will be used only for that purpose.

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