Blackstone Technologies remains committed to providing you (our clients) with excellent customer service and advice. As part of this commitment, we strive to protect your privacy and the confidentiality of personal information that you have entrusted to us.

In order to maintain your trust and confidence in us, Blackstone Technologies’ Privacy Policy is designed to outline for you in a question and answer format important details about how we safeguard the privacy, confidentiality and security of your personal information.

1.       Why does Blackstone need to collect information about you?

2.       What information about you do we collect?

3.       What do we do with your personal information?

4.       With whom is your information shared?

5.       Where do we keep your information?

6.       How is your information protected?

7.       How is Blackstone minimizing use of your personal information?

8.       How does Blackstone collect, use and protect your personal information received online?

9.       What privacy rights do you have?

10.   Who do you contact about privacy concerns at Blackstone?

1. Why does Blackstone need to collect information about you? 

Simply, we collect personal information about you in order to properly serve you and your investment needs.

Secondly, we never collect more information about you than is absolutely necessary to serve you and necessary to meet our legal and regulatory requirements.

2. What information about you do we collect? 

·         Personal and financial information you provide in the secure, online FundsUp application that you subscribe to.  Personal information may include your name, address, credit card information, employment information and portfolio information.

·         Information you provide during telephone conversations with a Blackstone representative, which calls are all recorded for the purposes described below;

·         Information you provide in emails or contact forms that you send us;

·         Information that your browser provides about the browser type and configuration your computer uses so that you can view our website properly;

·         Log File Information. In an ongoing effort to improve the quality of our website, we regularly review server-generated logs, which provide information on website use, browser types and very limited demographic overview information. We make no attempt to identify individual users; and

·         Personal and financial information you provide in response to surveys, questionnaires, focus groups or other marketing initiatives.

3. What do we do with your personal information? 

 We use your personal information:

·         to properly identify you;

·         to professionally serve your investing needs;

·         to establish your account and to maintain, record and store your information;

·         to ensure quality control during telephone conversations with our representatives;

·         to develop and offer additional products and services that we feel may be of interest to you; and

·         to meet our legal and regulatory requirements under Canadian law.

4. With whom is your information shared?

 Blackstone Technologies is not in the business of selling or distributing our clients' personal information to others. Client confidentiality and privacy remains a fundamental principle of ours. However, we may share your information with others outside Blackstone Technologies in certain limited circumstances including:

·         With Affiliates of Blackstone Technologies. To ensure you benefit from a full range of products and services and only with your consent, we may share your personal information with our affiliates including our billing company, NAL PATH Insurance Brokers Inc..

The affiliates may provide the following products and services: What are these?

·         When Permitted or Required by Law. Blackstone Technologies is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry.

We may disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

We may disclose information to various regulators to which we are subject in order to comply with their regulatory requirements. This helps prevent fraud, money laundering, and other illegal or unethical activity.

·         Business Re-organization As Blackstone Technologies continues to grow, we may in the future re-organize or streamline parts of our operations. Because our business consists in large measure of our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business.

5. Where do we keep your information? 

Blackstone Technologies records and retains your personal information in electronic, microfilm or paper format at our Head Office location in London, Ontario.

Electronic access to your personal information is made available to Blackstone Technologies’ staff.  Additionally, paper records forming part of your personal information held by us may also be kept at the head office location. Paper records are also kept in off site storage locations in London, Ontario as part of our document storage practices.

Your personal information may also be transferred to other off site locations as part of our disaster recovery practices.

6. How is your information protected? 

The security of your personal information is our top priority. We employ extensive physical, electronic and internal procedural controls to protect your personal data.  Blackstone annually undergoes a security audit to ensure that our procedures and controls meet or exceed industry standards.

Blackstone has comprehensive security standards to guard against unauthorized access to your personal information. For example:

·         We require users to identify themselves on the Fundsup Online "Sign-In Page" before granting Internet access to portfolio information;

·         We protect your account and log in information using highly secure "firewalls";

·         We reconfirm your computer's identity each time you ask to see a new Fundsup Online page;

·         We carefully review all court orders or legal enquiries received to confirm they are valid. We disclose only the personal information legally required under the terms of the court order or legal enquiry;

·         All Blackstone employees are properly trained to ensure all personal information is handled properly and safeguarded adequately; and

·         Blackstone will audit our privacy procedures and security measures in order to confirm that they remain adequate and effective.

While we make every attempt to provide the most secure environment for your data, there are a number of things you as a client can do to ensure the protection of your personal data.

7. How is Blackstone minimizing use of your personal information? 

Within Blackstone and among our service providers, we restrict access to personal information to those who need it in order to provide you with products and services.

We do not use personal or financial information for any purpose other than to best serve you and to identify how we can best meet your needs.

We do not ask for more information than we need to meet your financial needs and our legal and regulatory requirements.

8. How does Blackstone collect, use and protect your personal information received online?

·         Visiting our informational sites When you visit one of our informational websites and navigate through the content provided we learn what pages were visited, what pages were downloaded, the address of the site you visited prior to accessing our site and your Internet protocol address. We only use this information to gather overall site statistics (for example total number of visitors to the site). No attempt is made to identify you as an individual.

Information such as how people are using our site, which sections are of most interest and which pages are visited more frequently assists us in adapting our site to better suit your needs and make accessing information easier. No personal information about you is retained by us.

·         Cookies Cookies are small text files that are placed on your computer when you visit a website.

There are two types of cookies currently in use: "session cookies" and "persistent cookies". Session cookies store information only for the duration of your visit to a site. They are not written to the hard drive of your PC but rather are stored in your computer's memory. They do not exist after you have left the site. We currently use session cookies in our Fundsup Online application.

Persistent cookies are written to your hard drive and remain there until they expire or are deleted by you. We do not use persistent cookies in any Fundsup Online application.

Each time you use the service, we record your login id when you enter the system and when you leave. We record any changes to services that you have registered for and modifications to your portfolios and personal information.

Email When you send us an email we use that address to respond to your query via email. We will store your email and our reply for future reference should there be further correspondence.

If you have asked us to put you on our email mailing list to provide you with certain information on a regular basis you may ask us to remove you from that list at any time.

Please remember that email sent via the Internet is generally unencrypted and a potential security risk. We will only request that you transmit confidential information over the Internet where the communication is encrypted. You should use caution when forwarding emails and ensure that you do not include confidential information within the body of the messages.

9. What privacy rights do you have? 

Except in limited circumstances, you may request from us access to your personal information that we hold. You may also question or challenge the accuracy and completeness of this information. We will respond to your request within 30 days.

Please note that we may not be able to provide you with your information in the following circumstances:

·         if it contains references to other persons and the references are subject to legal privilege;

·         if it contains information that is proprietary to Blackstone Technologies;

·         if it relates to an investigation of a breach of agreement or law; and

·         if it cannot be disclosed for other legal reasons.

You are also permitted to withdraw your consent that allows us to share your personal information in certain circumstances (for example, the sharing of your information with our affiliates). You may withdraw such consent at any time by contacting us by email or telephone at the address and number noted below. However, your decision to withdraw or revoke your consent may limit the products or services that we are able to provide to you.

10. Who do you contact about privacy concerns at Blackstone Technologies?

·         Blackstone has appointed a Chief Privacy Officer to handle all privacy issues. If you have any questions, concerns or issues about our Privacy Policy or about confidentiality issues or other issues raised here, you may contact us as follows:

Attention: Chief Privacy Officer

By mail Blackstone Technologies Inc. P.O. Box 2880 210-700 Richmond Street London, Ontario N6A 4H9

By email privacy@fundsup.com

Telephone and fax 1-866-386-3755 (across Canada) 519-434-5220 (Fax)