PRIVACY POLICY

This privacy policy describes in detail how Black Oak Equity Partners Inc. and its subsidiaries and affiliates collect, use, and disclose information in connection with your use of our services.

This document is updated from time to time, and is available online at blackoakpartners.ca/legal/privacy.

For your protection, you should not provide your account information, username, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately.

Black Oak Equity Partners Inc. is committed to protecting and maintaining the accuracy, confidentiality and security of your personal information. Among the types of Personal Data that Black Oak Equity Partners Inc. collects, by itself, or through third parties include: first name, last name, email address, home address, work address, telephone number, social insurance number, drivers licence, digital copies of agreements and forms, credit and financial information, and other information that you provide to us such as your preferences, identities of your advisors and decision-makers, feedback, and comments.

Usage data collected by blackoakpartners.ca or other service providers is outlined in detail in the dedicated sections of this policy, or by specific explanation texts displayed prior to the data collection.

Some data may be freely provided by the User, or, in a case of Usage Data, collected automatically when using blackoakpartners.ca. Unless specified otherwise, all data requested by Black Oak Equity Partners Inc. is mandatory and failure to provide this Data may make it impossible for Black Oak Equity Partners Inc. to provide its services in compliance to local government legislation and securities laws. In cases where Black Oak Equity Partners Inc. specifically states that the Data is not mandatory, Users are free to not communicate this Data without consequences to the availability or functioning of the Service.

Any use of cookies – or other tracking tools – by Black Oak Equity Partners Inc. or by other third-party services used by Black Oak Equity Partners Inc. serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document.

If you are uncertain about what Personal Data is mandatory, you are welcome to contact us at legal@blackoakpartners.ca

The Data we collect is used for different purposes relating to the management of our business and our relationship with you. These purposes include, but are not limited to:

• establish, maintain, and manage the relationship between you and Black Oak Equity Partners Inc.
• enable Black Oak Equity Partners Inc. to communicate through your preferred method
• share your personal information with a representative, such as a financial planner, advisor, investor representative, trust administrator, or other third parties at your request
• protect our business from fraud, theft and damage to our assets and services
• enable Black Oak Equity Partners Inc. to comply with applicable laws, tax and regulatory requirements
• back-end infrastructure management, hosting, SPAM protection and analytics
• other reasons reasonably required by Black Oak Equity Partners Inc. to conduct business

You can find more detailed information about such purposes of processing and the specific Personal Data used for each purpose in the respective sections of this document.

We take appropriate security measures to protect and prevent unauthorized access, disclosure, modification, or unauthorized destruction of your Data. With the confidential nature of our Services, the Data processing is carried out using computers and IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Black Oak Equity Partners Inc., in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of blackoakpartners.ca (such as administration, marketing, legal, and system administrators) or external parties (such as third-party technical service providers, hosting providers, cloud computing providers, and communications agencies) appointed, if necessary, as Data Processors by Black Oak Equity Partners Inc. You may request an updated list of these parties at any time.

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner
• processing is necessary for the purpose of the legitimate interests pursued by the Owner or by a third party.

The Data is processed at our operating offices and in any other places where the parties involved in the processing are located.

To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data or inquire with the Owner using the information provided at the end of this Policy.

The Personal Data will be processed and stored for as long as required by the purpose they have been collected for. Therefore:

• Personal Data collected for purposes related to investments will be retained until such contracts or agreements have been fully performed and legal compliance has been met.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this Policy or by contacting Black Oak Equity Partners Inc.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Data concerning the User is collected to allow Black Oak Equity Partners Inc., and its subsidiaries to provide its Services, blackoakpartners.ca, and meet the legal requirements as outlined in the Securities Act (Ontario).

Users may exercise certain rights regarding their Data processed by Black Oak Equity Partners Inc. In particular, Users have the right to the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. In the event that consent is withdrawn, certain Services may be suspended or not function as intended.
• Object to processing of their Data. Users have the right to object to the processing of their Data. If the processing is carried out on a legal basis, certain Services will be suspended or not function as intended.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated and corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Right to Object
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided at the end of this Policy. These requests can be exercised free of charge and will be addressed by the Owner as early as possible.

System Logs and Maintenance
For operation and maintenance purposes, Black Oak Equity Partners Inc. and any third-party services may collect files that record interaction with winceymills.ca (System logs) use other Personal Data (such as the IP Address) for this purpose.

More details concerning the collection or processing of Personal Data may be requested at any time. Please see the contact information at the beginning of this document. For third-party integrations, please visit their policies below:
https://www.digitalocean.com/legal/privacy-policy/
https://www.rebel.ca/privacy-policy
https://www.dropbox.com/privacy2016
https://roylcreative.ca/privacy-policy/
https://policies.google.com/privacy?hl=en-US
https://mailchimp.com/legal/privacy/

blackoakpartners.ca does not support “Do Not Track” requests.  To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their respective privacy policies.

This document is updated from time to time. Black Oak Equity Partners Inc. will give notice to its Users on this page, and possibly within blackoakpartners.ca and/or as far as technically and legally feasible – such as sending notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of last modification. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User when required.

Black Oak offers a variety of options for accessing and reviewing your account information. You can review your information on your statements and other account documents, as well as through our website.
If you have any questions relating to this privacy policy, concerns about the way in which we have handled information about you, or to request a copy of your data, please do not hesitate to send us an email at
privacy@blackoakpartners.ca