THE PROTECTION OF YOUR PRIVACY IS OUR HIGHEST CONCERN - YOUR INFORMATION IS SAFE WITH US

Centum One (EasyRate.ca), values client privacy in the utmost, and takes every measure to safeguard your personal and financial data. We have implemented strict safety protocols to ensure your right to privacy is protected.

PRIVACY POLICIES

1. Centum One (EasyRate.ca), holds itself accountable for the safeguarding of clients` personal information. Though senior management is ultimately responsible for the protection of personal information, other staff may be delegated the task of regularly monitoring our operation's privacy protocols.

2. Centum One (EasyRate.ca), is dedicated to ensuring that the transfer of sensitive information meets with all necessary security measures; however when using e-mail or wireless communication or other third-party modes of transmission, clients of Centum One (EasyRate.ca) are advised that complete confidentiality and security cannot be assured.

3. Given the foregoing, Centum One (EasyRate.ca)., Direct is not accountable for any damages suffered when a client transmits personal information through e-mail or wireless communication or when Centum One (EasyRate.ca), transmits information by these means at the request of the client.

4. Centum One (EasyRate.ca), has implemented strict protocols to: protect personal information; to receive and attend to inquiries and complaints;to train staff regarding the privacy protocols; and to communicate the related policies and procedures to our clients.

5. Centum One (EasyRate.ca), collects client personal information for the following reasons only:

• To verify a client`s identity;
• To provide financial services;
• To understand our clients` financial needs;
• To determine client eligibility for different products and services;
• To develop, manage and deliver products and services to clients;
• To broker and administer loan agreements;
• To develop and deliver marketing and promotional offers to clients;
• To ensure that clients receive top-quality service;
• To meet national, provincial and other regulatory requirements; and
• To manage and transfer the liabilities and assets of Centum One (EasyRate.ca), and those assets under its care.

Centum One (EasyRate.ca), will only collect personal information for the aforementioned purposes, in a manner that is lawful. Centum One (EasyRate.ca) will not collect information without necessity, nor will it use information for any purpose other than those stated above without first seeking client consent.

6. Centum One (EasyRate.ca), will obtain client consent to collect, use or disclose any personal information except where detailed in this policy. Centum One (EasyRate.ca), will make reasonable efforts to ensure clients understand how their personal information is to be used and disclosed.

7. Client consent may be given orally, such as in the case of consent voiced over the telephone when information is being requested; consent may be given in writing, such as when signing an application form or agreement; and consent may be given electronically, such as when submitting an application form, agreement or other electronic document. Client consent may be express, or implied in those instances when Centum One (EasyRate.ca) can reasonably infer consent through client's action or inaction. Client consent may also be given through an authorized representative such as a broker, agent or lawyer.

8. Centum One (EasyRate.ca), reserves the right to collect, use or disclose personal information without the client`s prior knowledge or consent in the following exceptional circumstances:

• When said information is publicly available;
• When said information is lawfully permitted or required to be used, collected or disclosed;
• When we are seeking legal advice from a lawyer;
• During the course of client debt collection;
• When said information is needed to deal with a foreseen breach of law; and
• When potential stakeholders or investors wish to verify the characteristics and quality of an investment.

9. Except where otherwise legally or contractually bound, clients may refuse or withdraw consent but must give reasonable notice of such to Centum One (EasyRate.ca). Centum One (EasyRate.ca) may in turn refuse to do business with a client who denies consent to the use of such information, or be unable to offer certain products and services where such information is necessary.

10. Centum One (EasyRate.ca) may from time to time use client personal information to improve our products and services through client surveys. If a Third Party is contracted to conduct research on behalf of Centum One (EasyRate.ca), or provide other services requiring access to client personal information, Centum One (EasyRate.ca) will ensure that the personal information is appropriately protected in its use and transfer, through such security measures as confidentiality clauses in contractual arrangements.

11. Centum One (EasyRate.ca) will only retain client personal information as long as reasonably necessary for the above-mentioned purposes, or as required by law.

12. Centum One (EasyRate.ca) reserves the right to disclose personal information related to a financial asset of Centum One (EasyRate.ca) upon the transfer of the financial asset.

13. Centum One (EasyRate.ca) will make reasonable efforts to ensure that client personal information is complete, current and accurate. It is the client's responsibility to ensure that certain information provided to Centum One (EasyRate.ca), such as the client`s address or telephone number, is current, complete, and accurate.

14. Centum One (EasyRate.ca) will only update information where it is necessary to fulfill the purposes for which it was collected or where it is required to maintain an active account.

15. Centum One (EasyRate.ca), is committed to the safeguarding of client personal information, and will use appropriate security measures (including physical measures such as the security of offices and physical data, and electronic measures such as encryption and password protection) to protect the information against theft, loss, unauthorized disclosure, access, duplication, modification or use.

16. Centum One (EasyRate.ca) will use appropriate security measures when disposing of client personal information.

17. Centum One (EasyRate.ca)'s policies and procedures for the protection of personal information are subject to continuous development, updates and reviews to ensure security measures remain effective and up to date.

18. Centum One (EasyRate.ca) will make available the following information:

• The name, address and title of the person to whom inquiries or complaints regarding policies and procedures can be forwarded;
• A copy of any brochures or other information explaining the policies and procedures;
• A description of the kind of personal information held by Centum One (EasyRate.ca), including a general explanation of its use; and
• An account of what personal information is made available to affiliated companies or investors.

19. Centum One (EasyRate.ca) will accede to a client request to access their personal information within a reasonable time frame, providing the client with a description of the personal information held by Centum One (EasyRate.ca), what purpose it serves, who has access and to whom it has been disclosed, for those periods for which records are available.

20. Centum One (EasyRate.ca) may ask that clients specify in writing what information they would like to access.

21. Clients will be required to provide proof of identity in order for Centum One (EasyRate.ca) to provide an account of the existence, disclosure and use of personal information.

22. Centum One (EasyRate.ca) will make the information available within 30 days of the receipt of the request where possible, failing which, Centum One (EasyRate.ca) will provide written notice of extension within 30 days of the receipt of the request where additional time is needed to provide the information. Notice of extension will include the new deadline, the reason for the extension, and advise the client of the right to lodge a complaint regarding the extension.

23. The information provided may incur a cost to the client, which can vary depending on the amount and type of information requested. Where a cost is anticipated, Centum One (EasyRate.ca) will inform the client of the cost and offer the client the option to withdraw the request or direct Centum One (EasyRate.ca) to proceed with the request.

24. If the information retrieved is demonstrated to be incomplete or inaccurate, Centum One (EasyRate.ca) will amend the information as needed, including transmitting the amended information to relevant Third Parties where appropriate.

25. Should a request for information be refused or impossible to fulfill partially or completely, Centum One (EasyRate.ca) will notify the client in writing of the reasons for the failure to provide the information (which may include the burden of an unreasonable cost to provide the information, the threat to the life or security to another individual, information that may compromise the privacy of other individuals, information subject to solicitor-client or litigation privilege, information which is protected for legal, security or commercial proprietary reasons, and information generated in a formal dispute resolution process) and the resources for redress available to the client.

26. Questions, concerns or complaints regarding this privacy policy are to be directed in writing to the Compliance Officer.

27. Centum One (EasyRate.ca) captures information about what pages users visit and how they interact with our website at www.easyrate.ca, in order to improve the functionality of the site. The data we collect toward this end contains no personal information, and is used internally to better serve and understand our users.