Policies & Procedures Protecting Your Privacy at Arton Investments

This page informs you of the privacy policies of Arton Investments and the ways that we ensure the protection of your privacy and the confidentiality of your personal information. This policy applies to individual clients of Arton Investments, including, persons who carry on business alone or in partnership with other individuals, and to personal information held by us about individuals who are directors and officers of corporate clients.

CLIENT PRIVACY POLICY

---

Collection and Use of Personal Information by Arton Investments

When you open an account with Arton Investments, we will obtain personal information about you that will be retained in accordance with industry regulations. Only authorized individuals and entities have access to this information. The information we collect allows us to identify you, to protect you against possible fraud, to assess your potential investment needs so that we may suggest products and services to you which are appropriate for you, and to comply with legal and regulatory requirements. Also, while Arton Investments does not normally record its telephone conversations with clients, it may be the case that we could obtain personal information from you by phone, if you should happen to call us on one of our taped lines (trade desk or compliance). We may record these lines in order to ensure that we have an accurate record of conversations.

Social Insurance Number

If you are an individual, we may collect, use and disclose your SIN for income tax reporting purposes.

Disclosure of Personal Information to External Sources

Arton Investments may from time to time disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to us. We may also rely on external sources to collect personal information about you.

Your consent is required before we may provide your information to any third parties. The consent that you provide to us with regards to the collection use and disclosure of your personal information may be cancelled by you at any time by providing written notice to us. We do not require your consent to the collection, use and disclosure of your personal information where such collection, use and disclosure is reasonably required in the normal course of providing service to your account, or for the collection of a debt owed to us by you, or to a law enforcement agency, securities regulatory authority or self-regulatory organization, or to legal counsel for the purpose of obtaining advice. By opening an account with us, you are providing consent o us to collect, use and disclose your personal information as set out in this agreement.

Corrections to Personal Information

You may review the information you have provided to us and make corrections to it. We may request that your provide corrections in writing. You may address corrections, questions or privacy related complaints to the Chief Compliance Officer of Arton Investments.

Retention of Personal Information

Arton Investments may retain your personal information on file after you cease to be a client for as long as we require such information or as long as is demanded by our regulatory requirements.

Consent

By opening an account with Arton Investments, you consent and agree to the collection, use and disclosure of personal information by Arton Investments is as set out in this policy statement.

Questions regarding Arton Investments’s privacy policy should be addressed to:

Compliance
Arton Investments
1 Westmount Square, Suite 1110
Montreal, Quebec H3Z 2P9
Canada
Tel: 514 935 9333
Fax: 514 935 5622

COMPLAINT RESOLUTION

---

As an initial step, please contact your investment advisor to discuss questions or concerns you may have about a particular issue.

If you feel the issue is not being resolved to your satisfaction, contact our Compliance Department, by email at [email protected] , or by letter at Compliance, Arton Investments, 1 Westmount Square, Suite 1110, Montreal, QC H3Z 2P9, Canada.

Upon receipt of your formal complaint, a detailed and transparent investigation and resolution process begins. Within 5 business days, we will acknowledge your complaint and outline the investigative steps underway to seek a resolution. We will provide you with a substantive response, generally within 90 days or less. This will summarize the complaint, the steps we have taken to investigate it, the results of our investigation, and our final decision on the resolution of the complaint, with an explanation.

We will fully disclose the further options available to you should the complaint not be resolved to your satisfaction at this stage. These further resolution options and procedures are set forth in the attached IIROC brochure “An Investor’s Guide to Making a Complaint”.