Last Revised: July 21, 2026

This Privacy Statement for Canada describes how Arete IR Advisors Canada ULC (“Arete”) collects, uses and discloses personal information in connection with its commercial activities in Canada.

This Privacy Statement applies to personal information that is under the control of Arete. It does not apply to personal information that Arete may access, collect, or otherwise process on behalf of clients as a service provider. When Arete acts as a service provider to clients, it processes personal information only in accordance with the client’s instructions and the client’s privacy policies or statements will govern such processing.

1.    Collection and Use of Personal Information

We collect information as necessary to establish and manage our business relationships with our clients and prospective clients, including for the purposes of providing requested goods and services, providing information, marketing materials and other communications, collecting feedback including through surveys, understanding and managing client preferences, providing customer service, and for billing purposes including processing payments. The information we collect and use for these purposes is generally limited to business information, including business contact information of Representatives (as defined below) of our clients and prospects, but may also include information about your preferences and interactions with us.

Arete is subject to “Know Your Client” requirements, including pursuant to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada). In order to comply with these requirements, Arete is required to collect personal information of authorized signatories, beneficial owners, trustees, beneficiaries, settlors, and other representatives of its clients (“Representatives”). The personal information that must be collected for this purpose includes, as relevant, the Representative’s name, address, telephone number, date of birth, signature, and the reference number, issue and expiry date, and place of issue of the Representative’s driver’s license or passport. We use this information for the purposes of verifying Representatives’ identity in accordance with applicable “Know Your Client” requirements, which may include checking identity against sanctions or similar watch lists.

We may receive personal information directly from you (for example, if you complete a survey or request information or services from us). If you provide us with personal information, you are deemed to consent to our collection, use and disclosure of your personal information as described in this Privacy Statement. We may also receive information from other sources. For example, we may collect Representative personal information from our client. When we do, we require the client to represent and warrant that they have all necessary consents to provide the personal information to us for the purposes described in this Privacy Statement.

2.    Disclosure of Personal Information

Arete may disclose personal information to legal, regulatory or self-regulatory authorities in cases of suspected unlawful activity (including money laundering and insider trading), or when required to satisfy legal, regulatory or self-regulatory requirements.

Arete may disclose personal information to a purchaser or prospective purchaser of all or part of the business or assets of Arete, for the purposes of evaluating or completing the transaction, or carrying on the purchased business.

Arete may use agents or service providers (including affiliates acting in this capacity) to collect, use and disclose personal information for the purposes described herein. Some of these agents or service providers may be located in the United States, India or other jurisdictions outside of your country or province of residence where local laws may permit government, regulatory or national security authorities to have access to your personal information in certain circumstances.

Representative personal information may be shared for the purposes of conducting the Know Your Client requirements described above, including with telecommunication providers or mobile network operators for the purposes of identity verification.

3.    Retention and Safeguarding of Data

Personal information is maintained within secure cloud environments and will be accessible by our employees, agents and service providers who require access to perform their duties. We have implemented physical, technological, and organizational security measures that are designed to protect personal information in our control. However, please note that no security measures can ensure absolute security.

We intend to retain personal information only for as long as necessary to fulfill the purpose for which it was collected, and to comply with applicable laws and regulations. We consider the following criteria when determining how long to retain personal information: why we collected the personal information; the nature of the personal information; the sensitivity of the personal information; our legal obligations related to the personal information, and risks associated with retaining the personal information.

4.    Your Rights

You have the following rights regarding your personal information:

·      Right of Access. You may request access to the personal information we hold about you, including information about how it has been used and disclosed. In certain circumstances, you may also request that we communicate personal information that we have collected from you, to you or another organization in a structured, commonly used technological format.

·      Right to Correction. You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

·      Right to Withdraw Consent. You may withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions. Please note that withdrawing consent may affect our ability to provide you with certain products or services. We will inform you of the implications of withdrawal upon receiving your request.

To make a request to exercise any of your rights, please contact us as described in the Contact Us section below.

5.    Contact Us

If you have any questions or complaints about our Privacy Statement or our personal information handling practices, or if you would like to exercise any of your rights in respect of your personal information, please write to our Privacy Officer at privacy@areteir.com.