Your privacy is critical to our relationship and our collection of your personal information in the course of business operations fully complies with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

Your personal information is defined by PIPEDA as “information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.” We collect your personal information only with your consent and, in order for your consent to be valid, we reasonably expect you to understand the nature, purpose and the consequences of the collection, use and/or disclosure of the personal information which you provide us.

To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.

What Information do We Collect

This notice applies to all information collected or submitted on the Gatehouse Partners Funds website. On some pages, you can make requests, and register to receive materials. The types of personal information collected at these pages are:

• Name
• Address
• Email address
• Phone number
• (Etc.)

How We Use Information

With your consent, we will use your personal information in one or more of the following purposes:

• To determine your eligibility and suitability for our securities;
• To verify your identity for investment purposes;
• To purchase an investment with us;
• To pay you a return on your investment;
• To comply with tax requirements;
• To service your existing Gatehouse Partners Funds investments;
• To contact and correspond with you and to respond to your inquiries;
• Email advance notice of and/or invitation to events;
• Send email to confirm your registration to newsletters or other notices;
• Personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
• To email or otherwise send you communications regarding real estate properties we believe will interest you;
• Administer a contest, promotion, survey or other site feature;
• Follow up with you after correspondence (live chat, email or phone inquiries);
• Allow us to better service you in responding to your customer service requests;
• To compile statistics, conduct market research to measure and improve the effectiveness of our marketing initiatives;
• To report to regulatory or industry agencies;
• To administer and service your business relationship with us; and
• In the event a member of the Gatehouse Group proceeds with a business transaction such as the purchase, sale of a property for development, to assist with that transaction.

What Information with Share and Don’t Share with Others

General

With your consent or as permitted or required by law or other regulatory bodies which govern us and our business, we may disclose your information as follows:

• To those associates within the Gatehouse Group that require your Personal Information for the uses set out above;
• Or for a legitimate business purpose;
• To the securities dealer, individual dealing representative or finder through whom you purchased our securities and any subsequent dealer or individual representative that assumes custody of, management of, or reporting responsibilities to you regarding, your Gatehouse Partners Funds investments;
• To our legal counsel;
• To our auditors;
• To a government institution, self-regulating organization, or other person or entity that has asserted its lawful authority to obtain the information;
• Where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity to comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information;
• To comply with court rules regarding the production of records and information; and
• To contracted third party service providers (see below).

We will only use and disclose your Personal Information to fulfill the purposes for which it was collected.

Any exception will be with your prior consent, or as may be re quired by law or other regulatory bodies which govern our business. Also, we will keep your information only for as long as it is needed to fulfill the purposes for which it was collected.

Once your data has been shared with a third party, the Gatehouse Trust no longer has direct control over that information, but we require our partners to agree to follow all state and country privacy laws.

Service Providers

The Gatehouse Partners Funds may share your Personal Information with certain service providers in order to conduct our businesses, provide our products and services to you, verify and validate information and your identity, and to address investor, borrower, and business service matters. Examples of service providers include our bank, legal counsel, accountants and other business advisors, transfer agents, administration service providers, and delivery services. To reduce the risk of fraud or misuse of Personal Information, we will only provide such information as is necessary for the service provider to carry out the service we have contracted with them to provide.

We will use reasonable efforts to ensure that your Personal Information is used in a manner that is consistent with this policy. If you do not wish us to provide your Personal Information to our service providers, we may be unable to provide you with our products or services or properly service your account or carry out a transaction or enter into a business relationship with you.

We will not sell your Personal Information to any organization for any purpose.

E-Mail Communications, Newsletters and Related Services

We may occasionally send you informational e-mails or questionnaires. These e-mails may include links to this Web site or to the Web sites of other organizations. To enable this Web site to tailor our communications to your interests, we may track the Web links that you click on. This tracked information will only be used to analyze your interest in our communications, and in keeping with Gatehouse Group’s main Privacy Policy, will not be shared with any other organizations. Alternatively, if you wish to remain anonymous, you can access the Web pages referenced in those e-mails and your visit will not be tracked.

CASL

The Canadian Anti-Spam Legislation is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.
• Send you additional information related to your product and/or service.
• Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CASL, we agree to the following:

• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.
• If at any time you would like to unsubscribe from receiving future emails, follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

How is Consent to Collect, Use and Disclose Personal Information Obtained

The cornerstone to protecting your privacy is consent. We will only collect, use, and disclose your Personal Information with your consent except where otherwise permitted or required by law, and we will only collect, use, and disclose Personal Information that we reasonably believe is necessary to complete the transaction or provide the service.

We want to ensure we have and maintain your confidence and consent to collect, use, and disclosure your Personal Information for the purposes identified in this Policy and at the time that you provide your Personal Information to the Gatehouse Trust. However, you do have a choice and can refuse or withdraw your consent at any time as follows:

You may choose not to provide us with any of your Personal Information. However, if you make this choice, we may not be able to do business with you or provide you with the product, service or information that you requested or that could be offered to you.

You may have your Personal Information removed from marketing lists which we use to inform you of new or relevant product offerings.

You may also ask us about your Personal Information and notify us of any corrections that may be necessary.

We need your consent to collect, use and disclosure your Personal Information. If you have already provided us with Personal Information, we would like to continue to use and disclose it for the purposes for which it was collected. If you do not contact us, we will assume that we may continue to do this in accordance with the standards described in this Policy. If you have any questions about our privacy practices or wish to withdraw your consent to the use and disclosure of your Personal Information, please contact us at the phone numbers provided below or email us at Hello@partnerwithgatehouse.com.

Types of Consent

Consent may be expressed or it may be implied in appropriate circumstances.

Implied Consent

In some cases, your consent is implied if we ask you to provide Personal Information with a stated purpose and you comply with our request. Implied consent may be used by us as a basis for extending new product offers to you or delivering documentation, reports and servicing your investment. We will not use your implied consent for the use or disclosure of your sensitive Personal Information such as financial data, other than as required by law, such as reporting your investment or involvement in an investment with us to securities regulatory authorities and the Canada Revenue Agency.

Express Consent

In cases where the information being collected, used or disclosed is of a financial nature or is otherwise sensitive, we will seek your express consent to the use of your Personal Information. By completing and signing a subscription agreement or other transaction agreement and related documentation to purchase our securities or enter into a transaction with us, you are giving us your express consent for us to use the Personal Information provided by you in the ways outlined above or in the documentation provided to you at the time or as required or permitted by law or other rules and regulations governing us and our business.

Withdrawing Your Consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent, we will inform you of the consequences of such withdrawal. To withdraw your consent, simply contact us and advise us of what Personal Information you no longer wish us to use. Withdrawal of your consent may result in us being unable to continue to do business with you or to offer you our securities, products or services.

Data Security

Your privacy is important to us. We are committed to respecting your privacy through the protection of your Personal Information given to us when you invest with us, or enter into another commercial transaction or business relationship with us.

The following outlines our commitment to you:

1. Collection, Use, and Disclosure - before collecting your Personal Information, or at the time of collection, we will explain to you the purpose for collecting it and obtain your consent;
2. Responsible Use of Information - our collection of Personal Information is limited to what is reasonable under the circumstances and your information will be used only for the purpose for which it is collected;
3. Security, Retention and Disposal - your Personal Information is kept confidential and secure and is not disclosed to anyone outside of the Gatehouse Group without your consent, unless required by law, and your Personal Information will be appropriately disposed of when it is no longer needed; and
4. Access to and Correction - you have the right to access your own Personal Information, and to correct any inaccuracies.

Children’s Privacy

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

How You Can Access or Correct Your Information

You can access all your personally identifiable information that we collect online and maintain by contacting us. We use this procedure to better safeguard your information.

You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

How Long Does the Gatehouse Partners Funds Retain Personal Information?

We keep your information only as long as we need it for the products and services you’re receiving and for a reasonable time thereafter or to meet any legal requirements. We have retention standards that meet these requirements. We destroy your information when it is no longer needed, or we remove your personally identifiable information from our records.

Subject to legal, audit, or regulatory requirements for continued retention of your information, you can also request that we remove your information from our records.

This website uses Google AdWords and Analytics, LinkedIn, Facebook, Twitter and email service providers like Mailchimp. We use remarketing services to advertise on third party websites (including Google) to visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, such as using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Gatehouse Fund’s website. Of course, any data collected will be used in accordance with our own privacy policy, Google’s privacy policy, LinkedIn’s privacy policy, Facebook’s privacy policy, Twitter’s privacy policy, and Mailchimp’s privacy policy.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

To manage your privacy settings with us, please reach out to us.

How to Contact Us

If you have questions, concerns, or complaints about your privacy or Personal Information, you may send us an email by using our contact page. We will inform you of our complaint procedures and will assist you in resolving the situation. If a complaint is found to be justified, appropriate measures will be taken including, if necessary, amending our practices and procedures.