Code for the Protection of Personal Information
Our Commitment to Privacy
We are committed to respecting and protecting the privacy and confidentiality of your personal information. This Code applies to the operations of Deans Knight Capital Management Ltd., and all the services and products Deans Knight provides to its clients and prospective clients. Reference throughout this Code to "we", "our" and "us" means Deans Knight.
We require certain personal information to perform our duties. We treat all your personal information with the utmost care and confidence. We only collect, use and disclose personal information for the purposes set out in this Code. We do not share your personal information with any other third party unless we are required to by law or regulation.
What Is Personal Information
The term "personal information" means information about an identifiable individual. It includes information such as your name and address, age and gender, personal financial records, identification numbers including social insurance numbers, personal references, and employment records. Personal information is considered “sensitive” if, due to its nature, in particular its medical, biometric or otherwise intimate nature, or the context of its use or communication, it entails a high level of reasonable expectation of privacy.
Accountability and Privacy Governance
We are responsible for personal information under our control and have implemented policies, procedures, and safeguards to ensure compliance with applicable privacy legislation and securities regulatory requirements. Deans Knight has designated a Privacy Officer who is responsible for overseeing compliance with this Code.
How We Collect Your Personal Information
We collect personal information directly from you (through meetings, account opening documents and the client services platform), automatically from you (when you navigate our website), through the client access portal and third parties (such as your financial institution).
In certain circumstances, we may be required to collect personal information about individuals other than you, such as a spouse, partner, beneficiary, or other related person.
This may occur, for example, where third-party information is reasonably necessary to:
provide portfolio management services;
assess your financial circumstances, investment objectives, or suitability;
comply with securities, tax, or anti-money laundering requirements.
We collect third-party personal information only to the extent necessary for these identified purposes and in accordance with applicable privacy laws.
Why We Ask for and Use Your Personal Information
The better we know you, the better we are able to serve you. We therefore ask for personal information for the following purposes:
to verify your identity and protect you against fraud,
to understand your financial service requirements,
to determine the suitability of products and services for your profile,
to offer you products and services that may be of interest to you,
to set up and manage products and services, and
to comply with laws and securities regulations.
Consent
We obtain meaningful consent from you for the collection, use, and disclosure of personal information, except where consent is not required by law, for the purposes stated in this Code. If we need to use or disclose your personal information for purposes not indicated in this Code, we will request your consent to do so. Consent may be express or implied, depending on the circumstances and the sensitivity of the information.
By providing personal information relating to another individual, you represent that you have obtained the necessary authorization to disclose such information to us for the purposes described in this Code. Where required or appropriate, we may seek the consent of the third party directly.
Withdrawal of consent
You can choose not to provide us with some or all of your personal information. You can also withdraw your consent for the use or disclosure of your personal information, as long as:
you give us thirty (30) days written notice,
there are no legal requirements for the use of your personal information, and
we can continue to fulfill our contractual obligations to you.
Keeping Personal Information Accurate
While we take reasonable steps to maintain the accuracy of client personal information for as long as it is being used for the purposes set out in this Code, we also rely upon prompt notification from you of any changes, such as address or telephone number, to help us provide you with the best possible service. We will use reasonable efforts to notify third parties of any material updates or corrections to your personal information that we have previously disclosed to them.
Releasing Your Personal Information
Deans Knight does not sell your personal information to third parties.
Deans Knight does not disclose your personal information to third parties other than in the following circumstances or for the following purposes:
in connection with normal business operations to service your account;
to Deans Knight affiliated companies, in order to provide you with a wider range of services and better customer service experience, to ensure that any updated contact information you provide is processed efficiently, and to engage in surveillance, compliance, and reporting activities required by applicable law;
to legal counsel for the purpose of obtaining legal advice;
when required or permitted to do so by law, including to any law enforcement agency, securities regulatory authority or self-regulatory organization;
in connection with offers made to Deans Knight customers or prospective customers, or other promotional activities or service offerings engaged in by Deans Knight where (A) third party product or service providers assist Deans Knight or otherwise participate in fulfillment of the offer or provision of the service; (B) Deans Knight has contracted with a third party for the fulfillment of the offer or provision of the service or otherwise has an ongoing business relationship with such third party; (C) fulfillment of the offer or provision of the service requires disclosure of certain limited personal information for fulfillment purposes only to such third party; and (D) in an aggregated form for the purpose of analyzing statistics and metrics about Deans Knight’s business and operations.
By opening or maintaining an account with DK, using our services, access account information through the portal or using our platform, and by navigating on our website, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described above.
Keeping Your Personal Information Confidential
Personal information is protected at Deans Knight by safeguards that are reasonable to the sensitivity against loss or theft and against unauthorized access, disclosure, copying, use or modification. Safeguards include physical protection (such as locked cabinets and restricted access to offices), organizational measures (such as access clearances) and technological measures (such as passwords and encryption).
When engaging third-party providers to deliver services on our behalf — such as administrative tasks or trade processing — we disclose only the information necessary for them to fulfill their duties. We maintain contractual agreements that obligate these organizations to uphold stringent confidentiality standards comparable to our own, ensuring any data supplied is securely maintained and utilized solely for the purposes articulated in the contract.
Retention of Personal Information
We only keep personal information for as long as we need it, to meet the purposes set out in this Code and to enable us to respond to any concerns you may have. The length of time we retain personal information depends on:
the type of product or service you have with us, and
any legal, regulatory or business requirements we may have to meet.
Generally, our policy is to retain records for 10 years after they are no longer current.
We have procedures in place when destroying, deleting, or disposing of personal information when it is no longer required for the purposes set out in this Code, or by law.
Privacy Incidents and Mandatory Notification
Deans Knight values your personal information. If we ever experience a breach of security safeguards involving personal information which we believe creates a real risk of significant harm to you, we will notify both you and the Privacy Commissioners (depending on your province of residence) as soon as feasible.
Cross-Border Transfers
From time to time, we may engage the services of service providers and counterparties that may be located outside your province of residence (if you are a Quebec resident) or Canada, and personal information may be transferred, processed, stored and backed up in foreign jurisdictions.
Personal information transferred or accessed outside Canada may become subject to the laws of those foreign jurisdictions, including lawful access or disclosure by foreign courts, law-enforcement agencies or regulatory authorities, and may not receive equivalent protection to that afforded by Canadian privacy laws.
Your rights and How to Contact Us
You have the right to access, withdraw your consent, request corrections or deletions to your personal information as well as a right to lodge complaints or inquire about our policies and practices relating to the handling of personal information. If you reside in the province of Québec, you also have the right to request that we provide your personal information in a portable, reusable format that can be transferred to another service. For all requests, we will need specific information from you to assess the feasibility of your request and respond within 30 days of being given notice.
Please direct questions, requests to exercise your rights, or complaints to the attention of our Privacy Officer:
Martin Nigro
Deans Knight Capital Management Ltd.
1500 – 999 West Hastings Street
Vancouver, BC V6C 2W2
privacy@deansknight.com
Changes to the Code
This Code is effective as of the “last updated” date located below. We may update this Code from time to time. When we do, we will let you know by revising the Code with a new “Last updated” date.
Last Updated: September 1, 2026