Midnight Integrated Financial Inc. and its related entities (“Midnight Sun” or “We”) are committed to keeping the information entrusted to us by our investors and other individuals (“you”) confidential. This Privacy Policy outlines the principles and practices we follow in protecting your personal information.

Personal information is any information about an identifiable individual or that permits an individual to be identified. This includes information such as age, home address and phone number, income and assets, and social insurance number. While personal information also includes your name, business address and business contact information, such as your business title, email address or phone number, this information is not protected by this Privacy Policy when the information is provided for business purposes. Information that is in the public domain is also not protected by this Privacy Policy.

Collection

We collect only the personal information that we need for the purposes of providing services to you, including personal information needed to: open and manage an account, meet regulatory requirements, assess your eligibility for our products, assess your suitability for our products, contact you, etc.

We normally collect your information directly from you. However, we may also collect your information from other persons with your consent or as authorized by law. We inform you, before or at the time of collecting personal information, of the purposes for which we are collecting the information, unless the information is being provided for an obvious purpose.

We make every reasonable effort to ensure that your information is accurate and complete. We rely on you to notify us if there is a change to your personal information that may affect your relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible.

Use and Disclosure

We use and disclose your personal information only for the purposes for which the information was collected, except as authorized by law. If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent. In providing our services, we may share your personal information with third parties that have been retained by us to assist us in carrying out our services. While we have no way of controlling the third parties we retain, we do seek to ensure that they have security and privacy policies in place, comparable to our own.

Consent

We ask for consent to collect, use or disclose your personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask you to provide your consent in writing, often done through the execution of a subscription agreement. You may withdraw consent to the use and disclosure of personal information at any time upon reasonable notice, unless the personal information is necessary for us to fulfil our legal obligations. The withdrawal of your consent to the use and disclosure of your personal information may mean we will not be able to provide you with certain products and services.

We may collect, use or disclose your personal information without consent only as authorized by law.

Website

The Midnight Sun website may automatically collect certain non-identifiable information regarding website users, such as the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the website, the sections of the website you visit, and the materials you download from the website. This non-identifiable information is used for website and system administration purposes and to improve the website. The website may use “cookies”, a technology that allows a website to store information on a user’s machine and later retrieve it. Cookies are designed to enhance the convenience and use of the website. You may choose to decline cookies if your browser permits, but doing so may affect your use of the website.

Security

We protect your personal information in a manner appropriate for the sensitivity of the information. For example, any physical documents containing sensitive information, such as social insurance numbers, are kept in lockable filing cabinets. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. Employee access to personal information is limited to those employees who require such personal information to carry out their responsibilities. Any employee with access to personal information must certify on a recurring basis that s/he maintains the confidentiality of information to which s/he has access.

We retain your personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes. We render your personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying your personal information, including shredding paper records and permanently deleting electronic records.