Real Asset Management MIC Privacy Policy

The Definitions You Need to Know when Reading This Policy:

“Acts” means the Personal Information Protection Act (Ontario), and the Personal Information Protection and Electronic Documents Act (Canada) and such other privacy laws that may apply to Real Asset Management from time to time;

“Real Asset Management associates” means any employee, contractor, supplier, officer or director of the corporation;

“Real Asset Management”, “our”, “we”, or the “Corporation” means the RAM Group International and includes reference to Real Asset Management REIT, Real Asset Management Diversity, Real Asset Management Mortgage Investment Corporation, Real Asset Management Alternative Assets, Real Asset Management Staffing Solutions, Real Asset Management Hospitality, and those entities associated or affiliated with these companies or which have business, management, or ownership in common with them.

“Privacy Officer” means the individual designated by Real Asset Management to ensure compliance with the Acts and make information about Real Asset Management’s management of personal information available on request. The Privacy Officer shall be designated by the board of directors of the Corporation.

What is Personal Information and What Personal Information is Protected under Canadian Privacy Law?

Personal information as described in Canadian privacy laws is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual. You can be identified from information such as your name, email address, phone number, home address, driver’s license number, passport number, and financial history. You may also be identified from information such as an online identifier, IP address, unique device ID, or website cookie; this type of information becomes personal information when combined with information that further identifies who you are. Certain identifiable information is not protected by Canadian privacy laws such as your business or employment information typically found on a business card. Also, data we collect with personal identifiers removed, so that it is impossible to determine the identity of the person to whom the information relates, is not protected under Canadian privacy laws. When we capitalize “Personal Information” in this privacy policy we are referring to your information that is protected by Canadian Privacy Laws.

How does Real Asset Management Collect Your Personal Information?

Depending on how you do business with us, we may collect Personal Information from the following sources:

• from you, on applications, contracts or forms filled out through telephone, e-mail, online or face-to-face interviews;
• from intermediaries contracted by us with whom you have a relationship;
• from your interactions with us;
• for example, as an existing investor or past borrower or guarantor;
• from government and other entities, such as CRA;
• from consumer reporting agencies, such as a credit reporting agency; or
• from previous employers.

What Personal Information does Real Asset Management Collect?

We collect Personal Information from individuals who are investors in Real Asset Management, borrowers or guarantors of loans by Real Asset Management, parties to commercial transactions or individuals in business relationships with Real Asset Management and employee information.

With your consent, as an investor we usually collect and maintain your name, residential address, telephone number, e-mail address, social insurance number, identity verification information (such as driver’s license number or credit agency report) and banking information.

With your consent, as a borrower or guarantor, in addition to the information listed above for investors, we usually collect and maintain your financial status and history, employment history, and credit information.

The Personal Information we collect in relation to a commercial transaction or business relationship will vary depending on the nature of the transaction or relationship and may include additional information for investors and borrowers or guarantors.

Personal Information may also include your transaction history with Real Asset Management, customer service inquiries, information requested or provided to you, or responses to surveys.

We may also collect and summarize Personal Information in a format that does not identify you as an individual for statistical and marketing purposes.

We may record phone calls to or from our offices for the purposes of quality assurance control, customer service training, and to record consent and instructions related to business transactions with Real Asset Management. If you have any questions or concerns with the taping of your phone calls, you may contact us in writing or through our website or the Privacy Officer.

It is always your choice whether or not you provide us with your Personal Information. However, a decision to withhold Personal Information may restrict or prevent us from allowing you to invest with us or providing you with a loan or entering into a commercial transaction or business relationship with you.

We do not permit registration by, nor collect personally identifiable information from any person we know to be under the age of 18.

How does Real Asset Management Use the Personal Information IT Collects?

With your consent, we will use your Personal Information for one or more of the following purposes:

• To determine your eligibility and suitability for our products and services;
• 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 Real Asset Management 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 goods or services 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;
• In the case of borrowers or guarantors, to assess the viability of a loan and to market our products and services;
• To administer and service your business relationship with us;
• In the event a member of the RAM Group International proceeds with a business transaction such as the purchase, sale; or
• Lease transfer, merger or amalgamation or any other type of acquisition, or disposal of, or taking of a security interest in respect of, an organization, your personal information may be shared with such prospective party to complete the business transaction.

Does Real Asset Management Share My Personal Information with Other Parties?

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 RAM Group International 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 Real Asset Management investment holdings;
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, Real Asset Management 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

Real Asset Management 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, credit reporting agencies (with respect to investors, borrowers and guarantors) 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.

What are Cookies and How Does Real Asset Management Use Them?

A cookie is a small file saved on your computer to help store preferences and other information that is used on webpages that you visit. We use cookies on our website so that our webpages “remember” who you are as you navigate from page to page and process any requests you may have. Typically, a cookie will contain a user or session identifier without containing personal information about the user. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We, along with third-party vendors such as Google use cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to track website and app performance.

Tracking

Using cookies when you visit our website, we may automatically collect statistics about your visit. This information does not identify you personally, but rather about your visit to our website. We may monitor statistics such as how many people visit our site, which pages people visit, from which domains our visitors arrive, and which browsers people use. We use these statistics about your visit for aggregation purposes, not to track what specific individuals are doing on our sites. We do this for many reasons, including the following:

to recognize new visitors to our websites;
to recognize past visitors;
to present more personalized content, to improve your website experience, optimize your browser experience, and provide site and service enhancements; and
so that we can better understand our investors, our borrowers, our website visitors, and their respective interests.

We may also occasionally send you informational e-mails or questionnaires. These e-mails may include links to our website or to the websites of other organizations. To enable us 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 Real Asset Management’s 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.

Turning off Cookies and Tracking

Through your browser settings, you can accept or decline cookies or set your browser to prompt you before accepting a cookie from the websites you visit. You can delete cookies that have been installed in the cookie folder of your browser. The various browsers provide different procedures to manage your settings. Click on any of the browser links below for instructions:

Microsoft Windows Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-managecookies
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=enUS&redirectslug=Enabling+and+disabling+cookies

If you are not using the listed browsers, you should go to the “Help” function for information on where to find your cookie folder.

Your Consent

By using our websites, you consent to the processing of data about you by Google and Real Asset Management in the manner and for the purposes set out in this Privacy Policy.

How Does Real Asset Management Obtain Consent to Collect, Use and Disclose Your Personal Information?

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 Real Asset Management. 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 info@ramgroupinternational.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.

If you are a borrower or guarantor, by completing an application for a loan, including a personal financial statement, you are giving your express consent for us to use the Personal Information provided by you during the loan approval process 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 products or services.

How Does Real Asset Management Protect The Personal Information It Gathers?

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

The following outlines our commitment to you:

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;
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;
Security, Retention and Disposal – your Personal Information is kept confidential and secure and is not disclosed to anyone outside of the RAM Group International without your consent, unless required by law, and your Personal Information will be appropriately disposed of when it is no longer needed; and
Access to and Correction – you have the right to access your own Personal Information, and to correct any inaccuracies.

Privacy Principles

Real Asset Management has always been, and will continue to be, committed to maintaining the accuracy, confidentiality, and security of your Personal Information. As part of this commitment, we have adopted the following principles for the protection of privacy pursuant to the Acts which govern Real Asset Management and which establish rules for the collection, use, and disclosure of Personal Information by the private sector.

Accountability: All Real Asset Management associates are responsible for maintaining and protecting all Personal Information under their control. Real Asset Management has designated an individual as Privacy Officer to oversee compliance with the Acts and our Privacy Principles.
Identifying Purposes: We will identify the purposes for which Personal Information is collected, either before or at the time of collection.
Consent: We will only collect, use, and disclose your Personal Information with your knowledge and consent except where otherwise required or permitted by law.
Limiting Collection: We will limit the collection of your Personal Information to only those details that are necessary for the purposes identified.
Limiting Use, Disclosure, and Retention: Your Personal Information will only be used or disclosed for the purposes for which it was collected, unless you have otherwise consented, or when it is required or permitted by law. We will only retain your Personal Information for the period of time required to fulfill the purposes for which it was collected.
Accuracy: We will keep Personal Information we collect as accurate, complete, and up-to-date as necessary to fulfill the purposes for which it was collected.
Safeguards: We will protect the Personal Information we collect with security safeguards appropriate to the sensitivity of the information.
Openness: Information about our policies and practices relating to the management of Personal Information will be made readily available to you.
Access: At your request, we will inform you of the existence, use and disclosure of your Personal Information, as well as give you access to the information. You have the right to challenge the accuracy and completeness of your information, and to amend it as necessary. (See Access to and Changing your Personal Information).
Challenging Compliance: You may contact us with any questions, complaints, or suggestions about this policy.

Security and Disclosure of Your Personal Information

We know you are concerned about the security of the information you provide to us. To address this concern, we have developed processes and procedures to keep your Personal Information safe and secure.

We have appropriate safeguards in place depending on the sensitivity of the information, including:

Physical: secured storage facilities and premises;
Technological: password-protected computers/files, firewalls, and a secured server;
Organizational: Real Asset Management associates trained in the importance of safeguarding your Personal Information from loss and unauthorized access and access limited within the Real Asset Management organizations to those associates that require your Personal Information or part of it to carry out the uses outlined above or otherwise communicated to you or for a legitimate business purpose; and
Third Parties: in the event we transfer your Personal Information to a third party, we assess their privacy procedures or take steps to require them to protect your Personal Information in a manner consistent with our own internal measures or as required by law.

Although we cannot guarantee against theft, misuse, unauthorized disclosure, loss, alteration or destruction of your Personal Information by a third party, we take reasonable precautions to prevent such unfortunate occurrences. We will strive to keep your Personal Information as accurate and as up-to-date as is necessary for the purposes for which it is collected.

Personal information collected by us may be used, processed, or stored outside of Canada and may be subject to disclosure in accordance with the laws of such foreign jurisdictions, which may be different than the laws in effect in the jurisdiction in which you reside.

Compliance with Canadian Anti-Spam Legislation

Real Asset Management has implemented a series of practices to comply with the consent and unsubscribing provisions for Commercial Electronic Messages (CEMs) in Canada’s Anti-Spam Legislation (CASL). Where consent is required by CASL, Real Asset Management ensures that you have expressly opted-in or have given your implied consent to receive Real Asset Management communications. To be in accordance with CASL, we agree to the following when using your email:

• 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. We will send you a “Notice of Withdrawal of Consent” within 10 business days of an unsubscribe request.

What are Your Rights to Access and Change Your Personal Information?

Accessing your Personal Information
You may access and verify your Personal Information and find out to whom it has been disclosed. At the time of your request, we will need specific information from you to verify your identity before we can provide you with the Personal Information we hold.

There may be instances when we will not be able to provide you with the Personal Information that you request. Examples are if the Personal Information:

Contains references to other persons;
Has already been destroyed due to legal requirements or because we no longer needed it for our purposes;
Is subject to solicitor-client or litigation privilege; or
Contains trade secrets or confidential business information of Real Asset Management and its affiliates or others cannot be disclosed for legal reasons or we are not legally required to disclose it.

Changing your Personal Information

We are committed to maintaining the accuracy of your Personal Information for as long as it is being used for the purposes we have identified. To help us keep your Personal Information up-to-date, we encourage you to notify us of inaccuracies or corrections as often as you wish. Notification of changes such as your address or telephone number will help us provide you with the best possible service.

If you identify any incorrect or outdated information requiring amendment, please contact our Investor Relations team, your dealing representative, Real Asset Management business contact, or mortgage broker, as applicable, the Privacy Officer, or the contact provided by us from time to time for such purpose. We may ask you to put your request for a correction in writing. We will make the proper changes and, upon your request, provide you with a copy of the corrected information.

How Long Does Real Asset Management 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, LiveIntent, 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 Real Asset Management’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 You Can Contact Us

If you have questions, concerns, or complaints about your privacy or Personal Information, you may contact us at the address listed below. 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.

190 Millway Ave, Unit 1-B
Vaughan, Ontario L4K 3W7
Attention: Privacy Officer
Tel: 647-828-2406
E-mail: info@ramgroupinternational.com

We will respond to your request or investigate your concern as quickly as we can.

This website is to be used for general information purposes only. The information in this site does not constitute an offer to sell or a solicitation to invest in the Corporation. Investors should consult their own counsel and seek advice from a registered Financial Advisor or Dealing Representative before making an investment decision.

Privacy Policy