Privacy Policy

This Privacy Policy (the “Privacy Policy“) sets out the privacy policies and practices for
Steve Balaban/Mink Capital (the “Company“, “we“, “us“, “our“) with respect to how the Company collects personal information of its users, consumers, clients, service providers,
suppliers and other individuals (“you“, “your“). It also describes how the Company uses,
maintains, retains, transfers and discloses your personal information.

This Privacy Policy applies to information collected from you by the Company via (the “Website“) and other places where, or means by which, we
may collect personal information. This Privacy Policy also sets out how you can access
certain information that the Company may collect about you and explains the choices
you have regarding any collection, use, maintenance, retention, transfer and disclosure
of such information, and how you may access or correct that information. In this Privacy
Policy, “personal information” means any information about an identifiable individual or
information that allows an individual to be identified, as defined from time to time in
applicable privacy legislation. Personal information does not include business contact
information such as your name, title or position, business address, telephone number,
facsimile number or e-mail address.

Your Consent

collect, USE, MAINTAIN, retain, transfer and disclose such personal information in
accordance with this Privacy Policy and as permitted or required by law. Subject to legal
and contractual requirements, you may refuse or withdraw your consent at any time by
contacting the Company’s Privacy Officer at the address provided below. If you refuse or
withdraw your consent, you acknowledge that we may not be able to provide you, or
continue to provide you, with certain services, products or information. If you provide us
with personal information of another individual, you represent to us that you have that
individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose
that personal information in accordance with this Privacy Policy.

You are responsible for ensuring the accuracy of the personal information that you
submit to us. Inaccurate information will affect your experience when using the Website
and our ability to contact you as described in this Privacy Policy.

Amendments of This Privacy Policy

We may change, modify, add or remove portions of this Privacy Policy at any time and
from time to time, without prior notice to you. We will treat your continued use of the
Website following such change, modification, addition or removal as your acceptance of
such revisions. All revisions will be posted on the Website and will apply to any personal
information collected on or after the date posted. We will obtain the necessary consents
required under applicable privacy laws if we seek to collect, use, maintain, retain,
transfer or disclose your personal information for purposes other than those to which
consent has been obtained unless otherwise required or permitted by law.

This Privacy Policy was last updated on December 16th, 2018.

Collection of Your Personal Information

We may collect personal information in connection with your use of the Website or with
your use or purchase of the Company’s products and services, which may include
personal information provided in connection with the following activities:

  • Registering or filling in forms on the Website. This includes information you may provide
    when you request additional information about the Company’s products and services or
    sign up to receive the Company’s e-mail newsletters or coupons
  • Purchasing any product or service from the Company;
  • Requesting information or assistance from the Company. The Company may also keep a
    copy of any communications or correspondence you may send to it, including any e-mail
  • Using other features, including Interactive Functions (as such term is defined in the
    Website Terms of Use (the “Terms and Conditions“)) of the Website that may be
    offered from time to time, and may require such information in order to utilize the feature
    (including but not limited to making a User Submission as defined in the Terms and

The personal information that we may collect may include your name, email address,
age, date of birth, gender, telephone number, address, personal preferences, product
and service reviews, your location, your past and current investment practices, your
residency status, your employer or company name, your title, your investment capacity
and preferences and any other personal information that you choose to include in your
profile, your User Submissions (as defined in the Terms and Conditions), or in other
communications to the Company. We may combine personal and non-personal
information about you collected by us or by our affiliates and we may combine this
information with information from external sources.

In obtaining your consent to collect, use, maintain, retain, transfer and disclose your
personal information we will use reasonable efforts to inform you of the purpose for
which personal information will be collected, used, maintained, retained, transferred or
disclosed. The form of consent may vary depending on the circumstances and type of
information disclosed. We will take into account the sensitivity of the personal
information and your reasonable expectations when determining the appropriate form of


We may use a browser feature called a ‘cookie’ to collect information when you access
the Website. A cookie is a small text file containing a unique identification number that
identifies your browser, but not necessarily you, to our computers each time you visit the
Website. The information that may be collected includes the type of internet browser and
operating system you use, the domain name of the website from which you came, date
and duration of your visit, number of visits, the average time you spent on the Website,
pages viewed and number of cookies accumulated. Unless you specifically inform us (for
instance, by sending us correspondence from the Website), we will not know who you

are. In addition to the purposes described in our Privacy Policy, we may use such
Website information and share it with third parties with whom we have a commercial
relationship to measure the use of the Website, to improve the functionality and content
of the Website and to simplify your usage. You can reset your browser either to notify
you when you receive a cookie or refuse to accept cookies. If you refuse to accept
cookies, you may not be able to use some of the features available on the Website.

Online Communications

You may voluntarily submit personal information to us for purposes such as asking a
question, obtaining information, participating in a seminar or other event, reviewing or
downloading a publication, purchasing a product or service, subscribing to a newsletter
or a mail or e-mail list and participating in contests and surveys. If you are a registered
user on the Website, we may combine and store personal information about your use of
the Website and information you have provided to us with certain other online and offline
information we may have collected.

E-mail Communications

We may send you marketing or promotional e-mail communications. In this process, we
may collect certain information such as the date and time you first opened our e-mail
communications, the number of times you open our e-mail communications, the number
of instances you click through our articles and your total click-through activity on the
contents of our e-mail communications. We may also combine and store any such
information to manage and improve our e-mail communications. If you no longer wish to
receive any future marketing or promotional material from us, our promotional e-mail
communications will include instructions on how to unsubscribe and inform us of your

Third-Party Websites

We may include links to other websites on the Website or in our e-mail communications.
These third-party websites may collect your personal information and they may have
different privacy policies and practices than us. We do not assume any responsibility for
the privacy practices, policies or actions of the third parties operating these third-party
websites. We strongly encourage you to read the privacy policies of these websites to
enable you to make an informed decision whether or not to provide your personal
information to these websites’ operators.

Third-Party Analytics

To evaluate the usage of the Website, we use automated devices and applications
provided by third parties, such as Google Analytics (including Google Analytics’
Demographics and Interest Report). We use these tools to help us improve our products
and services, our performance and user experiences. These entities may: (a) use
cookies and other tracking technologies which collect information to perform their
services; and (b) collect personal information directly through the use of cookies and
other tracking technologies. Please go to the Google Privacy Policy to learn more. If you wish to opt out of Google Analytics data collection, please use the Google Analytics Opt-Out Browser Add-On.

IP Addresses

An IP address is a computer’s numeric address, by which it can be located within a
network. We may record your IP address when you visit the Website. We may use your
IP address to: (a) help diagnose problems with the Company’s server; (b) administer the
Website; (c) identify you when we believe it is necessary to enforce compliance with this
Privacy Policy or the Terms and Conditions; or (d) protect the Website and our systems,
information, employees, service providers, business partners, affiliates, users,
customers, distributors, retailers and others.

Protection of Your Personal Information

To: (a) prevent unauthorized access to, or disclosure of, personal information; (b)
maintain data accuracy; and (c) facilitate the appropriate use of your personal
information; we use physical, technological and administrative procedures to protect your
personal information that we collect from loss, unauthorized access, modification,
unauthorized disclosure or other misuse. Nevertheless, internet or wireless
transmissions are never completely private or secure. You understand that any
messages, content or information you send or submit through the Website may be read
or intercepted by others. If you have any questions about the security of your personal
information collected by us, please contact the Company’s Privacy Officer at the address

Use of Your Personal Information

Once we collect your personal information, we may use such personal information
internally, separately or in combination with any pre-existing information, for the
following purposes:

  • To develop, enhance, market, sell or otherwise provide information, products or services;
  • To assist with billing and the collection of accounts;
  • To provide you with transaction receipts;
  • To help us learn more about you, your financial goals and your preferences;
  • To produce aggregate insights or to generate statistics about you, your financial goals
    and your progress for our internal purposes as well as for commercial purposes such as
    marketing, selling or otherwise providing such insights and/or statistics to third parties;
  • To establish and conduct commercial relationships, including to process purchases or
    other transactions and to conduct or administer other transactions that you may engage
    in with us;
  • To conduct or administer contests, sweepstakes or other promotions in which you have
  • To contact you and to respond to any communications that you may have had with us;
  •  To troubleshoot problems with the Website;
  • To customize your experience or homepage on the Website;
  • To develop and manage our business and operations;
  • To enforce our Terms and Conditions and this Privacy Policy;
  • To conduct surveys, research, evaluations and measurement activities;
  • To market, sell or otherwise provide products and services of third parties with whom we
    have a commercial relationship;
  • To detect, and to protect the Company and other third parties against, error, negligence,
    breach of contract, fraud, theft and other illegal activity;
  • To audit compliance with our policies and contractual obligations;
  • To distribute our newsletters and other informational e-mail communications and other
    material to individuals on our mail and e-mail lists;
  • To obtain your feedback on the Website, our services and products;
  • To engage in business transactions, including the purchase, sale, lease, merger,
    amalgamation or any other type of acquisition, disposal, securitization or financing
    involving the Company;

As permitted by, and to comply with, any legal or regulatory requirements or provisions;

  • To use, maintain, retain, transfer and disclose your personal information if the Company
    is required to do so by law or legal process or if the Company determines, in its sole
    discretion, that such action is necessary to protect the rights of the Company, third
    parties and other users of the Website or to respond to your request for customer
    service; or
  • For any other purpose to which you consent.
    Disclosure of Your Personal Information
    Except as provided for in this Privacy Policy, we will not sell, rent, lease, commercially
    exploit or otherwise disclose your personal information or data to third parties unless: (a)
    we are required to do so by law or to cooperate with legal investigations; (b) it is
    required to protect the legal interests of the Company, including for credit checking and
    collection purposes or in connection with a potential financing, merger or acquisition; or
    (c) you provide consent to such disclosure.

Occasionally, we may disclose your personal information to:

  • Third-party service providers or vendors with whom we have a contractual relationship;
  • An organization or individual retained by us to collect outstanding debts;
  • A financial institution;
  • A person who, in our reasonable judgment, is providing or seeking the information as
    your agent;
  • Our personnel or contractors;
  •  Government authorities, insurers, regulatory agencies, benefits providers, consultants or
    agents; and
  •  Any third-party or parties, where you consent to such disclosure or where disclosure is
    required or permitted by law.
    In certain situations, we may use, maintain, retain, transfer or disclose personal
    information without your knowledge or consent (as permitted or required by law). These
    circumstances may be:
  •  Where your personal information is publicly available;
  • Where collection or use of the personal information is unmistakably in the interests of
    the individual and consent cannot be obtained in a timely manner;
  • To investigate a breach of an agreement or a contravention of law;
  •  In the event of a corporate change in control of the Company resulting from, for example,
    a merger, a reorganization, a sale of assets or bankruptcy;
  • To comply with a subpoena, warrant, court order or as required or otherwise permitted
    by law; and
  • When information is being collected for the detection and prevention of fraud or for law

Retention of Your Personal Information

After we have collected your personal information, we may retain a record of your
personal information (including correspondence or comments). We will continue to use,
maintain, transfer, disclose or retain your personal information for as long as necessary
to fulfill the purposes for which it was collected and as required or permitted by law.
However, we will take reasonable steps to destroy or permanently de-identify personal
information we hold if it is no longer needed for our business purposes.

To increase our efficiency, we use password-protected electronic file storage on cloud
servers based outside of Canada, in countries where laws regarding collection, use,
maintenance, transfer and disclosure of personal information may be less stringent than
the laws in Canada. We do not assume any responsibility for the privacy practices,
policies or actions of such cloud server providers or of any governmental authority of the
country in which such cloud servers are based.

Access to, and Correction of, Your Personal Information

If you do not want your personal information collected, used, maintained, transferred,
disclosed or retained by us as provided in this Privacy Policy, you should not use the
Website and you should refrain from: (a) registering for any specific tool or application
that collects personal information; (b) purchasing any product or service from us; and (c)
filling out any forms or questionnaires. You may request a copy of the personal
information which you have provided to us by advising our Company’s Privacy Officer at
the address provided below. If you have any questions or enquiries relating to our
privacy practices or procedures, or if you believe that the personal information that the
Company holds about you is not accurate, complete or up-to-date, you may write to the
Company’s Privacy Officer at the address provided below. If you are able to establish
that the information is not accurate, complete or up to date, we will take reasonable
steps to correct the information so that it is accurate, complete and up-to-date.

Non-Canadian Users

If you are located outside of Canada, please note that the information you provide to us
will be used, maintained, retained, transferred and disclosed in Canada, where laws
regarding use of personal information may be less stringent than the laws in your
country. By using this Website, you consent to such use, maintenance, retention,
transfer and disclosure. You also consent to the adjudication of any disputes arising in
connection with the Website, this Privacy Policy and the Terms and Conditions in the
Federal Court of Canada and the courts of the Province of Ontario.

Questions or Comments
We welcome questions and comments about this Privacy Policy. If you wish to access,
verify and/or amend your personal information or make a complaint under this Privacy
Policy, please contact the Company’s Privacy Officer at:

Mink Capital
Attn: Steve Balaban
120 Adelaide Street West, Suite 2500
Toronto, Ontario
M5H 1T1

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