CLIENT PRIVACY POLICY - COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION AND APPLICATION POLICY

At Alphatron Capital Partners LLC and our related entities (“Surely Now LLC” and “LegacyWealth”), we are committed to protecting and maintaining the accuracy, confidentiality and security of your personal information as a client of Alphatron Capital. This Client Privacy Policy describes the personal information Alphatron Capital collects from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Client Privacy Policy (“Policy”) applies to all commercial and business relationships in which Alphatron Capital Partners LLC is engaged. The Policy is intended to comply with privacy legislation relating to commercial activity in all jurisdictions in which Alphatron Capital operates, where such legislation is in force. In the United States of America, to the extent that Alphatron Capital operates in provinces that have not adopted privacy legislation, this policy complies with federal legislation, which governs such jurisdictions.

COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

For purposes of this Client Privacy Policy, personal information means any information about an identifiable individual, other than the person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business with you or provide services or products to you.

The type of information we collect about you includes the following:

Alphatron Capital uses the personal information above for different purposes relating to the management of our business and our relationship with you. These purposes include, but are not limited to the following:

Alphatron Capital shares your personal information with its employees, auditors, contractors and consultants and other parties, including its subsidiaries and affiliated companies (the “Alphatron Capital Partners”) who require such information to assist us with administering our business relationship with you. These include third parties that provide services to us or on our behalf, third parties that collaborate with Alphatron Capital in the provision of services to you and third parties with whom we contract to perform our services.

In addition, your personal information may be disclosed or transferred to another party (including to another member of the Alphatron Capital Partners or an affiliate of Alphatron Capital) in the event of a change in ownership of, or a grant of a security interest in, all or part of Alphatron Capital through a sale transaction or some other form of business combination, merger or joint venture. We will disclose personal information in these circumstances only when the third parties agree to use such personal information solely for the purposes evaluating and carrying out the transaction and, with respect to that information, to act in manner consistent with the principles articulated in this Client Privacy Policy.

Alphatron Capital may contract with third parties located in one or more countries outside of Canada, including potentially in the United States of America or the European Union, to provide Alphatron Capital with processing, storage or other administrative or data-related services. Please be advised that in that case your information may be transferred to, processed, used and stored in those countries, and that the governments, courts or law enforcement or regulatory agencies located in those countries may be able to obtain disclosure of your information through the laws of, or pursuant to a lawful order made in, those countries.

CONSENT

We require your consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By providing us with the personal information described in this Policy, we assume you have impliedly provided Alphatron Capital with your consent to collect, use and disclose your personal information in accordance with this Policy.

You may withdraw or limit your consent to Alphatron Capital’s collection, use and disclosure of your personal information at any time, subject to your legal and contractual obligations you may have to us as a result of our business relationship. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to our office in writing.

In some circumstances, Alphatron Capital is entitled, or required, to disclose your personal information without your consent. These circumstances include, but are not limited to:

ACCURACY AND RETENTION OF PERSONAL INFORMATION

Alphatron Capital endeavors to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If your personal information changes or you believe information we have about you is not accurate, please notify us as soon as reasonably possible. Any request to verify or correct your personal information must be made in writing to Alphatron Capital’s office. In some circumstances, we may not agree to your request to change your personal information, but will instead append an alternative text to the record in question.

We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of your business relationship with us but it will only be for as long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.

SAFEGUARDING PERSONAL INFORMATION

Alphatron Capital is committed to protecting the security of your personal information. We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

ACCESS TO YOUR PERSONAL INFORMATION

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing to Alphatron Capital’s office. Alphatron Capital will endeavor to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. We may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Alphatron Capital reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:

Where information requested will not or cannot be disclosed, Alphatron Capital will provide the reasons for non-disclosure.

COOKIE POLICY

Alphatron Capital uses cookies and similar technologies such as JavaScript and HTML (“cookies”) on its websites to facilitate and improve your online experience.

HOW WE USE COOKIES

When you visit alphatroncap.com, your web browser will automatically download cookies to your device. Cookies allow for faster loading of website content and allows our site to help you navigate efficiently to obtain the information and services you have requested. Cookies also allow our site to remember your preferences such as language selection and help you to view information that is most relevant to your interests. Alphatron Capital’s third party content manager server uses cookies can to store session data so you can leave Alphatron Capital’s website, come back, and remain logged in.

REVISIONS TO THIS POLICY

Alphatron Capital may amend this Client Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Policy on our website at www.alphatroncap.com. We encourage you to review the website on a regular basis. Any changes to this Policy will be effective as of the date posted on the website.

© 2024 Alphatron Capital

Alphatron Capital, including affiliates and related entities the (“Surely Now LLC” and “Legacy Wealth”) do not make any representation or warranty about the accuracy, currency or completeness of this website or its content. This website and its content are for general information purposes, are not intended to provide you with any financial, accounting, tax or legal advice, and do not constitute an offer to sell or a solicitation of an offer to buy any real estate investments of the Alphatron Capital Partners.