Roth Canada, Inc. (“Roth Canada”) ensures that the personal information you provide to it is used only for the purposes for which it was intended. In January 2004, the Personal Information Protection and Electronic Documents Act, (“PIPEDA”) came into effect. PIPEDA governs the treatment of personal information that individuals provide to companies as part of a commercial relationship. Under the terms of this legislation we are required to obtain your consent with respect to the collection, use and disclosure of your personal information.

Please be advised you are not obligated to provide any personal information that we may request; however, failure to do so may result in your account application being denied or, for current clients, the services we currently provide to you may be delayed or in some cases denied. In addition, to help us keep your records current, please notify us of any material changes in the information you previously gave us. If you wish to obtain a set of the information that we have on file about you, or if you prefer to prohibit us from releasing certain information about you to third parties who are acting on our behalf, of you want to ask questions about our privacy policy, please contact Roth Canada’s Chief Compliance Officer at CCO@rothcanada.ca.

Roth Canada’s Privacy Statement

Protecting the privacy and safeguarding the personal and financial information of our clients and website visitors, if applicable, is one of our highest priorities. Our privacy policy explains how Roth Canada collects and protects your personal information.

By opening an account with Roth Canada or by using Roth Canada’s website, if applicable, you give your consent to the collection and use of personal information by Roth Canada as explained in this privacy policy.

Collection of Personal Information

When you open an account with Roth Canada, we obtain personal information about you that is kept on file in accordance with industry requirements. Only authorized employees, authorized third-party service providers, and regulatory authorities have access to this information.

We collect information required to open an account, to transact business effectively and to safeguard your privacy. To do this, we gather information from you to help us assess your needs and preferences.

The information we collect directly from you includes information required to communicate with you, including your name, mailing address, telephone number and e-mail address. In addition, we collect information required by law to identify who you are, including your social insurance number, passport number or tax identification number, as applicable. We also collect demographic information when you open an account, including gender, birth date, occupation and employment status. Our regulatory bodies also require us to assess your trading experience, your approximate annual income, approximate net worth, and available risk capital, all to assess your financial position.

You directly provide to us the majority of the information that we collect. You do this by completing the account application and related documentation, by placing a trade, by sending us an e-mail, or by submitting information in response to a promotion or special offer.

Use of Personal Information

Roth Canada may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your Client Account, issue you a Client Account number and a secure password, maintain your account activity, and contact you with account information. This information helps us improve our services to you, customize your browsing experience and inform you about additional products, services or promotions that may be of interest to you.

Should you close your account with us, Roth Canada will retain your information, but only to comply with applicable regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other valuable offers.

Disclosure of Personal Information to External Sources

Roth Canada may, from time to time, disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to us. We may also rely on external sources, such as credit agencies, to collect personal information about you.

Consent

Roth Canada requires your consent to the collection, use and disclosure of your personal information to administer your account in the normal course of business. Your consent is also required before we may provide your information to our affiliates and any third parties for the purposes described in this privacy policy. In certain situations, however, your personal information may be collected, used or disclosed by us without your knowledge or consent. These situations include: collection and use of publicly available information specified by regulation; disclosure to legal counsel for the purposes of obtaining advice; collection or use that is clearly in your interests in situations that we cannot obtain your consent in a timely way; use and disclosure to investigate a breach of an agreement or a contravention of a law; disclosure for the collection of a debt that you owe us; the use and disclosure of such information in an emergency that threatens your life, health or security; disclosure to comply with a subpoena, warrant or court order, or to otherwise comply with applicable law, including the applicable securities regulatory authorities.

Corrections to Personal Information

You may review the information you have provided to Roth Canada and make corrections to it. We request that you provide these corrections in writing, addressed to our Roth Canada’s Chief Compliance Officer: CCO@rothcanada.ca

Retention of Personal Information

We may retain your personal information on file after you cease to be a client of Roth Canada for as long as we require such information or as long as is required by regulatory requirements.

Having opened an account at Roth Canada, unless you advise us otherwise in writing to the attention of the Privacy Officer named above, we shall assume that you are providing us with consent to collect, use and disclose your personal information for the purposes as set out herein. Although you may refuse or withdraw your consent at any time to any of these purposes, please be advised that withdrawing your consent in certain circumstances may cause us by regulation, to be unable to administer your account.