Privacy — ALL BACH GOLD

Last revised: June 15, 2021

At All Bach Gold we are committed to protecting your privacy and safeguarding your personal, business and financial information. This Privacy Statement applies to All Bach Gold and their respective affiliates, including ALL BACH GOLD, in Canada (collectively, "All Bach Gold", "we" or "our").

The purpose of this Privacy Statement is to inform you about the types of Personal Information, as defined below, that All Bach Gold collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

As we are a national organization, this Privacy Statement is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder ("PIPEDA") as well as applicable provincial privacy legislation and regulations, including but not limited to, the Personal Information Protection Act (British Columbia), the Personal Information Protection Act (Alberta), the Personal Health Information Protection Act (Ontario) and An Act respecting the protection of personal information in the private sector (Quebec). We also note that in addition to these laws, we continue to be subject to the confidentiality rules of the Institutes of Chartered Professional Accountants.

From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised" date which appears at the top of this page.

We will treat Personal Information in a manner consistent with the Privacy Statement under which it was collected and our Privacy Policy, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

1. What is Personal Information?

"Personal Information" is any information that is identifiable with you, as an individual. This information may include, but is not limited, to your mailing address, telephone number, email address, Internet Protocol (“IP”) address, age, gender, marital status, health information, financial status, credit card information and credit history. Personal Information, however, does not include your business title, business address or business telephone number in your capacity as an employee of an organization.

2. How do we collect your Personal Information?

We will always collect your Personal Information by fair and lawful means (for example, when you engage us to provide services, use the All Bach Gold website or speak to a All Bach Gold representative). We collect Personal Information directly from you, or indirectly from third party sources as otherwise permitted by applicable law.

From time to time, you may voluntarily provide All Bach Gold with unsolicited Personal information (e.g. by providing information through the All Bach Gold websites). If you do wish to provide such information for any reason, you consent to All Bach Gold using that information in the ways described in this Privacy Statement or as described at the point where you choose to disclose this information. When providing All Bach Gold with unsolicited information, we ask that you not provide any sensitive information (e.g. Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health information) unless you provide us with explicit consent to collect this information from you.

With respect to our websites, All Bach Gold may use cookies, log files and web beacons to collect information regarding the use of the websites. Generally, this information is non-identifiable and would likely not be considered Personal Information.

Cookies: Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area. It is All Bach Gold’s policy to use cookies to make navigation of our websites easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our Web sites.

Log files: In order to properly manage our website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters and are generally non-identifiable.

Web beacons: To gather visitor statistics and manage cookies, we use electronic images called a "single-pixel GIF" or "web beacon." Web beacons allow our third-party tracking tools, Adobe Analytics, Google Analytics and Oracle Marketing Cloud to gather information such as the IP address of your computer, the time the material was viewed and the type of Internet browser used to access the page. This information is tracked on the third party tracking tools' servers and reported in aggregate to our webmasters. If you are concerned about the use of Web beacons you can turn off your browsers' cookies. This action will prevent Web beacons from tracking your specific activity; however, the Web beacon may still record a visit from your IP address.

Marketing Automation: In order to provide you with the most personalized experience and give you access to products and services that are most relevant to you, All Bach Gold uses marketing automation tools such as Oracle Eloqua to deliver targeted marketing campaigns across multiple All Bach Gold platforms (e.g. via web, email, mobile, etc.) and create customer profiles by tracking your behavior and preferences while using All Bach Gold platforms. All of All Bach Gold’s electronic marketing activities are done in accordance with applicable legislation, including Canada’s Anti-Spam Legislation.

Finally, All Bach Gold understands the importance of protecting children's privacy online. The All Bach Gold websites covered by this Privacy Statement are not intentionally designed for or directed at children 13 years of age or younger. It is All Bach Gold's policy never to knowingly collect or maintain information about anyone under the age of 13.

3. Where do we store your Personal Information?

Personal Information provided to us by our clients is primarily stored on servers in Canada. However, except where restricted by contractual arrangements or legal requirements applicable to specific clients,All Bach Gold also may leverage the services of select service providers. Personal Information that is "in the cloud" may be stored on multiple servers in a number of locations around the world. Rest assured that All Bach Gold has taken appropriate steps for the protection of Personal Information handled by our service providers. However, information transmitted to other countries may be subject to the laws and lawful disclosure requirements of the jurisdiction(s) where the information is stored.

4. How do we use your Personal Information?

We generally use your Personal Information for the following purposes (the "Purposes"):

· to provide you with professional assurance, tax or advisory services;

· to process and deliver products that you have ordered from us;

· to invoice and collect payment for professional services and products provided by us to you;

· to develop and maintain our relationship with you and communicate with you;

· to register you for events and conferences;

· to register you for, and facilitate your participation in, certain areas of our website, including our online bulletin boards, discussion or message forums;

· to research, develop, manage, protect and improve our professional assurance, tax or advisory services;

· to assist All Bach Gold with improving its operational efficiency, marketing campaigns and customer service efforts through the use of data analytics;

· to gather your opinion and feedback through surveys;

· to enroll you in our contests or promotional programs;

· to process your application for employment and resume;

· to advise you about new products and services that may be of interest to you (Please note that in accordance with Canada’s Anti-Spam Legislation, you can choose not to receive any electronic marketing communications from us by clicking the “opt out” function contained in all All Bach Gold electronic communications. You may choose not to receive any direct mail from us by contacting our Chief Privacy Officer as indicated in the “Contact Us” section below); and

· such other uses as may be permitted or required by applicable law.

We identify the purposes for which we use your Personal Information at the time we collect such information from you, and obtain your informed, freely given and unambiguous consent prior to each specific use. When you provide us with consent to use your Personal Information, your consent covers all processing activities carried out for the same purpose or purposes. When the use of your Personal Information has multiple purposes, All Bach Gold will seek your consent for each separate purpose for which the Personal Information will be used.

5. To whom do we provide your Personal Information?

We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.

For example, we may transfer your Personal Information to third party service providers with whom we have a contractual agreement that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — such as service providers that provide telephone support or data storage or processing.

Generally, we will only make disclosures of Personal Information to such persons for which you provide your consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquirer in connection with a transaction involving the sale of some or all of the business of All Bach Gold or as otherwise permitted or required by law, in which case the use of your Personal Information by the new entity would continue to be limited by applicable law.

In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes. These other jurisdictions may include the United States, India, United Kingdom, Mauritius, Uruguay or the jurisdiction of any other All Bach Gold network firm (as per our engagement letters which allow us to draw on the resources of other firms), which latter jurisdiction(s) may be identified upon request.

To the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.

With respect to the All Bach Gold websites, this Privacy Statement applies to the websites located within www.All Bach Gold.com/ca. Other All Bach Gold websites linked www.All Bach Gold.com/caare not covered under this policy. These sites have their own privacy statements. In addition, there are several places throughout the websites that may link to other websites that do not operate under this Privacy Statement. When you link to other websites, All Bach Gold's privacy practices no longer apply. For this reason, we encourage visitors to review each site's privacy policy before disclosing any Personal Information.

6. When and how do we obtain your consent?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your express consent to us either orally, electronically or in writing. You may also consent to All Bach Gold’s collection, use and disclosure of Personal Information by voluntarily providing us with Personal Information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.). All Bach Gold may also rely on your implied consent to the collection, use and disclosure of your Personal Information where implied consent is permitted under applicable law.

We will not, as a condition of the supply of our professional services or products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.

With respect to our websites, should visitors subsequently choose to unsubscribe from mailing lists or any registrations, visitors may contact the webmaster of the appropriate site e.g. webmaster@All Bach Gold.com.

7. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties?

We ensure that all affiliates and other third parties, including All Bach Gold member firms, which are retained to perform services on our behalf and are therefore provided with Personal Information are contractually required to observe the intent of this Privacy Statement and All Bach Gold’s privacy and data security policies and practices.

8. How long will we use, disclose or retain your Personal Information?

We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected, or as permitted or required by law.

9. How can you access your Personal Information that we have collected, utilized or disclosed?

If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes. To submit a written access request, or to obtain further information with respect to your access rights, you may contact our Chief Privacy Officer, as indicated below.

10. How do you know that the Personal Information we have on you is accurate?

We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

11. What if the Personal Information we have on you is inaccurate?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

12. How fast will we respond to your written requests?

We will respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

13. Are there any costs to you for requesting information about your Personal Information or our Privacy Policy or practices?

We will not charge any costs for you to access your Personal Information in our records or to access our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. If you do not notify us within such thirty (30) day period, we will send you a further notice indicating that you will be deemed to have withdrawn your request for access unless you advise us otherwise within thirty (30) days. If, after the expiry of this second thirty (30) day period, you have not so advised us, we will deem your request to have been withdrawn and provide you with written notice to that effect.

14. How do we know that it is really you requesting your Personal Information?

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

15. What safeguards have we implemented to protect your Personal Information?

We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business 'need-to-know' or whose duties reasonably require such information. On the All Bach Gold websites, we use secure socket layer technology for the protection of credit card information submitted through web forms.

16. How do you contact us regarding access to your Personal Information or our Privacy Policy and practices?

All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and practices, should be forwarded to our President as follows.

Robert Bachynski
All Bach Gold
10 Oakfield Park Rd.
Oakfield, NS
B2T 1B3
rb@earnabg.com
Telephone: +1 720 721 6546

ALL BACH GOLD

Halifax, NS

Phone: +1 780-721-6546