Disclaimer

Important Information — Please Read

Please take the time to carefully read the following as it contains important information regarding certain restrictions imposed by statute and the applicable securities regulatory authorities on the distribution of information through this website.

Material presented on this website should be considered general or for illustrative purposes only and should not be construed as investment or financial advice. Further, information on this website should not be construed as an offer or solicitation by the OceanFront Group of companies (“OceanFront”) to provide investment management services or to buy or sell any products. OceanFront does not represent that the securities, products, or services discussed on or accessed through this website are suitable for a particular investor. Each investor’s circumstances are different, and you should consult your investment advisor before acting on any information provided on this website.

The OceanFront website may contain hyperlinks to Websites operated by parties other than OceanFront. Such hyperlinks are provided for your reference only. OceanFront does not control such websites and is not responsible for their contents. The inclusion by OceanFront of hyperlinks to other Websites does not imply any approval or endorsement of the material on such Websites or any association with their operators.

The OceanFront Group of companies includes a number of entities and/or individuals registered as Portfolio Managers, Investment Fund Managers, Financial Advisors, Insurance Agents, and Financial Planners in various provinces and territories of Canada. The information provided on this website regarding each entity is directed solely towards qualified investors in jurisdictions where the appropriate entity is registered. Services offered by any entities in the OceanFront Group of companies are offered solely to qualified residents of the jurisdictions where the entities are qualified to do business.

Terminology

The following terminology applies to the Terms and Conditions, Privacy Statement and Disclaimer Notice, and any or all Agreements: “Client,” “You,” and “Your” refer to you, the person accessing this website and accepting the Company’s Terms and Conditions. “The Company,” “Ourselves,” “We,” and “Us” refer to our Company. “Party,” “Parties,” or “Us” refers to both the Client and ourselves, or either the Client or ourselves. Any use of the above terminology or other words in the singular, plural, capital letters and/or plural, and/or the Terms are considered interchangeable and therefore a reference to them.

Using our Services

By accessing or using any OceanFront Wealth Inc. website (“Site”) or mobile application that makes available our Services (“Services”) to clients (“Content”) and the Services offered thereof, you (and together with all persons accessing or using the Site or Content, the “Users”) signify that you have read, understand, and agree to be bound by the Terms and Conditions, along with any disclosures, addendum, or amendments to it, as the same may be amended or modified from time to time (collectively known as the “Terms and Conditions”) with OceanFront Wealth Inc. (“us,” “we” or “our”), in all respects concerning your access and use of the Site and Content. Your use of the Site, Content, and/or Services is subject to our Privacy Policy as defined herein. If you do not agree to be bound by nor comply with the Terms and Conditions, do not access the site and refrain from using the Services.

Using our Services does not give you ownership of any intellectual property rights in our Services or the Content you access. You may not use Content from our Services or website unless you obtain permission from its owner or are otherwise permitted by law. Don’t remove, obscure, or alter any legal notices displayed in or along with our Services and Content.

In connection with your use of the Services or Content, we may send you service announcements, administrative messages, and other information. You may opt-out of some of those communications. Some of our Services are available on mobile devices. Do not use such Services in a way that distracts you and prevents you from obeying traffic or safety laws.

Terms of Use

This website and any site content are provided to you on an “as is” basis without any representation, warranty, or condition regarding accuracy, reliability, or completeness.

OceanFront and its directors, officers, employees, and advisors exclude all warranties or conditions of any kind, whether express, implied, or statutory, in connection with this website and any content exported or downloaded from it.

OceanFront, its directors, officers, employees, and advisors will not be liable to you or anyone else for any consequential, incidental, special or indirect damage to your computer, mobile device, or tablet, such as loss or corrupted data, loss of profit, any losses resulting from the use of this website or any products or services deleted on this website which you suffer arising from your use, or inability to use, this website, whether or not, the circumstances giving rise to such loss or damage may be within the control of OceanFront or any other party providing support of software or services for this website.

You agree to indemnify, defend and hold harmless to OceanFront, including its directors, officers, employees, and advisors, harmless from an against any and all liabilities, expenses, and costs, including without limitation reasonable legal fees and expenses, incurred by OceanFront and related parties in connection with any claim related to the use of the website.

Amendments and Modifications. OceanFront has exclusive control over its website. We reserve the right to amend the Terms and Conditions or modify or discontinue any portion of the Services, features, and functionality related to the operation of our Site and the Content from time to time without prior notice. If changes are made, the updated Terms and Conditions shall be posted on the website, and those changes will be reflected and effective at such time. We reserve the right to modify or temporarily discontinue your access to the website, the Content or portion thereof, or any Services, with or without before you. You are responsible for checking the latest information available herein to inform yourself of any change. Do not access or use the Site or Content if you do not agree to any amendments or modifications made to the Terms and Conditions.

Limitations. The access to and use of the Site, Content, and Services depend on the internet, including but not limited to networks, cabling, facilities, and equipment that are not in our control. Accordingly, (i) any representation made by use regarding configuration, access performance, speeds, reliability, availability or system uptime, use or consistency of the Site is on a “commercially reasonable efforts” basis (ii) we cannot guarantee any minimum level relating to performance, speed reliability, availability or system uptime, use or consistency and (iii) data, messages, information or material sent over the internet may not be completely private, and your anonymity is not guaranteed. We assume no responsibility for the timeliness, accuracy, deletion, non-delivery, or failure to store any user data, loss of user data, communications, or personal settings.

Privacy and Confidentiality

We are committed to protecting your privacy. At OceanFront, the safety and security of your privacy and personal information are paramount and essential to the long-term success of our business. We have adopted this policy to formalize our conduct governing collecting, using, and disclosing our clients’ personal information.

“Personal Information” is defined as information that can be used to identify you as an individual, including your name, age, address, personal, financial, and other details and any other identifying information about you that you provide us when you apply for or when we enter into an agreement to provide you with wealth management services.

OceanFront’s privacy policies explain how we handle your personal data and protect your privacy when using our Services. This policy applies to the operations of OceanFront and its affiliates and to all of the services and products we offer our clients. You agree to collect, use, and disclose your personal data under our Privacy Policy by using this website. By using our Services, you agree that OceanFront can use such data in accordance with our privacy policies.

Reference throughout this policy to “we,” “our,” “us,” and “OFIC” means OceanFront Investment Counsel Inc. and its affiliates. We will rely on the following principles concerning gathering, using, retaining, and securing client information. At OFIC, we are dedicated to ensuring your confidentiality by protecting the personal, business, and financial information entrusted to us. This dedication is fundamental to the way we do business. Only authorized employees within the company can access and use information collected from individual customers in the course of their duties.

We do not sell or distribute our clients’ information to third parties for marketing or soliciting any products or services.

Your Information is Necessary

We ask you for information to (a) establish and maintain responsible commercial relations with clients, (b) provide ongoing service, and (c) meet our legal obligations and regulatory requirements.

Information that we collect

From the beginning and throughout the course of our relationship, we collect information about you. We collect some information from our client agreements, including our Investment Management Agreement and Investment Policy Statement. This information includes:

• Information establishing your identity, such as your full legal name, address, phone number, work position, employer, email address, date of birth, social insurance number (for tax purposes), and account numbers;
• For individuals, information relating to your employment, risk tolerance, and the intended use of your investment account(s);
• For entity clients, information concerning your business name, address, phone number, email address, industry type, nature of your business, details on the beneficial owners, authorized persons, and directors;
• For trusts, information including settlors, trustees, and beneficial owners, address, phone number, email address, industry type, and other details on all authorized persons and those who have a financial interest in the account(s); and
• Additional information to meet our legal and regulatory obligations.

Use of Your Information

We use your information for a variety of purposes. It is used to help us provide wealth management services and satisfy information requests from regulators and other organizations or individuals legally entitled to make such requests. We use your information to (a) verify your identity; (b) manage your investments; (c) communicate with you; (d) understand your financial situation and goals; (e) manage our risks and operations; and (f) meet our regulatory and legal requirements.

Sharing Your Information

OceanFront Group combines a number of different investment teams with unique and diverse wealth management expertise. OceanFront Group provides an ensemble approach to client service, including Financial Planning, Portfolio Management, and other back-office support functions to its affiliated wealth management teams. Your personal information may be shared with the OceanFront Group. This information sharing allows us to more efficiently provide: (a) investment management and client relationship services; (b) investment and tax reporting; and (c) crime and fraud prevention, suppression, and detection. It also allows us to meet our legal, financial, and reporting obligations.

We may also use outside service providers or agents to perform services on our behalf, including custodial, trustee, legal, marketing, mail distribution, or third-party data processing services. These service providers may at times be responsible for processing or handling personal information and are only provided the information necessary to perform the services they have been engaged to provide.

We are committed to keeping your personal information safe, secure, and confidential. We will only share your information with third parties as described in your agreement with us or under the following circumstances:

• To respond to valid and authorized information requests;
• As permitted or required by law;
• To help prevent crime, fraud, money laundering, and terrorist financing;
• To protect the safety of employees, clients, or other third parties; or
• In situations where we have your consent.

When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the legally required information.

Cookies

We use cookies and similar technologies, which may be provided by third parties, on our website to enable certain functionality for security and fraud detection and prevention, analyze usage information about our site and personalize content for you. While the data collected by cookies doesn’t directly identify you, we may use it with other information, including personal information, as needed to meet these objectives. You can opt out of cookies and related tools by adjusting your device and browser settings, although some website features may not function properly when cookies are disabled.

Accuracy and Safeguarding Information

We make reasonable efforts to ensure the information we have about you is accurate, up-to-date, and complete. Given that we make decisions based on our information, we encourage you to help us keep your information current.

Having accurate information about you enables us to give you better service. It minimizes the possibility that out-of-date information may be used to make a decision that impacts you. We have procedures and practices in place to help us maintain the accuracy of your information, and we rely on you for such information. You can help by informing us of any changes, such as changing your address or phone number. Please let us know if any of your information on file is inaccurate, incomplete, or out of date.

We will protect your information with appropriate safeguards and security measures. We retain your information only for the time required and provide you with our investment management services. This period extends beyond the end of our relationship but only for as long as we must meet our legal and regulatory requirements and for as long as we must respond to any outstanding matters. Some non-specific information may be retained for statistical analysis and other internal purposes. When your information is no longer needed, we have procedures to destroy, delete or convert it to an anonymous form.

All our employees are familiar with the procedures required to safeguard client information. They are required to maintain the confidentiality of such information at all times; failure to do so will result in appropriate disciplinary measures. Protecting your information is an essential part of our job. Only authorized employees can access it to protect your information, and all employees sign a confidentiality agreement when hired. Additionally, all employees annually certify that they have complied with our privacy policy.

Your Consent

You are always in control of your personal information. Providing us with your information is always your choice. By establishing an account with us, you have consented to disclose your personal information to a third party in the circumstances or for the purposes described in this policy. Your decision to withhold information or withdraw consent concerning our use of your personal information may prevent us from taking you on as a client or continuing to work with you as a client. You can withdraw your consent at any time, subject to the requirement of reasonable notice and any legal or contractual restrictions, by writing to us.

Access To Your Personal Information

In the normal course of business, you receive periodic access to information in the form of transaction activity records, including account statements. This information is available to you through mailings and secure online sites. If you would like to verify the accuracy of your personal information or receive a copy of this policy, please submit a request at compliance@oceanfrontwealth.com. Upon such request, we will give you access to the information we retain about you.

Addressing Your Concerns

If you have any questions or concerns about privacy, this policy, or your personal information, we encourage you to let us know. Please include your full name, address, and telephone number if you choose to mail, fax, or email us @ compliance@oceanfrontwealth.com.

Disclaimers, Limits of Liability and Indemnities

User Acknowledgement. You acknowledge and agree that: (i) all use of the site and/or the Content provided by us is at your own risk; (ii) the site and the Content may contain links to other websites, which are provided solely as a convenience to you and the inclusion of any such link does not imply endorsement, investigation or verification by us of such websites or the information contained therein; and (iii) the site and the Content provided under the Terms and Conditions are provided on an “as is” and “as available” basis without warranty of any kind.

Disclaimer of Warranties. We make no conditions, warranties, or representations about the suitability, reliability, usability, security, quality, capacity, performance, availability, timeliness, or accuracy of the site, the Content, or any other services and products supplied under the Terms and Conditions. We expressly disclaim all conditions, warranties and representations, express, implied or statutory, including implied conditions or warranties of merchantability, fitness for a particular purpose, durability, title, and non-infringement, whether arising by usage of trade, by course of dealing, of performance, at law, in equity, by statute or otherwise howsoever.  We do not warrant that your use of the site or the Content will be uninterrupted, error-free, or secure, that defects will be corrected, or that the site, the Content, or the server(s) on which the site and/or the Content are hosted are free of viruses or other harmful components.

No Liability. Notwithstanding any other provision of the Terms and Conditions, in no event will we, our affiliates, or our controlling parties, agents, employees, suppliers, resellers, distributors, advertisers, sponsors and agents (collectively, in these capitalized sections, “we” or “us”) be liable for any direct, indirect, special, incidental, consequential or punitive damages, or any other damages or losses whatsoever, including damages for loss of profits, goodwill, opportunity, earnings, use or data, arising directly or indirectly from or related to the Terms and Conditions or the use, or non-use of the site and/or the Content or any software, regardless of the cause of action and even if one or more of us have been advised of the possibility of such damages or losses, including damages or losses arising from or in any way related to the following: (i) any loss or damage to data arising directly or indirectly out of use or non-use of the site and/or the Content or related component; (ii) delays, errors, interruptions, mistakes, omissions, non-delivery, incorrect delivery, or defects on or related to the site and/or the Content. Your sole remedy for dissatisfaction with the site and/or the Content is to stop using the site and/or the Content. Without restricting the foregoing, if circumstances arise in which you or another party is entitled to recover damages from one or more of us, the aggregate liability of us for damages is limited to the amount paid to us by you through the site or the Content during the six months preceding the circumstances in which such liability arises.

Applicability. Some jurisdictions prohibit the disclaimer of certain warranties or conditions or the limitation of certain types of liability. In such circumstances, to the extent that such prohibitions prohibit any exclusions and limitations in the Terms and Conditions, such exclusions and limitations will not apply to you strictly to the extent necessary to make the Terms and Conditions consistent with such prohibitions.

General Terms

Waiver of Rights and Remedies. Our failure to insist upon or enforce strict performance of any provision of the Terms and Conditions will not be construed as a waiver of any provision or right. Neither the course of conduct between you and us nor trade practice will act to modify any provision of the Terms and Conditions. Our rights, powers, and remedies in the Terms and Conditions, including without limitation the right to suspend, restrict, withdraw or terminate any use of the Site and/or the Content, are cumulative and in addition to and not in substitution for any right, power or remedy that may be available to us at law or in equity.

Severability. If any provision of the Terms and Conditions is determined to be invalid or unenforceable in whole or in part, such invalidity or unenforceability will attach only to such provision or part thereof, and the remaining part of such provision, all other provisions hereof will continue in full force and effect.

Assignment and Enurement. We may at any time assign our rights and obligations under the Terms and Conditions, in whole or in part, without notice to you. You may not assign the Terms and Conditions without our prior, written consent. The Terms and Conditions will enure to the benefit of and bind you and us and our respective personal and legal representatives, successors, and permitted assigns.

Entire Agreement. The Terms and Conditions, as amended from time to time, including any and all documents, websites, rules, terms, and policies referenced herein, including but not limited to the Privacy Policy, constitutes the entire agreement between you and us concerning the matters referred to in the Terms and Conditions and supersedes all prior and contemporaneous agreements and understandings, whether electronic, oral or written, between you and us with respect to such matters.

The Terms and Conditions of this agreement shall be governed by the law of British Columbia and the Federal laws of Canada, where applicable.

Complaint Handling Process

OceanFront Investment Counsel Inc. (“OFIC”) Inc. is committed to providing exceptional service to all its clients, including the prompt and fair resolution to any client complaint. You may direct any complaints relating to your account to the Chief Compliance Officer, OceanFront Investment Counsel Inc. 2772 – 1055 West Georgia Street, Vancouver, B.C. V6E 4N3.

In filing a complaint, you are expected to advise the nature and details of the complaint, when it happened, and what your expectations are. OceanFront Investment Counsel Inc. will formally acknowledge receipt of a complaint in writing within five business days of its receipt. As soon as practically possible within 90 days upon receiving a complaint, OceanFront Investment Counsel Inc. will provide a written assessment detailing the results of its investigation and an explanation of our position and decision.

In the event you are not satisfied with the outcome, you may seek independent dispute resolution services from the Ombudsman for Banking Services and Investments (OBSI) www.obsi.ca by email at ombudsman@obsi.ca, phone at 1-888-451-4519, or fax at 1-888-422-2865. You may only file with OBSI following the expiry of 90 days from when the complaint was first raised with OceanFront Investment Counsel Inc. directly and within 180 days following OceanFront Investment Counsel Inc.’s response to your complaint. You have the option to use your own resolution service at your own expense.