Privacy Policy

HORIZONS ETFs BIGGEST WINNER CONTEST

PRIVACY POLICY

As of January 1, 2004, Canadian commercial organizations that collect, use or disclose personal information must comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). The purpose of the legislation is to let individuals know how organizations handle the personal information of their clients. Quebec, British Columbia and Alberta have similar privacy legislation.

Horizons ETFs Management (Canada) Inc. is committed to protecting your personal information. In respect of the Horizons ETFs Biggest Winner Contest (the “Contest”), we control access to, and the use of, such information according to the practices and procedures set out in this statement.

We will ask you for information that we need to establish your identity, to keep records, to prevent error and fraud, to comply with the law, to assess your eligibility for the Contest, and to provide you with the best possible service. Your personal information may also be used for marketing purposes, including sending you product information.

We will not sell your personal information.

What is Personal Information?
Personal information is any information that identifies an individual. This includes an individual's address, age, financial records, social insurance number, credit history, personal email address, employment information, financial information, home telephone number, occupation, date of birth, country of citizenship, bank references and types of accounts at brokerage firms.

Consent
You give your consent to the collection, use and disclosure of your personal information by registering to participate in the Contest, unless you instruct otherwise. You may withdraw your consent to the collection, use and disclosure your personal information at any time (other than for the administration of the Contest), subject to reasonable notice. We cannot accept a Contest participant who does not consent to the collection, use and disclosure of personal information for the administration of the contest.

Collection of Personal Information
We collect personal information about you through your activity on the Contest website, including during the registration process.

The use of personal information may include:

Whom do we Disclose Personal Information to?
Your personal information will only be used for the purpose(s) for which it was collected, in accordance with the Contest Rules. We may also have to, by law, provide information for a search warrant, court order, regulatory inquiry, or other legal request. We may also disclose personal information to help us collect a debt owed by the investor.

Access and Accuracy of Consent to Information
You have the right to verify the accuracy and completeness of your personal information. If you believe that any information we have collected about you is inaccurate or incomplete, you have the right to ask us to correct it. Sometimes, we may not be able to provide you with information if it contains references to third parties, is subject to legal privilege, is our proprietary information or relates to an investigation.

Any request to access, withdraw consent to or update information may be made by forwarding a written request to the Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us. We will respond to your request as quickly as possible but, in any event, no later than 30 days from receiving your request.

Protecting Client Information
We will maintain the security and confidentiality of personal information. We have policies, procedures and safeguards to protect your personal information against unauthorized access, theft or misuse. Security measures include physical, electronic and procedural safeguards such as passwords and restricted access to our office.

Our employees and service providers have access to personal information to enable them to perform their duties. As a condition of employment, each employee must agree to ensure the confidentiality of personal information.

Resolving Your Concerns
Inquiries and complaints will be reviewed by Kevin S. Beatson, Privacy Officer. For more information, please contact Kevin S. Beatson by privacyofficer@horizonsetfs.com.