This is the Privacy Policy (the “Privacy Policy”) which sets forth the policies of Form Retail Advisors Inc. and its affiliated entities (collectively, “Form”) regarding how Form’s representatives, including all Form employees, directors, officers, consultants, and contractors, may communicate with clients, and other third parties, in a consistent, accurate, fair and timely manner and aligned with all Canadian legislative regulations. The primary objective of this Privacy Policy is to inform our clients about our privacy practices, why Form collects personal information, and how such information is protected. In addition, we want to ensure that Form continues to have our clients’ consent to continue to collect, use and disclose our clients’ personal information for those explicit purposes.

Your use of www.form.ca (the “Site”) signifies your understanding and acceptance of the terms of this Privacy Policy and by using or registering with our Site or by providing personal information, you also agree to the terms of this Privacy Policy.

It is Form’s policy that all its communications with third parties comply with the requirements of Canada’s privacy legislation the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Canada’s Anti-Spam Legislation, (“CASL), and our own commitment to protecting our clients’ privacy.

TYPES OF INFORMATION FORM COLLECTS

References to “personal information” contained in this Privacy Policy means any information about an individual person who uses, or applies to use, the services of Form (including our Site); about an individual who is solicited by Form; and about an individual who is a party to a transaction involving Form. Personal information includes an individual’s name, address, date of birth, gender, marital status and financial information. Any disclosure of clients’ Personal Information outside of Form is made on a confidential basis, with said information to be used only for the purpose for which it was disclosed.

Personal information does not include:

(i) information pertaining to an organization as distinct from an individual person;

(ii) information provided by an individual in the capacity of an employee of an organization;

(iii) an individual’s name, address telephone number or e-mail address which is listed on a directory or is available through directory assistance; and

(iv) other information that is publicly available and is specified by regulations under the federal Personal Information Protection and Electronic Documents Act and similar provincial legislation.

Form collects Personal Information for the following purposes:

1.1. To establish and maintain a responsible commercial relationship with our clients and to provide ongoing professional services.

1.2. To distribute communications including marketing materials.

1.3. To better understand our client’s needs and preferences and continue to develop improved services to our clients.

1.4. To meet legal and statutory requirements.

Form may disclose Personal Information for the following purposes:

2.1. Form may disclose its clients’ Personal Information to a person who is a legitimate representative of the client.

2.2. Subject to provincial Real Estate Act Legislation, clients’ Personal Information may be shared among business units to help us serve our clients better and to provide them with professional services.

2.3. Form may disclose a client’s Personal Information to:

2.3.1. Another Commercial Real Estate Services provider who are party to the client’s

prospective transaction.

2.3.2. A company or individual employed or associated with Form in order to perform

or fulfill services on its behalf, such as research, design or marketing.

2.4. Form may disclose a client’s Personal Information to meet legal or regulatory requirements.

2.5. As part of any sale, merger or amalgamation of any part of our business, a client’s Personal Information will normally be a part of such transactions and therefore will be disclosed only for such a purpose.

Protection of Clients’ Personal Information

3.1. Form will not collect, use or disclose our clients’ Personal Information for any purpose other than those identified above, except with the client’s consent.

3.2. Form will protect our clients’ Personal Information with appropriate security measures.

3.3. Form will comply with any reasonable and lawful client request to access their Personal Information.

3.4. Form will protect the confidentiality of our clients’ Personal Information when dealing with third party companies.

3.5. Form will endeavor to keep our clients’ Personal Information as accurate and up-to-date as necessary for the purposes listed above.

3.6. Personal Information is protected with appropriate security measures, but may be available to government agencies under applicable law.

Form’s Anti-Spam Policy

Form has a strict zero-tolerance policy against spamming. All professionals must refrain from using our operating and messaging systems, including but not limited to email, instant messaging, or texting (collectively, “Electronic Address”) to distribute any unsolicited commercial electronic messages for which consent has not been received.

Form considers spamming to be any activity whereby a professional, directly or indirectly, transmits an electronic message to any Electronic Address for which prior consent of such electronic message has not been granted. Form’s professional staff must receive explicit consent from our client contacts, prior to sending any marketing email correspondence to our clients.

A client may choose to be excluded from our external communications and withdraw consent at any time, subject to legal or contractual obligations.

By using this Site, you signify your acceptance of our Privacy Policy. If you have questions or concerns about Form Retail Advisor’s Privacy Policy, or wish to exclude your personal information from our direct marketing, please contact us at the following email address: privacypolicy@form.ca