Legal framework.

Summary of changes

This legal framework was expanded and rewritten to reflect current Canadian legal and regulatory expectations for an investment company website. Highlights:

• —Rewrote the Terms & Conditions from a short notice into a full agreement covering eligibility, no-advice, IP, acceptable use, disclaimers, limitation of liability, indemnity, force majeure, changes, governing law and contact.
• —Rewrote the Privacy Policy for PIPEDA / provincial-privacy alignment, with new sections on categories of personal information, purposes, marketing (CASL), disclosure and service providers, international transfers, retention, safeguards, rights and complaints, and a named Privacy Officer contact.
• —Added a standalone Financial Services Disclaimer covering no-advice, no-offer, investor eligibility, regulatory-status placeholder, forward-looking statements, and no guarantee of allocation / returns.
• —Added a standalone Risk Disclosure covering capital loss, market/valuation risk, liquidity, concentration, IPO/transaction, currency/cross-border, information, regulatory, fees, past-performance and suitability risks.
• —Added a Website Disclaimer covering purpose, accuracy, illustrative content, third-party references, external links and availability.
• —Added a Cookie Policy covering strictly-necessary vs analytics cookies, no advertising cookies, and browser controls.
• —Added an AML/CTF Policy referencing PCMLTFA, FINTRAC reporting, sanctions/PEP screening, source of funds/wealth, ongoing monitoring, record-keeping, governance and prohibited business.
• —Added a KYC Policy covering identification/verification for individuals and entities, beneficial ownership, investor-status verification, suitability and refusal/termination rights.
• —Added a Complaint Handling Policy with submission channels, timelines aligned to Canadian securities-regulator expectations, escalation and record-keeping.
• —Added a Conflicts of Interest Policy covering identification, controls, disclosure, examples and personal-trading/outside-activity controls.
• —Added a Client Communications Policy referencing fair-clear-not-misleading, performance-information context, CASL and review/approval.
• —Added Electronic Communications Consent and Electronic Signature Consent aligned to PIPEDA Part 2 and provincial electronic-commerce statutes.
• —Added an Accessibility Statement referencing WCAG 2.1 AA and the Accessible Canada Act / AODA where applicable.
• —Added a Fees, Refunds & Cancellation page describing that the Site itself is free, that fees are governed by offering / engagement documents, and preserving statutory withdrawal rights.
• —Rebuilt the /legal hub as a directory of all legal pages plus a summary of changes and items requiring counsel review.
• —Added consistent cross-links between all legal pages and refreshed the footer to include every legal document.
• —Inserted clearly-marked placeholders for regulatory status, legal name, jurisdiction and forum, so no statement asserts a specific registration or licensing status without verification.

Items requiring counsel review

The following items were deliberately left as placeholders or drafted cautiously. Each should be reviewed by qualified Canadian securities counsel and updated to reflect the company's confirmed status before this website goes live.

1. Regulatory status: confirm registration category (EMD, portfolio manager, investment fund manager, etc.), CIRO membership (if any), and provinces of registration; update the Financial Services Disclaimer accordingly.
2. Legal name & jurisdiction: confirm exact registered legal name of the company, the province of incorporation, and its registered office / principal place of business; update Terms §12, Privacy §11 and Complaints contact block accordingly.
3. Governing law & forum: confirm the province of governing law and forum-selection clause in the Terms.
4. Complaints escalation channels: confirm the specific external recourse mechanisms available given the company's regulatory status (e.g. OBSI, AMF, provincial securities commissions, CIRO).
5. Registrations & memberships: verify any references to CIRO, CIPF, IIROC-legacy language, provincial securities regulators, and self-regulatory organisations.
6. Insurance & bonding: verify statements (if any are added later) about professional indemnity, fidelity bonding, or investor protection funds.
7. AML programme: verify appointment of Chief AML Compliance Officer, latest independent effectiveness review date, and any FINTRAC-reporting obligations that in fact apply.
8. Marketing statements: audit the entire Site for statements that could imply guaranteed returns, guaranteed IPO access, regulatory endorsement or misleading performance claims; remove or qualify as required.
9. Third-party company references (including named private companies and IPO content): confirm any express permissions required and that all references are clearly informational and non-endorsing.
10. Privacy Officer contact: confirm named Privacy Officer and dedicated privacy@ mailbox.
11. Cookie inventory: confirm the actual cookies and analytics tools in use match the Cookie Policy; add a consent banner where analytics cookies are set.
12. Accessibility: obtain a WCAG 2.1 AA audit and update the Accessibility Statement based on findings.
13. Cross-border data flows: identify the actual jurisdictions where personal information is processed and update the Privacy Policy accordingly.
14. Retention schedule: confirm document-retention periods aligned to PCMLTFA, securities legislation and tax legislation.
15. Electronic signature: confirm the e-signature platform used (if any) and its evidentiary controls.

Nothing on this Site should be treated as legal advice. The content of the legal pages is provided as a starting point and must be reviewed by qualified professionals before publication.