Privacy Policy

Randy Rosenblat

Last updated: September 3, 2026

Objective

To ensure that:

(a) I am in compliance with regulatory and self-regulatory requirements regarding privacy ("Regulations");

(b) A client's privacy is handled in a professional manner, in a secure environment, and appropriately monitored.

The Privacy Officer

I, Randy Rosenblat, am the Privacy Officer for my practice. All privacy-related inquiries or complaints should be directed to me. I am hereby designated as responsible for the application of this policy.

My Commitment

My clients are my business. As an advisor, I am trusted with some of my clients' most sensitive personal information. I respect that trust and want my clients to be aware of my commitment to protect the information they provide in the course of doing business with me.

I collect personal information in compliance with applicable laws and ethical business practices, in order to provide services and conduct business. I limit the information I collect to what is necessary for, or related to, these purposes.

I abide by the Ten Privacy Principles, based on the federal government's privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA):

1. Accountability: I am responsible for personal information under my control and am designated as accountable for compliance with these principles.

2. Identifying Purposes: The purposes for which personal information is collected are identified at or before the time the information is collected.

3. Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except when inappropriate.

4. Limiting Collection: Collection of personal information is limited to what is necessary for the identified purposes, and is collected by fair and lawful means.

5. Limiting Use, Disclosure, and Retention: Personal information is not used or disclosed for purposes other than those for which it was collected, except with consent or as required by law. It is retained only as long as necessary to fulfill those purposes.

6. Accuracy: Personal information is kept as accurate, complete, and up-to-date as necessary for the purposes for which it is used.

7. Safeguards: Personal information is protected by security safeguards appropriate to the sensitivity of the information.

8. Openness: Specific information about my policies and practices relating to the management of personal information is made readily available.

9. Individual Access: Upon request, an individual is informed of the existence, use, and disclosure of their personal information and given access to it, and may challenge its accuracy and completeness.

10. Challenging Compliance: An individual may address a challenge concerning compliance with the above principles to me as the designated Privacy Officer.

Information Collection And Use

I collect the information required to complete the task for which I am engaged, whether that is insurance, investment products, or financial planning.

Personal information is information that refers to you specifically. I use fair and lawful means to collect your personal information, and I only collect information that is pertinent and consistent with the purposes of collection. Whenever practical, I collect the required information directly from the client, or from their authorized representative(s), through completed applications and forms, other correspondence (such as phone, mail, or the internet), and through business dealings with me.

What I Need To Know And Why

I collect information from my clients and about them only with their consent, or as required or permitted by law. In general, I will collect personal information such as name, address, telephone number(s), or other identifying information, such as Social Insurance Number (SIN) or date of birth.

The type of additional information gathered depends on the product or service involved. This may include financial information (such as place of employment, annual income, assets, and liabilities), investment or advice-related information (such as financial goals and retirement plans), and, if applying for insurance or group benefits, health-related or lifestyle-related information such as occupation, travel history and plans, driving record, or criminal record.

Consent

Consent is required for me to establish a file and to collect and maintain personal, medical, and financial information, and is documented and placed in the client's file.

Protection Of Personal Information

As the advisor, I am granted access to client information and understand the need to keep that information protected and confidential. My procedures clearly communicate that information is to be used only for its intended purpose(s). If I hire a staff member, they are required to sign a confidentiality agreement upon commencement of employment.

Retention Of Personal Information

I keep a client's personal information in my records only for as long as needed to fulfill the identified purposes, or as required or permitted by law.

Your Privacy Choices

• You may request copies of my privacy policies and procedures at any time.
• You may request access to your information. I will respond to this request as quickly as possible, and no later than 30 days after receipt of the request.
• You may withdraw your consent at any time by contacting me as the Privacy Officer. However, you will be made aware that failure to provide adequate information may prevent me from completing the task for which we were engaged.
• You may file a complaint about my privacy procedures, or about a breach of my privacy policy. Complaints should be received in writing and directed to me as the Privacy Officer. I will contact you, obtain all details, review the circumstances, and determine whether the existing privacy policy needs to be altered. Insurance carriers will be notified of any complaint involving their clients or products, where applicable.

Exceptions To Client Access

I must refuse an individual access to their personal information if:

• it would reveal personal information about another individual, unless there is consent or a life-threatening situation;
• the information has been disclosed to a government institution for law enforcement or national security reasons and that institution has instructed that access be refused.

I may refuse access to personal information where it:

• is subject to solicitor-client privilege;
• is confidential commercial information;
• could, if disclosed, harm an individual's life or security;
• was collected without the individual's knowledge or consent for the purpose of investigating a breach of an agreement or a contravention of law (in which case the Privacy Commissioner is notified);
• was generated in the course of a formal dispute resolution process.

Contact

Questions, requests, or complaints about this policy should be directed to:

Randy Rosenblat, Privacy Officer

Licensed in BC, ON

Services provided through HUB Financial Inc.

Phone: (416)882-3061

Email: RandyRosenblat@outlook.com