Protecting your Privacy

This privacy policy (this “Privacy Policy”) applies to Foundation Wealth Partners LP and its affiliates (“Foundation Wealth”, the “Firm”) and explains how the Firm collects, uses, and discloses personal information in Canada through services provided to our clients, through its website located at www.foundationwealth.ca, and through other interactions with consumers.

In general, “personal information” means information about an identifiable individual, subject to more particular definitions or interpretations under applicable law. This information may include, but is not limited to: a client’s name, mailing address, e-mail address, financial information, and telephone number. This Privacy Policy does not apply to personal information about employees, partners, or other temporary or permanent staff, consultants, volunteers, or other individuals assigned to the Firm (each, a “Foundation Wealth Member”), or to any information that is not personal information as defined in or interpreted under applicable law.

What’s in this privacy policy?

This Privacy Policy covers the following topics:

· THE INFORMATION WE COLLECT AND HOW WE USE IT

· HOW WE COLLECT INFORMATION ABOUT YOU

· HOW WE DISCLOSE AND SHARE YOUR INFORMATION

· OUR WEBSITE

· YOUR CONSENT

· INTERNATIONAL TRANSFER AND STORAGE OF INFORMATION

· SECURITY

· ACCESS, CORRECTION, INQUIRIES, AND COMPLAINTS

· CHANGES TO THIS PRIVACY POLICY

· CONTACT US

The information we collect and how we use it

In general, we collect and use personal information for the following purposes:

Account Opening: When a client opens an account, personal information is collected and kept on file in accordance with industry regulations, including name, date of birth, address, citizenship, income, investments, debts, marital status, dependents, and social insurance number.

Only authorized employees, authorized third-party service providers and regulatory authorities have access to this information. The information collected allows the Firm to identify clients, to assess their investment needs, to provide financial products and services requested, to protect against possible fraud, to manage risks and operations and to comply with legal and regulatory requirements.

If you are an individual client, Foundation Wealth is required to collect, use and disclose your Social Insurance Number for income tax reporting purposes. The Firm may also share it with credit reporting agencies as an aid to identify you.

The Firm also collects an email address, a password, and information for security questions to allow clients to login into the Firm’s website.

Marketing Communications: The Firm may obtain your consent to use your information to send you marketing communications by mail or email that promote products and services that may be of interest to you. You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in marketing email communications or by contacting us as set out under Contact Us below. Please note that you may continue to receive certain required transactional or informational electronic communications from us.

Customer Service: When you contact the Firm with a comment, question or complaint, you may be asked to identify yourself (such as your name, address and a phone number) along with additional information that will assist in answering or responding to your inquiry or complaint. The Firm may retain this information to assist you in the future and to improve our customer service, and product and service offerings.

Employment: For individuals that have applied for a position at Foundation Wealth, personal information pertaining to the applicant such as your work experience, education information, and contact information will be collected. For candidates who are not offered or do not accept a position, their personal information will be retained for a reasonable period in the event that an appropriate position becomes available or that the candidate reapplies to Foundation Wealth. If the candidate accepts a position at FWP, the information will be retained in accordance with the Firm’s privacy procedures applicable to the personal information of Foundation Wealth Members.

Website: The Firm also collect some personal information through cookies, tracer tags and web beacons on our website. Please refer to the section below for more information on the use of these technologies.

How we collect information about you

The Firm typically collects personal information directly from you. However, there may be instances where this information is collected from third parties, including your advisor , credit reporting agencies, or other financial institutions.

How we disclose and share your information

Custodian: If you open an account with Foundation Wealth, we will share your personal information with a custodian so that they may provide services such as the safekeeping of your securities, trade execution, and clearing. Your personal information will be treated in accordance with the custodian’s privacy policy.

Service Providers: Foundation Wealth may also transfer your personal information to Service Providers used to administer or provide products, services or information on the Firm’s behalf such as hosting its website, operate certain features, send marketing messages or other communications, or managing and analyzing data and advertising effectiveness. The Firm uses reasonable measures to require the organizations with whom the client’s personal information is shared with only to perform the services the Service Providers have been contracted to provide.

Sale of Business: Foundation Wealth may also disclose certain personal information to parties connected with the proposed or actual financing, insuring, securitization, assignment, sale or other disposal of all or part of the Firm’s business or assets or as part of a corporate reorganization, or share sale or other change in corporate control, for purposes connected to evaluating and performing the transaction. These purposes may include determining whether to proceed with the transaction or business relationship, or fulfilling any records or other reporting requirements to those parties. The personal information the Firm may disclose includes personal and financial information obtained in support of your account application. Where applicable, the Firm will take steps to require that such parties treat your personal information in accordance with this Privacy Policy and use and disclose it only for the purposes for which it was collected, including to provide the services or information that Foundation Wealth would otherwise provide to you and generally to carry on Foundation Wealth business. The Firm’s successors or assigns may collect, use and disclose personal information for purposes similar to those described in this Privacy Policy or as otherwise permitted or required by applicable law.

Legal/Compliance: Foundation Wealth and its service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defense of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.

Our website

In general, anyone can visit Foundation Wealth’s website without submitting any personal information. However, usage patterns are tracked such as your internet service provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URLs you came from. The Firm uses this information to better understand and optimize its website service.

Cookies, Tracer Tags & Web Beacons: The website uses a technology called “cookies”. A cookie is a file containing a unique identification number that the website can send to your browser, which may then be stored on your hard drive so that the website recognizes you when you return. Cookies are used where you are prompted to log in. If you have registered with our website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information, and (3) will provide the Firm and its service providers with information that will be used to personalize the user’s experience in accordance with your preferences. Cookies also assist in understanding website activity which will aid in enhancing user experience.

Users may opt out of accepting cookies, which means tracking behaviour will not be recorded and may limit the features and functionality of Foundation Wealth’s website.

Analytics: Foundation Wealth’s website uses web analytics services such as Google Analytics. These services use cookies to help analyze how visitors use the website. For example, with Google Analytics, the information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage. You can prevent the storage of data relating to your use of the website by Google, as well as the processing of this data, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Additional information on Google Analytics’ collection and processing of data and data privacy and security can be found at the following links:

https://policies.google.com/technologies/partner-sites and

https://support.google.com/analytics/topic/2919631

Third Party Links: There may be direct links to third party websites within Foundation Wealth’s website. However, the Firm is not responsible for, nor accepts any liability for, the personal information collection, use, and disclosure practices of other entities to which the website may link to. You should consult the privacy policies of these other entities before providing any personal information on their websites.

Your consent

The Firm collects, uses and discloses your personal information with your consent or as permitted or required by law. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to Foundation Wealth, it is assumed that you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered.

Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to the collection, use and disclosure of your personal information or you may withdraw your consent on further collection, use, and disclosure of information about you, by contacting Foundation Wealth via email at CCO@foundationwealth.ca. Note that if you withdraw your consent to certain uses of your personal information, the Firm may no longer be able to provide certain services. There are instances where Foundation Wealth may collect, use, or disclose your personal information without your consent, for example, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.

You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in the Firm’s marketing email communications or by contacting us as set out under Contact Us below.

Use of Artificial Intelligence and Advanced Technologies

We may use artificial intelligence (“AI”) tools and other advanced technologies to support internal business activities, including research and analysis, investment management, product development, client support functions, and operational efficiency.

These tools may assist our professionals by analyzing information, identifying patterns or trends, generating research insights, or preparing draft materials. AI tools are used as decision support tools only and do not operate autonomously or replace human judgment. All investment decisions, advice, portfolio construction, and suitability determinations remain subject to human oversight and are made in accordance with applicable securities laws and our duty to act in the best interests of clients.

AI enabled tools may process market data, research materials, portfolio level information, and other business data. Where personal information is involved, it is handled in accordance with applicable privacy laws and our Privacy Policy. Where recordings are involved, such as AI-enabled meeting transcripts, we will obtain your consent prior to using such functionality. We maintain governance, security, and contractual safeguards designed to manage risks associated with AI use, including conflicts of interest, data protection, record keeping, and regulatory compliance.

AI tools may also be used to assist in preparing communications, educational materials, or informational content. Such materials are reviewed by our personnel and are subject to existing regulatory requirements applicable to client communications and marketing.

Our use of AI and advanced technologies is subject to ongoing governance, supervision, and review. We may refine or update our use of these tools over time as technologies and regulatory expectations evolve.

Retention of personal information

Foundation Wealth will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by Canadian privacy laws and securities laws and regulations.

International transfer and storage of information

Note that some of the Service Providers that process or handle personal information on the Firm’s behalf may be located outside of Canada, including in the United States. As a result, your personal information may be transferred, stored and/or processed outside Canada in connection with the purposes described in this Privacy Policy. While your personal information is outside of Canada, it is subject to the laws of the jurisdiction in which it is held, and may be accessed by government authorities in that jurisdiction pursuant to those laws. For more information on policies regarding foreign processing of personal information, contact the Firm’s Privacy Officer (contact information is at the end of this policy).

Security

Foundation Wealth has implemented reasonable physical, organizational, and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized Foundation Wealth Members, agents, and mandatories have access to your personal information.

Access, correction, inquiries, and complaints

If you wish to request access to, or correction of, your personal information in custody or control of Foundation Wealth, please make your request in writing to your Portfolio Manager or, alternatively, to the Chief Compliance Officer at CCO@foundationwealth.ca. The Firm may need to verify your identity before providing such information. In some circumstances, the Firm may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date.

Changes to this privacy policy

Foundation Wealth reserves the right to change this Privacy Policy at any time, and we will take reasonable steps to advise affected individuals of any material changes, if necessary.

Contact us

Please contact the Firm’s Privacy Officer if:

· you have any questions or comments about this Privacy Policy,

· you wish to access, update, and/or correct inaccuracies in your personal information, or

· there's any questions or complaints about the manner in which Foundation Wealth or its service providers treat your personal information.

You may contact the Firm’s Privacy Officer by email at CCO@foundationwealth.ca or by mail at the following address: Foundation Wealth Partners LP, Attn: Chief Compliance Officer, 1128 Yonge St., Suite 300, Toronto, Ontario, M4W 2L8.

Last updated: February 2026