Client Privacy Policy - Collection, Use and Disclosure of Personal Information

Scope and Application of Policy

Walton International Group (USA), Inc. and our related entities ("Walton USA") are committed to protecting and maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information Walton USA collects from or about you, how we use that information, and to whom and in what circumstances we disclose that information.

This Privacy Policy ("Policy") applies to all commercial and business relationships in which Walton USA is engaged. The Policy is intended to comply with privacy legislation relating to commercial activity in all jurisdictions in which Walton USA operates.

Privacy Officer

In order to ensure compliance with this policy and applicable privacy legislation, Walton USA has appointed a Privacy Officer. If you have any questions about the application of this Policy, please contact Walton USA’s Privacy Officer:

Collection, Use and Disclosure of Personal Information

For purposes of this Policy, "personal information" means any information about an identifiable individual, other than the person’s business title or business contact information when collected, used or disclosed in the course of commercial activity, to conduct business with you or provide services or products to you.

The type of information we collect about you includes the following:

• Information such as your name, home address, telephone number and e-mail address
• Social Security Number
• Copies of any agreements you enter into with us
• Information that you provide to us, such as your preferences, identities of your advisors and decision-makers, feedback and comments
• Financial affirmations and information

Walton USA uses the personal information for different purposes relating to the management of our business and our relationship with you. These purposes include, but are not limited to, the following:

• Establishing, maintaining and managing a business relationship with you so that we may provide you with services or products that you have requested
• Enabling us to comply with your requests such as preferred mode of communication
• Sharing your personal information with a party representing you, such as your investment representative, financial planner or to other third parties at your direction/consent
• Protecting our business from error, fraud, theft and damage to our goods and property
• Enabling us to comply with applicable law or regulatory requirements (including tax requirements)
• Other purposes reasonably required for the management of our business relationship with you and the management of Walton USA’s business

Currently, Walton USA shares your personal information only with its officers, directors, employees, auditors, agents, including ACS Securities Services, Inc. (Walton USA’s transfer agent and registrar), contractors and consultants, and other parties, including its subsidiaries and affiliated companies (the "Walton Group") who require such information to assist us with administering our business relationship with you. These include third parties that provide services to us or on our behalf, third parties that collaborate with Walton USA in the provision of services to you and third parties with whom we contract to perform our services.

In addition, your personal information may be disclosed or transferred to another party (including to another member of the Walton Group or an affiliate of Walton USA) in the event of a change in ownership of, or a grant of a security interest in, all or part of Walton USA through a sale transaction or some other form of business combination, merger or joint venture. We will disclose personal information in these circumstances only when the third parties agree to use such personal information solely for the purposes of evaluating and carrying out the transaction and, with respect to that information, to act in a manner consistent with the principles articulated in this Policy.

Apart from the foregoing, Walton USA does not otherwise share, use, disclose or transfer your personal information to anyone.

Consent

We require your consent to collect, use and disclose your personal information in accordance with this Policy. Consent may be expressed or implied. Express consent may be given orally or in writing, including electronic transmission. Implied consent is consent that can be reasonably inferred by your action or inaction. By providing us with the personal information described in this Policy, we assume you have provided implied consent to Walton USA to collect, use and disclose your personal information in accordance with this Policy.

You may withdraw or limit your consent to Walton USA’s collection, use and disclosure of your personal information at any time, subject to legal and contractual obligations you may have to us as a result of our business relationship. You must provide reasonable notice of the withdrawal of your consent. All communications with respect to the withdrawal or limitation of your consent should be directed to our Privacy Officer in writing.

In some circumstances, Walton USA is entitled to or required to disclose your personal information without your consent. These circumstances include, but are not limited to:

• Protecting your health or safety
• The disclosure is necessary for an investigation or proceeding
• The disclosure is required or authorized by law
• The disclosure is required to comply with a subpoena, warrant or order of a court or other body authorized to compel production of the information
• The disclosure is to a public body and relates to an investigation of an offence
• The disclosure is to a lawyer who is representing the Walton Group
• The disclosure is required to respond to an emergency
• Where the personal information is publicly available

Accuracy and Retention of Personal Information

Walton USA endeavors to ensure that any personal information in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If your personal information changes or you believe information we have about you is not accurate, please notify us as soon as reasonably possible. Any request to verify or correct your personal information must be made in writing to Walton USA’s Privacy Officer. In some circumstances, we may not agree to your request to change your personal information, but will instead append an alternative text to the record in question.

We keep your personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service, the nature of the information and as otherwise required by law. This period may extend beyond the end of your business relationship with us, but it will only be for as long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date and to comply with applicable law and regulatory requirements. When we no longer require your personal information, we will either destroy or erase it, or we will make it anonymous such that it cannot be associated with or tracked to you.

Safeguarding Personal Information

Walton USA is committed to protecting the security of your personal information. We endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Access to Your Personal Information

You may ask to see the personal information we have about you. A request to review your personal information must be made in writing to Walton USA’s Privacy Officer. Walton USA will endeavor to provide the information requested within a reasonable time from the date of the written request, or within the time otherwise required by law.

If you make a request to review your personal information, we may request specific information from you to enable us to confirm your identity and right to access such information. We may also require information that would assist us in locating your personal information. We may charge a fee to access your personal information; if so, we will notify you of that fee at the time you make your request or within a short time thereafter.

Walton USA reserves the right to decline to provide access to personal information in certain circumstances. These include, but are not limited to, circumstances where the information requested:

• Would disclose personal information, including opinions, about another individual
• Would disclose the Walton Group’s trade secrets or other confidential business information
• Is subject to lawyer-client privilege
• Is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information
• Does not exist or cannot be found
• Could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual
• May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions
• May be or is required to be, withheld by other legislation

Where information requested will not or cannot be disclosed, Walton USA will provide the reasons for the non-disclosure.

Revisions to this Policy

Walton USA may amend this Policy from time to time to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information.

Interpretation of this Policy

The Privacy Officer has the responsibility and authority to interpret and administer this Policy. This Policy does not create or confer any additional rights or obligations to those imposed under privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and applicable legislation, then this Policy will be interpreted to give effect to and comply with such privacy laws.