Privacy Policy

Privacy Policy – Website Use

First Avenue (“us”, “we” or “our”) operates www.firstavenuecounsel.com (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Identifying Information we receive from users of the Site.

We use your Identifying Information only for improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

Information Collection & Use

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name and email address (“Identifying Information”).

Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site

(‘Log Data”).

This Log Data may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze the above.

Communications

We may use your Identifying Information to contact you with newsletters, marketing or promotional materials and other information that would be applicable to our business and/or services.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier.

Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

Security

The security of your Identifying Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Identifying Information, we cannot guarantee absolute security.

Privacy Policy – Client Information

Canadian personal information protection legislation, including the federal Personal Information Protection and Electronic Documents Act (the “Act) regulates the way private sector organizations collect, use and disclose personal information. It does not apply to either corporate or not-for-profit organizations. Its main objective is to ensure personal information collected from clients is used for the stated purpose of such collection and to safeguard such information. “Personal information” is defined as information about an “identifiable individual”. Personal Information may include, but is not limited to, client:

• Name and contact information (address, phone number, email address)
• Nationality, origin, race, age, sex, or marital status
• Identification number, financial information, service history and other information on file
• Investment holdings data, transactional data, and risk tolerances
• KYC information, including copies of photo identification (driver’s license, passport, etc.)

Personal information that First Avenue Investment Counsel Inc.’s (“First Avenue“) has collected, including information for completion of the Investment Policy Statement, is subject to the requirements of the Act.

First Avenue recognizes the importance of privacy and recognizes the sensitivity of personal information received by it in the conduct of its business. This policy has been prepared with this objective in mind.

We collect personal information from clients to meet certain regulatory requirements and to help us establish an appropriate investment objective and risk tolerance for your Managed Accounts. This information typically includes personal information about our clients such as names, addresses, telephone numbers, birth dates, government-issued identification numbers and personal financial information. In some cases, we also collect information about individuals who are not our clients. For example, about spouses and partners of our client or about a person with authority over your Managed Accounts. Where practical, First Avenue will try to collect personal information directly from the person to whom the information pertains. However, where appropriate, we may collect personal information from publicly available sources.

The Act provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.

By retaining First Avenue for investment management services, we consider that you have consented to our collection, use or disclosure of personal information as necessary to properly represent you in investment matters. Where necessary, to fulfil our regulatory obligations, we may also collect personal information about individuals other than our clients in accordance with the provisions of the Act.

When we collect personal information about individuals directly from them, except in situations when their consent to the collection is deemed, we will advise them of the purpose for which the information is collected.

Obtaining consent from the individual after disclosure of the purpose for which the personal information is collected, used and disclosed, is a key element of the Act. However, this obligation is not absolute. The Act also permits us to collect, use or disclose personal information about an individual in some circumstances without the individual’s consent. Such circumstances include (but are not limited) to the following situations:

• The collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
• The collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
• The personal information is available to the public from a prescribed source; or
• The collection, use, or disclosure is required or authorized by a Federal or Provincial statute or regulation.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. The Act also allows us, for legal or business purposes, to retain personal information for as long as is reasonable but also imposes obligations upon us to ensure that procedures are in place to destroy the personal information when it is no longer required.

We recognize our professional and legal obligations to protect the confidential information of our clients. We also recognize our legal obligations to protect the personal information we have gathered about our clients and about other individuals during the course of our business. First Avenue has implemented policies and procedures to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

Pursuant to the Act, an individual may submit a written request to us to provide them with:

• A record of the personal information of the individual under our custody or control;
• Information about the purposes for which their personal information under our custody or control has been and is being used by us; and
• The names of persons to whom and the circumstances in which their personal information has been and is being disclosed by us.

We will respond to requests in the time allowed under the Act, and will make a reasonable effort to assist applicants, and to respond as accurately and completely as reasonably possible. Requests may be subject to certain fees and disbursements in accordance with the provisions the Act. An individual’s ability to access his or her personal information under our control is not absolute.

The Act provides that we must not disclose personal information where:

• The disclosure would reveal personal information about another individual and consent is not obtained: or
• The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
• The disclosure would reveal the identity of an individual who has, in confidence, provided us with an opinion about another individual, and the individual providing the opinion does not consent to the disclosure of his or her identity.

The Act further provides that we may choose not to disclose personal information where:

• The personal information is protected by any legal privilege, the disclosure of the information would reveal confidential commercial information, and it is not unreasonable to withhold that information;
• The personal information was collected by us for an investigation or legal proceeding:
• The disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided;
• The personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under an agreement, under an enactment, or by a court; or
• The personal information relates to or may be used in the exercise of prosecutorial discretion.

The above examples are not exhaustive, and you are encouraged to examine the provisions of the Act for a complete list.

An individual may also submit a written request to us to correct errors or omissions in the personal information of the individual that is in our custody or control. When provided with a written request, First Avenue will: correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact First Avenue’s Chief Compliance Officer or reach out to us via info@firstavenuecounsel.com.

If you are dissatisfied with our handling of your personal information, we invite you to contact our Chief Compliance Officer in writing, setting out the reasons for your concern. If you remain dissatisfied, you may wish to contact the Office of the Information and Privacy Commissioner. We also encourage you to obtain a complete copy of the Act to further determine the rights and obligations contained within that legislation and to obtain independent legal advice if considered necessary.

The contact information for the Office of the Privacy Commissioner and a copy of the Act can be obtained from the following link: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/.

Changes to this Privacy Policy

This Privacy Policy is effective as of April 14, 2026 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page, will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified Privacy Policy.

Contact: info@firstavenuecounsel.com