Privacy Policy

1. Introduction

North Front Advantage ("we," "our," or "the Company") is committed to protecting the privacy and confidentiality of personal information entrusted to us by asset holders, capital partners, and other parties with whom we conduct business. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

This policy applies to all personal information collected by North Front Advantage in the course of our resource asset advisory and transaction services, whether through our website, email correspondence, telephone communications, or in-person meetings.

2. What Personal Information We Collect

In the course of providing resource asset advisory services, we may collect the following categories of personal information:

2.1 From Asset Holders

• Contact Information: Name, title, company affiliation, business address, telephone number, and email address
• Asset Details: Property descriptions, mineral rights information, land titles, technical reports, financial data related to assets, ownership structures, and valuation information
• Transaction History: Previous divestiture activities, sale mandates, and transaction preferences
• Due Diligence Documentation: Corporate records, title certificates, royalty agreements, and other documents necessary for transaction facilitation

2.2 From Capital Partners and Buyers

• Contact Information: Name, title, company affiliation, business address, telephone number, and email address
• Investment Profile: Asset acquisition criteria, geographic focus, capital capacity, investment thesis, and strategic objectives
• Qualification Information: Proof of funds, corporate structure, authorized signatories, and regulatory compliance documentation

2.3 Website and Technical Information

• Usage Data: IP address, browser type, device information, referring URLs, pages viewed, and time spent on our website
• Cookies and Tracking: We may use cookies or similar technologies to enhance user experience and analyze website traffic (see Section 8)

3. How We Use Personal Information

North Front Advantage uses personal information for the following purposes, each of which is necessary for the provision of our advisory services:

3.1 Transaction Facilitation

• Assessing the suitability of assets for potential transactions
• Matching asset holders with qualified buyers based on investment criteria
• Organizing and presenting transaction documentation
• Coordinating due diligence processes and confidential negotiations

3.2 Client Communication and Relationship Management

• Responding to inquiries and providing advisory services
• Maintaining ongoing client relationships and transaction updates
• Sending industry insights, market intelligence, and relevant opportunities (with consent)

3.3 Compliance and Legal Obligations

• Complying with applicable laws, regulations, and professional standards
• Maintaining transaction records as required by law
• Responding to legal processes, regulatory inquiries, or government requests

3.4 Business Operations and Improvement

• Analyzing service effectiveness and client satisfaction
• Improving our advisory processes and website functionality
• Managing business risks and preventing fraud

4. Consent

North Front Advantage obtains consent for the collection, use, and disclosure of personal information in accordance with PIPEDA. The form of consent we seek depends on the sensitivity of the information and the reasonable expectations of the individual.

4.1 Express Consent

For sensitive personal information, such as financial data, asset valuations, and transaction-specific documentation, we obtain express consent through:

• Signed engagement agreements
• Confidentiality agreements and non-disclosure agreements (NDAs)
• Written authorization for specific uses or disclosures

4.2 Implied Consent

For less sensitive information, such as business contact details provided voluntarily through our website or email, we may rely on implied consent where the purpose is reasonably apparent.

4.3 Withdrawal of Consent

Individuals may withdraw consent for certain uses of their personal information at any time, subject to legal or contractual restrictions. To withdraw consent, please contact our Privacy Officer using the contact information provided in Section 1. Please note that withdrawing consent may limit our ability to provide certain advisory services.

5. Disclosure of Personal Information

North Front Advantage does not sell, rent, or trade personal information. We disclose personal information only in the following limited circumstances:

5.1 With Consent

We share personal information with third parties only when we have obtained explicit consent from the individual. This includes:

• Sharing asset holder information with pre-qualified buyers under confidentiality agreements
• Disclosing buyer profiles to asset holders during transaction discussions

5.2 Service Providers

We may engage trusted third-party service providers to assist with business operations, including:

• Legal counsel for transaction documentation and compliance
• Accounting and financial advisors for valuation support
• Secure data storage and IT infrastructure providers
• Professional consultants (engineers, geologists, title researchers)

These service providers are contractually bound to use personal information only for the specified purposes and to maintain confidentiality and security standards consistent with this policy.

5.3 Legal and Regulatory Requirements

We may disclose personal information when required or permitted by law, including:

• In response to a court order, subpoena, or legal process
• To comply with regulatory inquiries or government investigations
• To protect our legal rights, prevent fraud, or ensure safety

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of our assets, personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

6. Data Security

North Front Advantage employs industry-standard security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Physical Security: Secure office premises with restricted access to confidential records
• Technical Security: Encrypted email communications, secure file transfer protocols, password-protected systems, and firewalls
• Organizational Security: Confidentiality agreements with employees and contractors, role-based access controls, and regular security audits
• Confidentiality Protocols: All transaction-related information is handled under strict confidentiality agreements with all parties

While we take reasonable precautions to safeguard personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but remain committed to maintaining robust protective measures.

7. Data Retention

North Front Advantage retains personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Our retention practices include:

7.1 Transaction Records

Personal information related to completed transactions is retained for a minimum of [7 years] from the date of transaction completion, in accordance with standard business practice and potential legal requirements.

7.2 Inquiry and Prospect Information

Contact information and inquiry details from individuals who do not proceed with a transaction are retained for [3 years] unless consent is withdrawn earlier.

7.3 Secure Destruction

Upon expiry of the retention period, personal information is securely destroyed through methods including shredding of physical documents and secure deletion of electronic records.

8. Cookies and Website Tracking

Our website may use cookies and similar tracking technologies to enhance user experience and analyze website traffic. Types of cookies we may use include:

• Essential Cookies: Necessary for website functionality and navigation
• Analytics Cookies: Used to understand how visitors interact with our website (e.g., Google Analytics)
• Preference Cookies: Used to remember user preferences and settings

Most web browsers allow you to control cookies through browser settings. You can choose to block or delete cookies, though this may affect website functionality. For more information on managing cookies, please refer to your browser's help documentation.

9. Access and Correction Rights

Under PIPEDA, individuals have the right to access their personal information held by North Front Advantage and to request corrections if the information is inaccurate or incomplete.

9.1 How to Request Access

To request access to your personal information, please submit a written request to our Privacy Officer at the contact information provided in Section 1. We will respond to your request within 30 days and provide access to your personal information, subject to limited exceptions permitted by law.

9.2 Correction of Information

If you believe that personal information we hold about you is inaccurate or incomplete, you may request that we correct or update the information. We will make reasonable efforts to correct the information and notify any third parties to whom the information was disclosed.

9.3 Limitations on Access

In certain circumstances, we may be unable to provide access to personal information, such as when:

• The information is subject to solicitor-client privilege
• Disclosure would reveal confidential commercial information
• The information was collected for legal proceedings or investigations
• Providing access would threaten the safety or physical or mental health of another individual

If we deny a request for access, we will provide the reasons for the denial and inform you of your right to challenge the decision.

10. Cross-Border Data Transfers

As North Front Advantage facilitates transactions across Western Canada and U.S. markets, personal information may be transferred to, stored, or processed in the United States or other jurisdictions. When personal information is transferred outside of Canada, it is subject to the laws of the foreign jurisdiction, including laws permitting government access to personal information.

We take steps to ensure that personal information transferred outside of Canada is protected by contractual safeguards and security measures consistent with this Privacy Policy. By engaging with North Front Advantage, you consent to the cross-border transfer of your personal information as necessary for the provision of our advisory services.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information promptly.

12. Changes to This Privacy Policy

North Front Advantage reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Any changes will be posted on our website with an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically.

If we make material changes that affect how we use or disclose personal information, we will provide notice through our website or by direct communication with affected individuals.

13. Questions and Complaints

If you have questions, concerns, or complaints about our privacy practices or this Privacy Policy, please contact our Privacy Officer:

We will investigate all complaints and respond within 30 days. If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada:

14. Acknowledgment

By using our website or engaging our advisory services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.