Philosophy Surrounding Privacy

This policy explains how Twist Financial Corp. ("Twist Financial") collects, uses, discloses and safeguards personal information provided to us either directly by you or by a third party.

By providing personal information to us or authorizing a third party to provide your personal information to us, you signify your consent to Twist Financial's collection, use and disclosure of your personal information in accordance with this privacy policy.

For purposes of this privacy policy, "personal information" shall mean any information that can identify an individual directly or through other reasonably available means. Personal information will not include an individual's name, title, business name, and business address or business telephone number.

As part of our commitment to treat personal information with respect, we operate in accordance with the following ten principles:

Principle 1 - Accountability

Principle 2 - Identifying Purposes

Principle 3 - Consent

Principle 4 - Limiting Collection

Principle 5 - Limiting Use, Disclosure and Retention

Principle 6 - Accuracy

Principle 7 - Safeguarding Customer Information

Principle 8 - Openness

Principle 9 - Customer Access

Principle 10 - Handling Customer Complaints and Suggestions

Principle 1 - Accountability
We will maintain and protect all personal information under our control. We have designated an individual or individuals who is/are accountable for compliance with the Principles.

Principle 2 - Identifying Purposes
Prior to collecting personal information, we inform the individual or source from which it is collected of the purpose for which it will be used.

Principle 3 - Consent
Except where required or permitted by law, we obtain informed consent before collecting, using or disclosing personal information.

Principle 4 - Limiting Collection
The personal information we collect is limited to those details necessary for our business purposes identified at the time of collection.

Principle 5 - Limiting Use, Disclosure and Retention
We will only use or disclose personal information in accordance with the purposes for which it was collected, or when it is required by law or industry regulation. We will retain personal information only for so long as is required to fulfill the purpose for which it was collected or as required by industry regulation.

Principle 6 - Accuracy
We shall make every reasonable effort to ensure that personal information is maintained in an accurate, complete and up-to-date form in view of the purposes for which it will be used.

Principle 7 - Safeguarding Customer Information
We shall utilize no less than industry standards security safeguards to protect personal information that is in our custody.

Principle 8 - Openness
If you would like a copy of our privacy policies we would be more than happy to provide one to you and if you have any questions regarding same, we are more than happy to discuss the merits with you.

Principle 9 - Customer Access
Upon your request, we shall inform any individual of: (i) the type of personal information we have collected; (ii) how we have used such personal information in the past, and how we may in the future; and (iii) whether or not we have disclosed such personal information to any third parties (and, if so, to whom). An individual may verify the accuracy and completeness of his/her personal information, and may request that it be amended, if appropriate.

Prior to correcting any inaccuracies in connection with the personal information collected, we shall verify the identity of the individual making the request.

Principle 10 - Handling Customer Complaints and Suggestions
Customers may direct any questions or enquiries with respect to the Principles or about our information handling practices by contacting:

David Middleton
Twist Financial Capital Markets
Phone: (416) 573 4377

Why We Gather Personal Information
At Twist Financial, we gather and use personal information in accordance with all applicable regulations, rules and policies.
We only use personal information for the purposes that we have disclosed. If for any reason personal information is required to fulfill a different purpose, we will obtain consent before we proceed.


Types of Information We Collect
The collection, use and disclosure of information by Twist Financial may include but is not limited to the following:

Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction with any of the foregoing.

The choice to provide us with your personal information, either directly or through a third party, is always yours. However, your decision to withhold particular information may result in limiting our ability to provide you with the services or products you requested.

How We Collect Such Personal Information
We may gather such personal information from you in person, over the telephone or by corresponding with you via mail, facsimile, the Internet, or from third parties who have your authority to disclose such personal information to us.

WHILE WE TRY TO ENSURE THAT EVERY THIRD PARTY WHO DISCLOSES PERSONAL INFORMATION TO US HAS YOUR CONSENT TO DO SO, IF YOU BELIEVE THAT A THIRD PARTY HAS INAPPROPRIATELY DISCLOSED YOUR PERSONAL INFORMATION TO US, PLEASE CONTACT THAT THIRD PARTY. IF THEY DO NOT ADEQUATELY RESPOND TO YOUR INQUIRIES, PLEASE LET US KNOW IMMEDIATELY.

Twist Financial's Website
When you visit our web site, information is not collected that could identify you personally unless you choose to provide it voluntarily. You are welcome to browse the Web site at any time anonymously and privately without revealing any personal or financial information about yourself.

When Information May be Disclosed to Outside Parties
Except as specifically provided for in this privacy policy and as required by governmental legislation, we do not disclose any personal information to third parties.
The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances such as a legal proceeding or court order, we may also be required to disclose certain information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the request have legitimate grounds to do so.

There are some situations where we are legally permitted to disclose personal information such as employing reasonable and legal methods to enforce our rights or to investigate suspicion of illegal activities.

Our Employees and your Personal Information
In the course of daily operations, access to private, sensitive and confidential or personal information is restricted to authorized employees who have a legitimate business purpose and reason for accessing it.

As a condition of their employment, all employees of Twist Financial are required to abide by the privacy standards we have established. Employees are informed about the importance of privacy and they are required to agree to Twist Financial's Policy that prohibits the disclosure of any customer information to unauthorized individuals or parties.

Unauthorized access to and/or disclosure of personal information by an employee of Twist Financial is strictly prohibited. All employees are expected to maintain the confidentiality of personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.

How We Safeguard Your Information
We use industry standard technologies and maintain current security standards to ensure that personal information is protected against unauthorized access, disclosure, inappropriate alteration or misuse.

Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.

Updating this Privacy Policy
Any changes to our privacy policy and information handling practices will be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this privacy policy.


Web Sites Governed by this Privacy Policy
The web site that is governed by the provisions and practices stated in this privacy policy is: www.TwistFinancial.com.

Twist Financial's web site may contain links to other third party sites that are not governed by this privacy policy. Although we endeavor to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave the Twist Financial web site. Additionally, we are not responsible for the privacy practices employed by other third party web sites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.