Privacy Policy

1. Who this policy covers

This Privacy Policy explains how Fieldhouse Capital Management Inc. ("Fieldhouse," "we," "us," or "our") collects, uses, discloses, and protects personal information gathered through our websites, including johnkason.com and any linked campaign or landing pages (together, the "Website"). It applies to visitors, prospective clients, and anyone who submits information to us through a form on the Website. It does not replace or override the account documentation you receive as a client of Fieldhouse, nor the risk disclosures in our Terms of Use.

This Policy is designed to comply with British Columbia's Personal Information Protection Act ("PIPA") and, where applicable to information that crosses provincial or international borders, the federal Personal Information Protection and Electronic Documents Act ("PIPEDA").

2. Information we collect

We collect personal information you voluntarily provide through forms on the Website, which may include:

• Your name
• Your email address
• Your phone number
• Any additional information you choose to include in a message or form field (for example, details about your financial situation or what you'd like a guide or conversation to cover)

We may also automatically collect limited technical information when you visit the Website, such as your IP address, browser type, device type, and pages viewed, through cookies and similar tracking technologies (see Section 4).

3. How we use your information

We use the personal information you provide to:

• Respond to your inquiry and provide the information, guide, or resource you requested
• Contact you by email or phone to follow up on your request, including to offer a conversation or meeting with a Portfolio Manager
• Maintain a record of prospective client inquiries in our customer relationship management (CRM) system
• Show relevant ads to people who have previously visited the Website, through third-party advertising platforms (see Section 4)
• Improve the Website and understand which campaigns or pages are effective
• Meet our legal, regulatory, and record-keeping obligations as a registered Portfolio Manager, Investment Fund Manager, and Exempt Market Dealer

We will not use your information for any purpose materially different from what's described here without seeking your consent.

4. Cookies and tracking technologies

We advertise on third-party platforms (such as Meta/Facebook and Google Ads), and those ads link back to this Website, we do not display third-party ads on the Website itself. To measure how those campaigns perform and to show relevant ads to people who have previously visited our Website, the Website uses cookies, pixels, or similar tracking technologies from the advertising and analytics platforms we use. By continuing to use the Website, you consent to our use of these cookies and similar technologies as described in this section. You can also control or disable cookies through your browser settings; doing so may affect how the Website functions

5. How we share your information

We do not sell your personal information. We may share it with:

• Service providers who help us operate the Website, manage inquiries, and support our customer relationship management and email communications, under obligations to protect your information and use it only for the purposes we specify
• Advertising and analytics platforms, to measure campaign performance and show relevant ads to prior visitors, as described in Section 4
• Regulators or other parties where required by law, regulation, or a valid legal process
• A successor entity in the event of a merger, acquisition, or sale of all or part of our business

6. Where your information is stored

Some of the third-party service providers we use to operate the Website and manage inquiries, including our customer relationship management and advertising/analytics platforms, may store or process personal information on servers located outside Canada, including in the United States. Where that is the case, your information may be subject to the laws of those jurisdictions, including lawful access by government authorities.

7. How long we keep your information

We retain personal information collected through the Website for as long as we consider it relevant to our ongoing relationship with you as a prospective client, since individuals sometimes engage with Fieldhouse over an extended period, including years, before becoming a client. If you do not wish us to continue holding your information, you may ask us to delete it at any time by contacting us using the details in Section 10.

If you become a client, your information is retained as part of your client record and is subject to the retention periods required under applicable securities regulations and our internal record-keeping obligations, rather than the approach described above.

8. Your choices and rights

You may:

• Ask us what personal information we hold about you and request a correction
• Ask us to delete your information at any time
• Withdraw your consent to be contacted at any time
• Unsubscribe from marketing emails using the link included in every such email
• Make a complaint about how we have handled your personal information

To exercise any of these rights, contact our Privacy Officer using the details in Section 10. We may ask you to verify your identity before responding to a request. We will respond within 30 business days of receiving your request, unless we are entitled to an extension under applicable law, in which case we will notify you. If we charge a fee to provide access to your information, it will be minimal, and we will give you a written cost estimate in advance.

9. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, or disclosure. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Fieldhouse maintains internal policies and procedures for responding to a suspected or actual cyber or privacy breach, including notifying affected individuals and any other parties as required by law.

10. Contact us

Questions, requests, or complaints about this policy or your personal information can be directed to our Privacy Officer:

Chief Compliance Officer / Privacy Officer
Fieldhouse Capital Management Inc.
1122 Mainland Street, Vancouver, BC V6B 5L1, Canada
Phone: 778-330-3000
Email: [email protected]

We take all complaints about how we handle personal information seriously and will investigate and respond to you in writing. If you are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner for British Columbia:

Office of the Information and Privacy Commissioner for BC (OIPC)
Website: www.oipc.bc.ca
Phone: 250-387-5629

11. Changes to this policy

This Privacy Policy may change from time to time. Any updates will be posted on this page, along with a revised effective date at the top of this document.