primeMogulAssets Direct Investment Guarantee

At primeMogulAssets Direct investment security is of paramount importance. We employ strong measures to protect your account and personal information. In appreciation of the trust that you have placed in us and our strong commitment to security, primeMogulAssets is proud to offer the following Guarantee:

You will receive 100% reimbursement for any losses that you have incurred, resulting from an unauthorized online activity in your primeMogulAssets investment account*. 

*The Guarantee is subject to Restrictions, Limitations and client meeting responsibilities. See Guarantee Restrictions, Guarantee Limitations and Client Responsibilities. 

Guarantee Restrictions

The Guarantee does not apply, if, deliberately or inadvertently: 

1. You fail to follow your customer responsibilities as noted below (Client Responsibilities); 
2. You fail to promptly alert primeMogulAssets about the unauthorized activity by contacting us
3. You have allowed or enabled access to your email account used for correspondence with primemogulassets investment; 
4. You have allowed or enabled access to your sensitive personal information (e.g. SIN) that may be used to impersonate you to primeMogulAssets investment; 
5. The disputed activity has been performed or initiated by an individual with whom you have shared your account access information or to whom you have granted investment authority or a power of attorney over your account(s); 
6. You refuse to co-operate fully with primeMogulAssets during the course of any consequential investigation. The full cooperation may include, but is not limited to, answering questions from primeMogulAssets investment and law enforcement authorities, access to your personal computer or other access devices, filing a police report, and completing notarized affidavit regarding the unauthorized activity; and 
7. You refuse to sign a release, as a condition of reimbursement. 

*The Guarantee is subject to Restrictions, Limitations and client meeting responsibilities. See Guarantee Restrictions, Guarantee Limitations and Client Responsibilities.

Guarantee Limitations

1. The guarantee does not cover any tax consequences, your legal fees and expenses, consequential lost opportunity or non-monetary damages. 
2. The type and amount of reimbursements is determined solely by primeMogulAssets investment, and may include in-kind replacement of taken securities. 
3. You may not assign your rights under the guarantee to any other individual or party. 
4. primeMogulAssets invetsmnet may take legal action and seek full restitution for reimbursements made under this guarantee against any individual or entity that committed or is suspected of committing the unauthorized activity.   

primeMogulAssets investment Responsibilities

At primeMogulAssets Direct investment the security and confidentiality of your information is of paramount importance. We employ several electronic, physical and procedural measures to protect the privacy of your personal information and confidential communications.  

Client Responsibilities

You are responsible for keeping your primeMogulAssets Direct Investment account details and access information confidential. You must take the following measures to help protect yourself from fraud, especially when using the internet.  

1. Frequently review your primeMogulAssets investment account holdings and transaction history. 
2. Promptly review and reply to any primeMogulAssets investment correspondence with you regarding unauthorized activity. 
3. Keep your account access information (User ID and password) protected and confidential at all times. 
4.  Enable Multi-Factor authentication using Software OTP (i.e. Okta Verify, Google Authenticator etc) solution or SMS as the second factor. Use of e-mail as a second factor is not secure and is not recommended. 
5. Protect your computer with up-to-date anti-malware software. 
6. Install a firewall. 
7. Protect your internet connection, especially when using a wireless network. 
8. Ensure your browser and operating systems are up-to-date, including installation of security patches as soon as they become available. 
9. Avoid using public computers. 
10. Protect yourself from online fraud and Phishing. 

In addition, you must not, deliberately or inadvertently, share or disclose (i) account access information and (ii) your sensitive personal information (e.g. SIN) that may be used to impersonate you to primeMogulAssets Direct investment. 

In compliance with the Accessibility for Americans with Disabilities Act, primeMogulAssets Direct Investing is committed to providing a respectful, welcoming and accessible environment for all persons with disabilities; treating all individuals in a way that allows them to maintain their dignity and independence. We are devoted to offering our services in a manner that is accessible to all clients; and working towards a barrier – free workplace for job applicants and employees. 

Accordingly, primeMogulAssets Direct Investing will provide accommodations for individuals with disability supports upon request. The nature and level of accommodation to be provided, is unique to each situation and we will work with the individual to facilitate accommodations within a reasonable manner. 

As an primeMogulAssets Financial Corp (“primeMogulAssets Financial”) company, primeMogulAssets Direct Investing is subject to primeMogulAssets Financial’s Accessibility Policies. 

References to “we” refers to primeMogulAssets Direct Investing (“CIDI”). By accessing this web site, you agree to be bound by and accept the website terms of use, and the terms and conditions set out below. 

General

The content of this web site is provided for informational purposes only and is not intended to provide specific advice with respect to financial, investment, insurance, tax, legal or accounting matters and should not be relied upon in that regard. Additionally, the information contained on this website may not apply to all investors. For information specific to your situation, you should consult your financial advisor or other appropriate investment, legal or accounting professionals before acting on any of the information contained herein. 

The information presented does not constitute a solicitation or offer by primeMogulAssets to buy or sell any particular security, investment, or other financial instrument of any issuer.  

Information provided on this web site is believed to be reliable when posted however it is subject to change without notice and no warranty can be made as to its accuracy or completeness. Market conditions may change which may impact the information contained herein. primeMogulAssets (including any of their related corporations or affiliates, and their respective officers, directors, employees or advisors, or any other person associated with the creation of this website and its contents) is not responsible in any manner for any direct, indirect, special or consequential damages or losses of any kind, however caused, arising out of the use of this web site. 

primeMogulAssets Direct Investing

primeMogulAssets Direct Investing, a registered business name of iMetal Resources Inc. (“WealthBar”), is an online wealth management firm providing managed investment portfolios as well as personalized financial advice and planning. primeMogulAssets is a registered portfolio manager under the securities legislation in all provinces and territories in US.

primeMogulAssets Financial Corp.

WealthBar and primemogulassets resources are wholly-owned subsidiaries of primeMogulAssets Financial Corp. a public company whose shares are traded on the TSX. A number of shares may be held by employees and agents who work within primeMogulAssets and other members of the primeMogulAssets organization.  

The principal business of primeMogulAssets includes global asset management and wealth management advisory services. The management, marketing, distribution and administration of mutual funds, segregated funds and other fee-earning investment products  is offered through its wholly-owned subsidiary primeMogulAssets Financial Global Asset Management. If you invest in primeMogulAssets  products, primeMogulAssets will, through its ownership of subsidiaries, earn ongoing asset management fees in accordance with applicable prospectus or other offering documents. primeMogulAssets Global Asset Management is a registered business name of primeMogulAssets Investments Inc. 

Custodian Service Arrangement

PrimeMogulAssets DI uses the custodial services of Credential Qtrade Securities Inc.,  and  National Bank Independent Network.

A custodian is a specialized financial institution that holds customers’ assets for safekeeping. Portfolio managers or investment dealers open accounts in clients’ names with a custodian and manage the accounts on behalf of clients. 

The responsibilities of a custodian are to: 

• Safeguard your assets so that nobody can access them without your consent.
• Isolate your assets from the corporate assets of the custodian and the portfolio manager or investment dealer. That means that in the unlikely event that PrimeMogulAssets were to go bankrupt, your assets would be protected.
• Process investments as delegated by PrimeMogulAssets DI on your behalf, including buying and selling assets, and tracking and reconciling the account records.
• Manage administration related to your investments such as issuing account statements, collecting investment income on your behalf, and tax reporting.

Regulatory Oversight

PrimeMogulAssets are subject to the oversight of the provincial securities commissions and/or national SRO, and are required to adhere to regulations governing investor protection, financial market integrity, and stringent recordkeeping. These requirements are monitored through independent audits conducted by external auditors and by examiners or the regulators. 

Industry-wide Investor Protection

PrimeMogulAssets Investment Services Inc., Credential Qtrade Securities Inc., and National Bank Independent Network are members of the US Investor Protection Fund . This investor protection plan reimburses investors for account assets, within predefined limits, if their dealer or the custodian becomes insolvent or bankrupt and their assets are missing as a result. 

Exchange Traded Investments

Commissions, management fees and expenses all may be associated with an investment in exchange-traded funds (“ETFs”). If the units are purchased or sold on these US exchanges, investors may pay more than the current net asset value when buying units of the ETF and may receive less than the current net asset value when selling them. Important information about an exchange-traded fund is contained in its prospectus. ETFs are not guaranteed; their values change frequently, and past performance may not be repeated.  

Mutual Fund Investments

Commissions, trailing commissions, management fees and expenses all may be associated with mutual fund investments. Mutual funds are not guaranteed, their values change frequently and past performance may not be repeated.  Mutual fund securities are not covered by the United States Deposit Insurance Corporation or by any other government deposit insurer.  

Investments in Limited Partnerships

There are a number of risks associated with investments in a Limited Partnership (“LP”). Investors should refer to each LP’s offering documents for details. Important information about this offering is contained in the prospectus relating to this offering, a copy of which should be obtained from the agents or the offices of designated subagents. You should review the prospectus carefully, and consult your advisors, including tax professional, before making an investment decision. Such an offer can only be made by prospectus. 

Investment Calculations

All charts, calculations, projections and illustrations are for general illustrative purposes only, they are not intended to predict or project investment results, and they are not guaranteed to be accurate or complete. Actual results may vary from your investment, savings, loan or other investments available to you and depend on a number of factors including each investor’s personal investment profile, investment time horizon, and fees and expenses charged. Rates of return will vary over time, particularly for long-term investments. Please consult your advisor for individual financial advice based on your personal circumstances.  

Forward-looking Statements

This website may contain forward-looking statements which reflect our current expectations or forecasts of future events. Forward-looking statements include statements that are predictive in nature, depend upon or refer to future events or conditions, or include words such as “expects”, “anticipates”, “intends”, “plans”, “believes”, “estimates”, “preliminary”, “typical”, and other similar expressions. Statements that look forward in time or include anything other than historical information are inherently subject to, among other things, risks, uncertainties and assumptions which could cause actual events, results, performance or prospects to differ materially from those expressed in, or implied by, these forward-looking statements. Forward-looking statements are not guarantees of future performance and are by their nature based on numerous assumptions. These risks, uncertainties and assumptions include, without limitation, general economic, political and market factors in North America and internationally, interest and foreign exchange rates, the volatility of global equity and capital markets, business competition, technological change, changes in government regulations, changes in tax laws, unexpected judicial or regulatory proceedings and catastrophic events. The foregoing list of important risks, uncertainties and assumptions is not exhaustive. Please consider these and other factors carefully and not place undue reliance on forward-looking statements. 

The forward-looking information contained on this website is current only as of the date the statement was made. Unless required by applicable law, there should not be an expectation that such information will in all circumstances be updated, supplemented or revised whether as a result of new information, changing circumstances, future events or otherwise. 

Complaint Handling Process

PrimeMogulAssets provide a written summary of our complaint handling procedures to new clients at account opening. 

PrimeMogulAssets have an obligation to review all client complaints. Upon receipt of a complaint, our firm first determines the nature of the complaint. Once determined, we review the details with those persons party to the event/transaction that gave rise to the complaint. Where necessary, our review may include additional contact with the individual(s) who initiated the complaint. Upon completion of our review, we provide a summary of the complaint, results of our investigation, an explanation of our final decision and an outline of other options for seeking compensation available to the client, if the client is not satisfied with the firm’s response. Our firm will provide a final decision with respect to a complaint within 90 days or an interim response, with an explanation for the delay and the expected new response time. 

Securities rules and regulations govern the processes by which PrimeMogulAssets shall review and respond to client complaints. For further information, please contact us. 

These website terms and conditions of use for PrimeMogulAssets constitute a legal agreement and are entered into by and between you and PrimeMogulAssetss Direct Investing, a registered business name of  PrimeMogulAssets Resources  Inc. PrimeMogulAssets, a registered business name of PrimeMogulAssets Investment Services Inc. (collectively, “we”, “us”, “our”). The following terms and conditions, together with any documents and/or additional terms they expressly incorporate by reference (collectively, these “Terms and Conditions”), govern your access to and use, including any content, functionality, and services offered on or through www.PrimeMogulAssets.com (the “Website”). 

BY USING THE WEBSITE OR BY CLICKING TO ACCEPT THE TERMS AND CONDITIONS, YOU ACCEPT AND AGREE TO BE BOUND AND COMPLY WITH THESE TERMS AND CONDITIONS AND OUR PRIVACY POLICY, INCORPORATED HEREIN BY REFERENCE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS OR THE PRIVACY POLICY, YOU MUST NOT ACCESS OR USE THE WEBSITE.  

By using this Website, you represent and warrant that you are the legal age of majority under applicable law to form a binding contract with PrimeMogulAssets and meet all of the foregoing eligibility requirements. If you do not meet all of these requirements, you must not access or use the Website.  

All materials on the Website are meant to be reviewed in their entirety, including any footnotes, legal disclaimers, restrictions or disclosures, and any copyright or proprietary notices. Any disclaimers, restrictions, or disclosures apply to any partial document or material in the same manner as they do the whole, and will be deemed incorporated in the portion of any material or document that you consult or download.  

PrimeMogulAssets products and services are only offered in jurisdictions where they may be lawfully offered for sale. All products and services are subject to terms of each and every applicable agreement. It is important to note that not all products, services and information are available in all jurisdictions outside US. This Website should not be considered an offer to sell or solicitation to buy any investment fund or other product, service or information to anyone in any jurisdiction in which an offer or solicitation is not authorized or cannot be legally made or to any person to whom it is unlawful to make an offer or solicitation. Prospective investors who are not resident in US should consult with their financial advisor to determine whether these products and services may be lawfully sold in their jurisdiction.  

Information provided on this website (the “Information”) is intended for informational purposes only and should not be considered investment, financial, legal, tax or accounting advice, and should not be relied upon in that regard. Many factors unknown to PrimeMogulAssets may affect the applicability of any statement or comment made on this website to your particular circumstances. You should not rely on the Information for investment, financial, legal, tax or accounting advice. You should directly consult your financial professional or other advisors before acting on any Information. Information on this website is being provided with the understanding that PrimeMogulAssets are not acting in a fiduciary capacity.  

Modifications to the terms and conditions and to the website

We reserve the right in our sole discretion to revise and update these terms and conditions from time to time. Any and all such modifications are effective immediately upon posting and apply to all access to and continued use of the Website. You agree to periodically review the terms and conditions in order to be aware of any such modifications and your continued use shall be your acceptance of these.  

The information and material on this Website, and the Website, may be changed, withdrawn or terminated at any time in our sole discretion without notice. We will not be liable if, for any reason, all or any part of the Website is restricted to users or unavailable at any time or for any period.    

Privacy

Your access to and use of the Website constitutes your consent to certain personal information being collected, held, used and disclosed by PrimeMogulAssets in the ways and for the purposes identified in these Terms and Conditions and in the PrimeMogulAssets Privacy Notice and Online and Mobile Privacy Policy. If you do not agree to the PrimeMogulAssets Privacy Notice or Online and Mobile Privacy Policy, you must not access or use the Website.  

Any provision of registration information and any submissions you make to the Website through any functionality such as applications, chart rooms, e-mail, message boards, personal or interest group web pages, profiles, forums, bulletin boards and other such functions (collectively, “Interactive Functions”) constitute your consent to all actions PrimeMogulAssets take with respect to such information consistent with the PrimeMogulAssets Privacy Notice and Online and Mobile Privacy Policy.  

The contents of any chat session on the Website are intended for informational purposes only and not to be used or construed as an endorsement or recommendation of any entity or security discussed. The information in a chat session should not be construed as investment, tax, legal or accounting advice, and should not be relied upon in that regard. Individuals should seek the advice of professionals, as appropriate, regarding any particular investment. Investors should consult their professional advisors prior to implementing any changes to their investment strategies.  

To the extent that, within a chat session, you provide us with personal information of another individual, you represent that you have the authority and/or have obtained all necessary consents from such individual to enable us to collect, use and disclose such personal information for the purposes identified in the PrimeMogulAssets Privacy Notice and Online and Mobile Privacy Policy and as permitted or required by law. By accepting personal information from PrimeMogulAssets or their affiliates, service providers and agents, you agree to comply with the respective obligations under applicable data and privacy protection laws, codes of practice and other legal and regulatory obligations.  

Your Use of the Website and Account Set-up and security

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  

The safety and security of your information also depends on you. Users are responsible for obtaining their own access to the Website. Users are required to ensure that all persons who access the Website through a user’s internet connection are aware of these Terms and Conditions and comply with them. The Website, including content or areas of the Website, may require user registration. It is a condition of your use of the Website that all the information you provide on the Website is correct, current, and complete. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. 

Any username, password, or any other piece of information chosen by you, or provided to you as part of our security procedures, must be treated as confidential, and you must not disclose it to any other person or entity. You must exercise caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information. You understand and agree that should you be provided an account, your account is personal to you and you agree not to provide any other person with access to this Website or portions of it using your username, password, or other security information. You agree to notify us immediately of any unauthorized access to or use of your username or password or any other breach of security. You also agree to ensure that you logout from your account at the end of each session. You are responsible for any password misuse or any unauthorized access. 

You are responsible for keeping your PrimeMogulAssets account details and access information confidential. You must take the following measures to help protect yourself from fraud, including when using the internet or wireless network.  

1. Frequently review your PrimeMogulAssets account holdings and transaction history on an ongoing basis.
2. Promptly review and reply to any PrimeMogulAssets correspondence with you regarding unauthorized activity.
3. Keep your account access information (e.g., User ID, and password, security questions, etc.) protected at all times.
4. Enable Multi-Factor authentication using Software OTP solution (i.e. Okta Verify, Google Authenticator, etc.) or SMS as the second factor (use of e-mail as a second factor is not secure and is not recommended).
5. Protect your computer with up-to-date anti-malware software.
6. Install a firewall.
7. Protect your internet or wireless network connection, as applicable.
8. Ensure your browser and operating systems are up-to-date, including installation of security patches as soon as they become available.
9. Avoid using public computers.
10. Protect yourself from online and mobile phishing scams.

In addition, you must not, deliberately or inadvertently, share or disclose your (i) account access information and/or (ii) sensitive personal information (e.g. SIN) that may be used to impersonate you to PrimeMogulAssets.

We reserve the right at any time and from time to time, to disable or terminate your account, any username, password, or other identifier, whether chosen by you or provided by us, in our sole discretion for any or no reason, including any violation of any provision of these Terms and Conditions.  

You are prohibited from attempting to circumvent and from violating the security of this Website, including, without limitation: (a) accessing content and data that is not intended for you; (b) attempting to breach or breaching the security and/or authentication measures which are not authorized; (c) restricting, disrupting or disabling service to users, hosts, servers or networks; (d) illicitly reproducing TCP/IP packet header; (e) disrupting network services and otherwise disrupting Website owner’s ability to monitor the Website; (f) using any robot, spider, or other automatic device, process, or means to access the Website for any purpose, including monitoring or copying any of the material on the Website; (g) introducing any viruses, trojan horses, worms, logic bombs, or other material that is malicious or technologically harmful; (h) attacking the Website via a denial-of-service attack, distributed denial-of-service attack, flooding, mailbombing or crashing; and (i) otherwise attempting to interfere with the proper working of the Website.  

Intellectual Property Rights and Ownership

You understand and agree that the Website and its entire contents, features, and functionality, including, but not limited to, all information, software, code, text, displays, graphics, photographs, video, audio, design, presentation, selection, and arrangement, are owned by PrimeMogulAssets Financial Corp. its licensors, or other providers of such material and are protected in all forms by intellectual property laws including without limitation, copyright, trademark, patent, trade secret, and any other proprietary rights. 

Certain names, logos, product and service names, designs, images and slogans are trademarks of PrimeMogulAssets or their affiliates or licensors. You must not use such marks without the prior written permission of PrimeMogulAssets. Other names, logos, product and service names, designs, images and slogans mentioned, or which appear on this Website are the trademarks of their respective owners. Use of any such property, except as expressly authorized, shall constitute an infringement or violation of the rights of the property owner and may be a violation of federal or other laws and could subject the infringer to legal action.  

Without limiting the generality of the foregoing, the registered and unregistered trademarks include the following: PrimeMogulAssets Financial, PrimeMogulAssets Global Asset Management, the PrimeMogulAssets Global Asset Management design, Sentry Investment Management, the Sentry Investment Management design, Signature Global Asset Management, the Signature Global Asset Management design, Cambridge Global Asset Management, PrimeMogulAssets Institutional Asset Management, the PrimeMogulAssets Institutional Asset Management design, PrimeMogulAssets Multi-Asset Management, the PrimeMogulAssets Multi-Asset Management design, Harbour Advisors, the Harbour Advisors design, Harbour Funds, the Harbour Funds design, Harbour Mutual Funds, the Harbour Mutual Funds design, PrimeMogulAssets Preferred Pricing, PrimeMogulAssets Private Wealth, PrimeMogulAssets Private Pools, PrimeMogulAssets First Asset, the PrimeMogulAssets First Asset design, “Trusted Partner in Wealth”, “Be Well-Advised”, Assante, Assante Wealth Management, Assante Private Client, Stonegate Private Counsel, Assante Connect, PrimeMogulAssets Direct, PrimeMogulAssets Direct Investing, WealthBar, WealthBar Financial Services, PrimeMogulAssets Direct Trading, and PrimeMogulAssets Investment Services.  

You may only use the Website for your personal and non-commercial use. You shall not directly or indirectly reproduce, compile for an internal database, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, or transmit any of the material on our Website, in any form or medium whatsoever except: 

1. your computer and browser may temporarily store or cache copies of materials being accessed and viewed;  

2. a reasonable number of copies for personal use only may be printed keeping any proprietary notices thereon, which may only be used for non-commercial and lawful personal use and not for further reproduction, publication, or distribution of any kind on any medium whatsoever;  

3. one single user copy may be downloaded with any proprietary notices intact, for your own personal, non-commercial use, conditional on your agreement to be bound by our end user licence agreement for such downloads; and  

4. in the event social media platforms are linked to certain content on our Website, you may take such actions as our Website and such third-party social media platforms permit.

Users are not permitted to modify copies of any materials from this Website nor delete or alter any copyright, trademark, or other proprietary rights notices from copies of materials from this site. You must not access or use for any commercial purposes any part of the Website or any services or materials available through the Website.  

If you print off, copy or download any part of our Website in breach of these Terms and Conditions, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made. You have no right, title, or interest in or to the Website or to any content on the Website, and all rights not expressly granted are reserved by PrimeMogulAssets. Any use of the Website not expressly permitted by these Terms and Conditions is a breach of these Terms and Conditions and may infringe or violate copyright, trademark, and other intellectual property or other proprietary laws.   

Conditions of use and user submissions and site content standards

As a condition of your access and use, you agree that you may use the Website only for lawful purposes and in accordance with these Terms and Conditions.  

The following content standards apply to any and all content, material, and information a user submits, posts, publishes, displays, or transmits (collectively, “submit”) to the website, to other users or other persons (collectively, “User Submissions”) and any and all Interactive Functions. Any and all User Submissions must comply with all applicable federal, provincial, local, and international laws, regulations and terms of service.  

Without limiting the foregoing, you warrant and agree that your use of the Website and any User Submissions shall not:  

1. In any manner violate any applicable federal, provincial, local, or international law or regulation including, without limitation, any laws regarding the export of data or software, patent, trademark, trade secret, copyright, or other intellectual property, legal rights (including the rights of publicity and privacy of others) or contain any material that could give rise to any civil or criminal liability under applicable laws or regulations or that otherwise may be in conflict with these Terms and Conditions or the PrimeMogulAssets Privacy Notice and Online and Mobile Privacy Policy. 
2. In any manner violate the terms of use of any third-party website that is linked to the Website, including but not limited to, any third-party social media website. 
3. Include or contain any material that is exploitive, obscene, harmful, threatening, abusive, harassing, hateful, defamatory, sexually explicit or pornographic, violent, inflammatory, or discriminatory based on race, sex, religion, nationality, disability, sexual orientation, or age or other such legally prohibited ground or be otherwise objectionable, such determination to be made in PrimeMogulAssets sole discretion. 
4. Involve stalking, attempting to exploit or harm any individual (including minors) in any way by exposing them to inappropriate content or otherwise or ask for personal information as prohibited under applicable laws, regulations or code. 
5. Involve, provide or contribute any false, inaccurate or misleading information. 
6. Impersonate or attempt to impersonate PrimeMogulAssets, a PrimeMogulAssets employee, another user, or any other person or entity (including, without limitation, by using email addresses, or screen names associated with any of the foregoing).
7. Transmit, or procure the sending of, any advertisements or promotions without our prior written consent, sales, or encourage any other commercial activities, including, without limitation, any “spam”, “junk mail”, “chain letter”, contests, sweepstakes and other sales promotions, barter, or advertising or any other similar solicitation.
8. Encourage any other conduct that restricts or inhibits anyone’s use or enjoyment of the Website, or which, as determined by us, may harm PrimeMogulAssets or users of the Website or expose them to liability. 
9. Cause annoyance, inconvenience, or needless anxiety or be likely to upset, embarrass, or alarm any other person. 
10. Promote any illegal activity, or advocate, promote, or assist any unlawful act. 
11. Give the impression that they originate from or are endorsed by us or any other person or entity, if this is not the case.  

User Submissions: Grant of License

The Website may contain Interactive Functions allowing User Submissions on or through the Website.  

None of the User Submissions you submit to the Website will be subject to any confidentiality by PrimeMogulAssets. By providing any User Submission to the Website, you grant us and our affiliates and service providers, and each of their and our respective licensees, successors, and assigns the right to a world-wide, royalty free, perpetual, irrevocable, non-exclusive licence to use, reproduce, modify, perform, display, distribute, and otherwise disclose to third parties any such material for any purpose and according to your account settings and/or incorporate such material into any form, medium or technology throughout the world without compensation to you. You further waive any moral rights or other rights of authorship as a condition of submitting any User Submission.  

By submitting the User Submissions, you declare and warrant that you own or have the necessary rights to submit the User Submissions and have the right to grant the licence hereof to us and our affiliates and service providers, and each of their and our respective licensees, successors, and assigns to the User Submissions and comply with these Terms and Conditions. You represent and warrant that all User Submissions comply with applicable laws and regulations and the User Submissions site content standards set out in these Terms and Conditions.  

You understand and agree that you, not PrimeMogulAssets, nor their parent, subsidiaries, affiliates nor their respective directors, officers, employees, agents, service providers, contractors, licensors, suppliers or successors, are fully responsible for any User Submissions you submit or contribute, and you are fully responsible and legally liable, including to any third party, for such content and its accuracy. We are not responsible or legally liable to any third party for the content or accuracy of any User Submissions submitted by you or any other user of the Website.   

Site Monitoring and Enforcement, Suspension and Termination

PrimeMogulAssets have the right, without provision of notice to:  

• Remove or refuse to post on the Website any User Submissions for any or no reason in our sole discretion. 
• At all times, take such actions with respect to any User Submission deemed necessary or appropriate in our sole discretion, including, without limitation, for violating the Website and User Submissions site content standards or Terms and Conditions.  

• Take appropriate legal action, including, without limitation, referral to law enforcement or regulatory authority, or notifying the harmed party of any illegal or unauthorized use of the Website. Without limiting the foregoing, we have the right to fully cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or other information of anyone posting any materials on or through the Website.
• Terminate or suspend your access to all or part of the Website for any or no reason, including, without limitation, any violation of these Terms and Conditions.

YOU WAIVE AND HOLD HARMLESS PrimeMogulAssets, THEIR PARENT, SUBSIDIARIES, AFFILIATES, AND THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS AND SUCCESSORS FROM ANY AND ALL CLAIMS RESULTING FROM ANY ACTION TAKEN BY CI AND ANY OF THE FOREGOING PARTIES RELATING TO ANY, INVESTIGATIONS BY EITHER CI OR SUCH PARTIES OR BY LAW ENFORCEMENT AUTHORITIES.  

We have no obligation, nor any responsibility to any party to monitor the Website or its use, and do not and cannot undertake to review material that you or other users submit to the Website. We cannot ensure prompt removal of objectionable material after it has been posted and we have no liability for any action or inaction regarding transmissions, communications, or content provided by any user or third party, subject to applicable laws.   

No Reliance

The content on our Website is provided for general information purposes only. It is not intended to amount to advice on which you should rely. You must obtain more specific or professional advice before taking, or refraining from, any action or inaction on the basis of the content on our site.  

Although we make reasonable efforts to update the information on our Website, we make no representations, warranties or guarantees, whether express or implied, that the content on our Website is accurate, complete or up to date. Your use of the Website is at your own risk and neither PrimeMogulAssets, nor their parent, subsidiaries, affiliates, and their respective directors, officers, employees, agents, service providers, contractors, licensors, licensees, suppliers or successors have any responsibility or liability whatsoever for your use of this Website.  

This Website may include content provided by third parties, including from other users and third-party licensors. All statements and/or opinions expressed in any such third-party content, other than the content provided by PrimeMogulAssets, are solely the opinions and the responsibility of the person or entity providing those materials. Such materials do not necessarily reflect the opinion of PrimeMogulAssets. Neither PrimeMogulAssets, nor their parent, subsidiaries, affiliates, and their respective directors, officers, employees, agents, service providers, contractors, licensors, licensees, suppliers or successors have any responsibility or liability whatsoever to you, or any third party, for the content or accuracy of any third-party materials.    

Third-Party Websites

For your convenience, this Website may provide links or pointers to third-party sites. We make no representations about any other websites that may be accessed from this Website. If you choose to access any such sites, you do so at your own risk. We have no control over the contents of any such third-party sites and accept no responsibility for such sites or for any loss or damage that may arise from your use of them. You are subject to any terms and conditions of such third-party sites.  

Such links to third-party sites from the Website may include links to certain social media features that enable you to link or transmit on your own or using certain third-party websites, certain content from this Website. You may only use these features when they are provided by us and solely with respect to the content identified.  

You may link to our homepage, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. Our Website must not be framed on any other site, nor may you create a link to any part of our Website other than the homepage. We reserve the right to withdraw linking permission without notice. The website in which you are linking must comply in all respects with the Conditions of Use and User Submissions site content standards. You agree to cooperate with us in causing any unauthorized framing or linking to immediately stop.  

Complete confidentiality and security is not yet possible over the Internet. Linking to any other site is at your own risk, and PrimeMogulAssets will not be responsible or liable for any damages in connection with linking.    

Geographic Restrictions

The owner of the Website is based in United States. This Website is not intended for use in any jurisdiction where its use is not permitted. If you access the Website from outside US, you do so at your own risk, and you are responsible for compliance with local laws of your jurisdiction.   

Disclaimer of warranties

YOU UNDERSTAND AND AGREE THAT YOUR USE OF THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT, AND ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.  

NEITHER PrimeMogulAssets, NOR THEIR PARENT, SUBSIDIARIES, AFFILIATES OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS OR SUCCESSORS MAKE ANY WARRANTY, REPRESENTATION OR ENDORSEMENT WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, SUITABILITY, ACCURACY, CURRENCY OR AVAILABILITY OF THE WEBSITE OR ITS CONTENTS. WITHOUT LIMITING THE FOREGOING, NEITHER PrimeMogulAssets, NOR THEIR PARENT, SUBSIDIARIES, AFFILIATES OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS OR SUCCESSORS REPRESENT OR WARRANT THAT THE WEBSITE, ITS CONTENT, OR ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE, OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR WEBSITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.  

WE CANNOT AND DO NOT GUARANTEE OR WARRANT THAT FILES OR DATA AVAILABLE FOR DOWNLOADING FROM THE INTERNET OR THE WEBSITE WILL BE FREE OF VIRUSES OR OTHER DESTRUCTIVE CODE. YOU ARE SOLELY AND ENTIRELY RESPONSIBLE FOR YOUR USE OF THE WEBSITE AND YOUR COMPUTER, INTERNET AND DATA SECURITY. TO THE FULLEST EXTENT PROVIDED BY LAW, WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE CAUSED BY DENIAL-OF-SERVICE ATTACK, DISTRIBUTED DENIAL-OF-SERVICE ATTACK, OVERLOADING, FLOODING, MAILBOMBING OR CRASHING, VIRUSES, TROJAN HORSES, WORMS, LOGIC BOMBS, OR OTHER TECHNOLOGICALLY HARMFUL MATERIAL THAT MAY INFECT YOUR COMPUTER EQUIPMENT, COMPUTER PROGRAMS, DATA, OR OTHER PROPRIETARY MATERIAL DUE TO YOUR USE OF THE WEBSITE OR ANY SERVICES OR ITEMS FOUND OR ATTAINED THROUGH THE WEBSITE OR TO YOUR DOWNLOADING OF ANY MATERIAL POSTED ON IT, OR ON ANY WEBSITE LINKED TO IT.  

Limitation on Liability 

EXCEPT WHERE SUCH EXCLUSIONS ARE PROHIBITED BY LAW, UNDER NO CIRCUMSTANCE WILL PrimeMogulAssets,  NOR THEIR PARENT, SUBSIDIARIES, AFFILIATES OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SERVICE PROVIDERS, CONTRACTORS, LICENSORS, LICENSEES, SUPPLIERS, OR SUCCESSORS BE LIABLE FOR NEGLIGENCE, GROSS NEGLIGENCE, NEGLIGENT MISREPRESENTATION, FUNDAMENTAL BREACH, DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING, BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT, BREACH OF PRIVACY OR OTHERWISE, EVEN IF THE PARTY WAS ALLEGEDLY ADVISED OR HAD REASON TO KNOW, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, OR RELIANCE ON, THE WEBSITE, ANY LINKED WEBSITES OR SUCH OTHER THIRD-PARTY WEBSITES, NOR ANY WEBSITE CONTENT, MATERIALS, POSTING OR INFORMATION THEREON EVEN IF THE PARTY WAS ALLEGEDLY ADVISED OR HAD REASON TO KNOW.   

Indemnification

To the maximum extent permitted by applicable law, you agree to defend, indemnify, and hold harmless PrimeMogulAssets, their parent, subsidiaries, affiliates, and their respective directors, officers, employees, agents, service providers, contractors, licensors, suppliers, successors, and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to your breach of these Terms and Conditions or your use of the Website, including, but not limited to, your User Submissions, third-party sites, any use of the Website’s content, services, and products other than as expressly authorized in these Terms and Conditions.  

Governing Law and Jurisdiction

The Website and these Terms and Conditions will be governed by and construed in accordance with the laws of US and the federal laws of US applicable therein, without giving effect to any choice or conflict of law provision, principle or rule (whether of the laws of US or any other jurisdiction) and notwithstanding your domicile, residence or physical location.  

Any action or proceeding arising out of or relating to this Website and under these Terms and Conditions will be instituted in the courts of the province of Ontario and/or the Federal Court of Canada, and each party irrevocably submits to the exclusive jurisdiction of such courts in any such action or proceeding. You waive any and all objections to the exercise of jurisdiction over you by such courts and to the venue of such courts.  

Waiver

No failure to exercise, or delay in exercising, any right, remedy, power or privilege arising from these Terms and Conditions operates, or may be construed, as a waiver thereof. No single or partial exercise of any right, remedy, power or privilege hereunder precludes any other or further exercise thereof or the exercise of any other right, remedy, power or privilege.  

Severability  

If any term or provision of these Terms and Conditions is invalid, illegal or unenforceable in any jurisdiction, such invalidity, illegality or unenforceability shall not affect any other term or provision of these Terms and Conditions or invalidate or render unenforceable such term or provision in any other jurisdiction.  

Entire Agreement

The Terms and Conditions, the PrimeMogulAssets Privacy Notice and Online and Mobile Privacy Policy constitute the sole and entire agreement between you and PrimeMogulAssets regarding the Website and supersede all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, regarding such subject matter.  

 

Privacy notice

We are dedicated to respecting and protecting the privacy and confidentiality of the information you have entrusted to us. This Privacy Notice outlines our privacy principles and practices. 

Scope: what is personal information?

Personal information refers to information that identifies you. The word “information” means personal, financial and other details about you that you, or someone you authorize, provide to us or we obtain from others within or outside the Company. 

What does it apply to?

This Privacy Notice applies to the operations of PrimeMogulAssets Financial Services Inc., doing business as PrimeMogulAssets Direct Investing, Assante Connect, PPI Valet and PrimeMogulAssets Direct Investment Services Inc. doing business as PrimeMogulAssets Direct Trading.  It applies regardless of how you choose to do business with us – over the phone, in person, through the internet, through your mobile device or through email. 

Who does it apply to?

The Notice applies to all individuals whose personal information we collect, including clients who are individuals, individuals carrying on business alone or in partnership with other individuals, signing officers of our business clients, and beneficiaries of clients to the extent that we collect, use or disclose their personal information. 

Change to the notice

We may amend this Notice from time to time and will post the revised Privacy Notice on our website. 

Your consent

Each time you use our online, mobile, and electronic services, you are indicating your acknowledgment and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services. 

Online and Mobile Privacy Policy Scope

This Online and Mobile Privacy Policy supplements the Privacy Notice and specifically addresses the way in which we collect, use, disclose, and manage personal information in connection with our online, mobile and other digital channels and services.  It should be read in conjunction with the Legal Notice and Terms of Use. 

Your consent

Each time you use our online, mobile, and electronic services, you are indicating your acknowledgment and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice.  We will let you know of any changes by posting the revised policy with a new effective date.  If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services.  

What personal information do we collect?

We may collect personal information when you use our websites, online, mobile, and other electronic services (collectively, digital channels), including: 

• Personal information you provide like account and contact information, including your name, email address, user ID, password, and service preferences. Refer to your specific app for additional, applicable information.
• Financial information – that you provide to us at the time of account creation of an account through our online or mobile account creation process
• Transactional data about your use of our products and services
• Mobile phone number
• Device-related information like:
• Internet Protocol (IP) address – An IP address is a unique set of numbers assigned by Internet Service Providers (ISP) to all devices used to access the internet. While PrimeMogulAssets is not able to identify an individual using the IP address alone, in certain circumstances, it could be used to identify an individual using the site.
• Mobile country code which is a three-digit number that indicates the country in which your mobile device is registered (for example, 302 is the mobile country code for Canada)
• Geolocation (if enabled on your device) provides the approximate physical location of your device
• Device ID which is a unique number that identifies your device
• Make and model of your device
• Operating system of your device
• Information about screen size of your device
• Date and time of your use of our app
• Browser data
• Software applications data
• Mobile device identification number (IMEI)
• Mobile Marketing ID (if enabled) such as AAID and IDFA
• Statistical information about how users interact with our digital channels, such as average time spent on a specific mobile or web page.
• Website use information, such as browsing behaviour on our websites and links, location you click, form data and downloads, as well as other data gathered from the use of web tools (for example, Cookies, Web Beacons, Tagging)
• Other information, such as any feedback you may provide us 

For what purposes do we use and disclose your personal information?

• We may use or disclose this information collected online to:
• Verify your identity and authenticate you during online sessions
• Provide and manage the online products and services
• Provide you with services and offers compatible with your device and relevant to your region
• Determine eligibility of your device
• Protect against fraud, security threats, and otherwise manage risks
• Communicate with you regarding products and services that may be of interest, including displaying targeted and relevant advertising, and offering you special promotions
• Evaluate and improve our websites, online apps, mobile apps, and other electronic offerings
• Tailor our services and otherwise enhance the online customer experience to better meet your needs through digital channels
• Perform analytics and measure the effectiveness of our digital channels and services, including obtaining insight into how to improve the design, content and navigation of our digital channels
• Satisfy legal or regulatory requirements

Use of web tools

We and our service providers may use various tracking tools, such as Cookies, Pixel Tags and Web Beacons. Through the use of cookies and other technologies, we can enhance your experience with improved design, personalized content that may be relevant to you, and effective navigation. We also use online advertising to reach new potential clients and remarketing tools that allow us to target ads to specific groups of people who have previously interacted with PrimeMogulAssets Direct Investing’s and PrimeMogulAssets Direct Trading’s websites. 

• Cookies – A Cookie is a string of data containing a unique identification number that our website sends to your computer’s web browser. PrimeMogulAssets Financial Services Inc. and PrimeMogulAssets Investment Services Inc. use cookies and online tools, such as Google Analytics, to collect non-personal information to understand how people are using the Services and how PrimeMogulAssets Financial Services Inc. and PrimeMogulAssets Investment Services Inc. can make them better. Most browsers and mobile devices offer their own settings to manage cookies. You can refuse or delete cookies. Please refer to your browser’s online help for further instruction and information on setting Cookie preferences. If you do not accept any category of Cookies, you may continue to browse our websites; however, please be aware that certain features of our website may not function properly without Cookies. You should note that if you would like certain services, you will be required to accept the Cookies to maintain session integrity and enhanced security. Additional resources that may assist you in managing Cookies used for advertising include the Digital Advertising Alliance (DAA).

If you refuse a cookie when using the Services, or if you delete cookies, you may experience some inconvenience in your use of the Services. For example, you may not be able to sign in and access your account, or PrimeMogulAssets Financial Services Inc. or PrimeMogulAssets Investment Services Inc. may not be able to recognize. 

• Tagging – Tagging software is customized code on our websites, designed to monitor user activity on our websites, to help us in presenting users with content relevant to their use of our website.
• Web Beacons – Web beacons are small and transparent images embedded in web pages and e-mail communications that, when combined with Cookies, help provide us with information about the use and effectiveness of a website or e-mail communication. As an example, we may include web beacons within e-mail communications to receive confirmation of receipt of an e-mail communication or clicks on links within our websites. 

Your choices

• Email communications – PrimeMogulAssets Financial Services Inc. and PrimeMogulAssets Investment Services Inc. use electronic messages and e-mail to contact clients about information relating to PrimeMogulAssets Financial Services Inc. or and PrimeMogulAssets Investment Services Inc., including special offers, products and services. You may withdraw you consent at any time by clicking an unsubscribe link provided in each e-mail I receive or by sending an unsubscribe request by contacting us.
• Voluntary participation – You may choose to enter your information to participate in online surveys, feedback, contests, or other activities we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or identifying products and services that might interest you. This information will be used for the purposes outlined in the Privacy Notice. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
• Educational webinars – You may choose to enter your information to participate in online meetings, educational events that we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or issuing continuing education credits. This information will be used for the purposes outlined in the Privacy Notice. The information you enter may be transmitted through or to our 3rd party providers of webinars. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
• Use of electronic signature – In the event you choose to utilize electronic signature features included in any of our online Services, you agree to the collection and retention of your IP address, e-mail address and activity records for the purposes of identifying you, maintaining evidence of transaction authorization, fraud protection and security. 

Safeguards Our security measures

We take our responsibility to safeguard customer information very seriously. To protect certain communications between your computer and our servers, we use a technology solution called “Secure Sockets Layer” (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of “defense in depth”, in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network.  

Your security measures

You are responsible for ensuring the security of your unique web login ID and password. You must avoid selecting an obvious password, such as a street address, date of birth, or telephone number and to change your password on a regular basis, in order to reduce the potential for unauthorized use. Any web login ID, password, or any other piece of information chosen by you or provided to you as part of PrimeMogulAssets Financial Services Inc.’s and PrimeMogulAssets Investment Services Inc.’s security procedures, must be treated as confidential and personal to you, and you must not disclose it to any other person or entity. 

Do not respond to text messages, pop-ups, emails, or other internet requests that ask you to reveal personal information about yourself or your account when using the Services. PrimeMogulAssets Financial Services Inc. and PrimeMogulAssets Investment Services Inc. will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. PrimeMogulAssets Financial Services Inc. and PrimeMogulAssets Investment Services Inc. will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails. 

Third-party links

For your convenience, the Services may provide links or pointers to third-party sites. You are subject to any terms and conditions of such third-party sites. Non-PrimeMogulAssets Financial Services Inc. and non-PrimeMogulAssets Investment Services Inc. websites are not subject to our privacy policy or our security standards. 

Contact us 

If you have any questions or concerns about our privacy practices, the privacy of your personal information, or you want to change your privacy preferences, please let us know. We are committed to helping resolve your questions or concerns. 

Step 1: Voice your question or concern 

The best way to address the concern or question for existing clients, is to login and submit your request through our messaging platform, or by email to customercare@primemogulassets.com. If you are not satisfied with the answer or resolution provided in Step 1, please proceed to Step 2. 

Step 2: Escalate your concern to the Privacy Office 

You can escalate your concern in the following ways: 

1. Ask the individual you are dealing with in Step 1 to escalate on your behalf. 

2. Escalate the concern directly with the Privacy Office, using the following contact information.