Privacy Policy

HRU Financial, HRU Mortgage Investment Corporation, and all affiliates and subsidiaries (“HRU Group”) are committed to protecting personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). This Privacy Policy clarifies the limited scope of personal information collected and maintained by HRU Group, particularly in relation to borrowers and MIC unitholders.

Scope of This Privacy Policy

This Privacy Policy applies only to personal information that HRU Group is authorized to collect, use, and retain in the course of its business activities.

Importantly: - HRU Group is not a securities dealer or registrant - HRU Group does not conduct AML or KYC processes for MIC investors - All investor KYC, suitability, and AML obligations are the responsibility of the registered dealer, Belco Private Capital Inc. - HRU Group does not receive, access, or maintain dealer-level investor KYC or AML information

Borrowing Clients (Mortgage Applicants)

For borrowing clients, HRU Group may collect personal information necessary to: - Process mortgage applications and administer loans - Verify identity and documentation as required for mortgage administration - Communicate with borrowers and third parties involved in a mortgage transaction - Comply with applicable legal and regulatory requirements related to mortgage lending

Information collected may include identification, contact details, employment and income information, financial information, and credit-related information, as required for mortgage processing purposes.

MIC Unitholders (Investors)

For MIC unitholders, HRU Group’s collection and use of personal information is strictly limited.

HRU Group: - Collects and maintains only the information contained in the executed subscription documents - Uses this information solely for: - Maintaining the unitholder register - Processing subscriptions and redemptions - Distributions and tax reporting (e.g., T5 slips) - Required corporate, legal, and record-keeping purposes

HRU Group does not: - Perform investor identity verification, KYC, or suitability assessments - Conduct AML or source-of-funds reviews for investors - Maintain dealer KYC files or AML documentation

All such obligations are fulfilled by the registered dealer Belco Private Capital Inc. through which the investment is made.

Consent

Personal information is collected with consent, as set out in mortgage documentation or subscription agreements, or as otherwise permitted or required by law.

Use, Disclosure & Retention

Personal information is used only for the purposes identified above
Disclosure is limited to third parties as required to administer mortgages, MIC operations, or comply with legal obligations
Information is retained only for the period required by applicable laws and regulations

Safeguards

HRU Group employs physical, organizational, and electronic safeguards appropriate to the nature and sensitivity of the information it maintains.

Accuracy & Access

HRU Group takes reasonable steps to ensure that personal information within its custody is accurate and up to date. Individuals may request access to, or correction of, their personal information, subject to legal limitations.

Questions or Concerns

Questions or concerns regarding this Privacy Policy may be directed to:

info@hrufinancials.com
HRU Mortgage Investment Corporation

Privacy Policy.