As of January 1, 2004, Canadian commercial organizations that collect, use or disclose personal information must comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). The purpose of the legislation is to let individuals know how organizations handle the personal information of their clients. Quebec, British Columbia and Alberta have similar privacy legislation.

As of May 25, 2018, commercial organizations that collect, use or disclose personal information concerning European Union (“EU”) citizens must comply with the EU General Data Protection Regulation (“GDPR”). The purpose of FDPR is to protect personal data from risks such as unauthorized disclosure, identity theft or online abuse, for example, and to codify the rights of EU citizens to control who may have their data and how it may be used, and for how long.

Horizons ETFs Management Canada Inc. is committed to protecting its clients' or investors' personal information and shall obtain your consent before collecting, using and disclosing your personal information. All personal information is held in strict confidence and we control access to, and the use of, such information according to the practices and procedures set out in this statement.

We will only ask you for information that we need to provide fund management services, to establish your identity, to keep records, to prevent error and fraud, to comply with the law, to assess your eligibility for our products and services, or to respond to inquiries from your advisor, if you have one, and to provide you with the best possible service. Your personal information may also be collected from you directly and used for marketing purposes, including sending you product information, updates, news or other information.

We will not sell your personal information.

What is Personal Information?
Personal information is any information that identifies an individual. This includes an individual's address, age, financial records, social insurance number, credit history, personal email address, employment information, financial information, home telephone number, occupation, date of birth, country of citizenship, bank references and types of accounts at brokerage firms.

We Will Obtain Your Permission
We will only collect, use or disclose your personal information with your consent. You can give your consent in writing, when you open an account, or request or subscribe for information from us, or you can give your consent verbally, electronically or through your authorized representative. We may also obtain it through dealers, credit bureaus or other financial institutions. If we don't obtain information directly from you, we will ensure that you have given us your consent before we collect and use your personal information.

You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. However, your ability to access our products and services may be limited and declined should you refuse or withdraw your consent to the collection, use and disclosure of your personal information. For example, we must decline to accept or administer an account for a person who does not consent to our disclosing personal information to back-office third party providers.

Collection of Personal Information
We collect personal information about you from: (i) subscription forms and other information provided by you in writing, by telephone, in person, electronically or by other means; (ii) your activity on the web site and transactional activity in your accounts, including account balances, investments, withdrawals and fees/commissions; (iii) through your advisor, if you have one, and (iii) other interactions with us, such as discussions with our staff.

Collection of Personal Information
As a fund manger, we may use personal information to:
* identify the investor;
* ensure our records are accurate;
* establish and administer an investor's account(s);
* execute transactions;
* maintain, store, record and determine investor account holdings and transaction records;
* provide investors and their authorized advisors with statements/information;
* provide investors with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service their accounts;
* provide investors with customer service, updates, and support;
* for debt recovery; and
* to comply with legal and regulatory requirements.

Whom do we Disclose Personal Information to?
Your personal information will only be used for the purpose(s) for which it was collected. We may, as required by law, share personal information with third party service providers, such as those who print and prepare investment statements. We have legal agreements with third party providers to ensure that they protect your personal information. We may also have to by law provide information for a search warrant, court order or other legally valid request. We may also disclose personal information to help us collect a debt owed by the investor.

Access and Accuracy of Consent to Information
You have the right to verify the accuracy and completeness of your personal information. If you believe that any information we have collected about you is inaccurate or incomplete, you have the right to ask us to correct it. Sometimes, we may not be able to provide you with information if it contains references to third parties, is subject to legal privilege, is our proprietary information or relates to an investigation.

Any request to access, withdraw consent to or update information may be made by forwarding a written request to the Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us. We will respond to your request as quickly as possible but, in any event, no later than 30 days from receiving your request.

Protecting Client Information
We will maintain the security and confidentiality of personal information. We have policies, procedures and safeguards to protect your personal information against unauthorized access, theft or misuse. Security measures include physical, electronic and procedural safeguards such as passwords and restricted access to our office.

Our employees and service providers have access to personal information to enable them to perform their duties. As a condition of employment, each employee must sign a code of conduct which includes provisions ensuring the confidentiality of personal information.

How Long do we Keep Your Information?
We only keep your information as long as it is necessary to do so. The length of time we keep your information will depend upon the product or service and the nature of the information and will be only as long as it is legally necessary for us to retain sufficient information to respond to any inquiries that may arise later.

You may request a copy of any information we have about you and it will be provided to you within a reasonable amount of time. You may also request that we delete any information we have about you and we will do so to the extent that we are permitted to do so under Canadian law. Certain information, such as tax information, for example, must be maintained for a certain period of time. IF you have requested that you be treated as a ‘do not contact’ party, we will retain that information in order to comply with your request, as long as such request remains in place.

Resolving Your Concerns
Inquiries and complaints will be reviewed by Martin Fabregas, Privacy Officer and Data Protection Officer (user GDPR regulation). For more information, please contact Martin Fabregas at privacyofficer@horizonsetfs.com

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Commissions, management fees and expenses all may be associated with an investment in exchange traded products managed by Horizons ETFs Management (Canada) Inc. (the "Horizons Exchange Traded Products"). The Horizons Exchange Traded Products are not guaranteed, their value changes frequently and past performance may not be repeated. Certain ETFs may have exposure to leveraged investment techniques that magnify gains and losses and which may result in greater volatility in value and could be subject to aggressive investment risk and price volatility risk. Such risks are described in the prospectus. The prospectus contains important detailed information about the ETF. Please read the relevant prospectus before investing.

The Horizons Exchange Traded Products include our BetaPro products (the “BetaPro Products”). The BetaPro Products are alternative mutual funds within the meaning of National Instrument 81-102 Investment Funds, and are permitted to use strategies generally prohibited by conventional mutual funds: the ability to invest more than 10% of their net asset value in securities of a single issuer, to employ leverage, and engage in short selling to a greater extent than is permitted in conventional mutual funds. While these strategies will only be used in accordance with the investment objectives and strategies of the BetaPro Products, during certain market conditions they may accelerate the risk that an investment in shares of a BetaPro Product decreases in value. The BetaPro Products consist of our Daily Bull and Daily Bear ETFs (“Leveraged and Inverse Leveraged ETFs”), Inverse ETFs (“Inverse ETFs”) and our BetaPro S&P 500 VIX Short-Term Futures™ ETF (the “VIX ETF”). Included in the Leveraged and Inverse Leveraged ETFs and the Inverse ETFs are the BetaPro Marijuana Companies 2x Daily Bull ETF (“HMJU”) and BetaPro Marijuana Companies Inverse ETF (“HMJI”), which track the North American MOC Marijuana Index (NTR) and North American MOC Marijuana Index (TR), respectively. The Leveraged and Inverse Leveraged ETFs and certain other BetaPro Products use leveraged investment techniques that can magnify gains and losses and may result in greater volatility of returns. These BetaPro Products are subject to leverage risk and may be subject to aggressive investment risk and price volatility risk, among other risks, which are described in their respective prospectuses. Each Leveraged and Inverse Leveraged ETF seeks a return, before fees and expenses, that is either up to, or equal to, either 200% or –200% of the performance of a specified underlying index, commodity futures index or benchmark (the “Target”) for a single day. Each Inverse ETF seeks a return that is –100% of the performance of its Target. Due to the compounding of daily returns a Leveraged and Inverse Leveraged ETF’s or Inverse ETF’s returns over periods other than one day will likely differ in amount and, particularly in the case of the Leveraged and Inverse Leveraged ETFs, possibly direction from the performance of their respective Target(s) for the same period. For certain Leveraged and Inverse Leveraged ETFs that seek up to 200% or up to or -200% leveraged exposure, the Manager anticipates, under normal market conditions, managing the leverage ratio as close to two times (200%) as practicable however, the Manager may, at its sole discretion, change the leverage ratio based on its assessment of the current market conditions and negotiations with the respective ETF’s counterparties at that time. Hedging costs charged to BetaPro Products reduce the value of the forward price payable to that ETF. Due to the high cost of borrowing the securities of marijuana companies in particular, the hedging costs charged to HMJI are expected to be material and are expected to materially reduce the returns of HMJI to unitholders and materially impair the ability of HMJI to meet its investment objectives. Currently, the manager expects the hedging costs to be charged to HMJI and borne by unitholders will be between 10.00% and 45.00% per annum of the aggregate notional exposure of HMJI’s forward documents. The hedging costs may increase above this range. The manager publishes on its website, the updated monthly fixed hedging cost for HMJI for the upcoming month as negotiated with the counterparty to the forward documents, based on the then current market conditions. The VIX ETF, which is a 1x ETF, as described in the prospectus, is a speculative investment tool that is not a conventional investment. The VIX ETF’s Target is highly volatile. As a result, the VIX ETF is not intended as a stand-alone long-term investment. Historically, the VIX ETF’s Target has tended to revert to a historical mean. As a result, the performance of the VIX ETF’s Target is expected to be negative over the longer term and neither the VIX ETF nor its target is expected to have positive long-term performance. BetaPro Bitcoin ETF (“HBIT”), and BetaPro Inverse Bitcoin ETF (“BITI”), which are a 1X ETF, and an up to -1X ETF, respectively, as described in the prospectus, are speculative investment tools that are not conventional investments. Their Target, an index which replicates exposure to rolling Bitcoin Futures and not the spot price of Bitcoin, is highly volatile. As a result, neither ETF is intended as a stand-alone investment. There are inherent risks associated with products linked to crypto-assets, including Bitcoin Futures. While Bitcoin Futures are traded on a regulated exchange and cleared by regulated central counterparties, direct or indirect exposure to the high level of risk of Bitcoin Futures will not be suitable for all types of investors. An investment in any of the BetaPro Products is not intended as a complete investment program and is appropriate only for investors who have the capacity to absorb a loss of some or all of their investment. Please read the full risk disclosure in the prospectus before investing. Investors should monitor their holdings in BetaPro Products and their performance at least as frequently as daily to ensure such investment(s) remain consistent with their investment strategies.

Horizons Total Return Index ETFs (“Horizons TRI ETFs”) are generally index-tracking ETFs that use an innovative investment structure known as a Total Return Swap to deliver index returns in a low-cost and tax-efficient manner. Unlike a physical replication ETF that typically purchases the securities found in the relevant index in the same proportions as the index, most Horizons TRI ETFs use a synthetic structure that never buys the securities of an index directly. Instead, the ETF receives the total return of the index through entering into a Total Return Swap agreement with one or more counterparties, typically large financial institutions, which will provide the ETF with the total return of the index in exchange for the interest earned on the cash held by the ETF. Any distributions which are paid by the index constituents are reflected automatically in the net asset value (NAV) of the ETF. As a result, the Horizons TRI ETF receives the total return of the index (before fees), which is reflected in the ETF’s share price, and investors are not expected to receive any taxable distributions. Certain Horizons TRI ETFs (Horizons Nasdaq-100 ® Index ETF and Horizons US Large Cap Index ETF) use physical replication instead of a total return swap. The Horizons Cash Maximizer ETF and Horizons USD Cash Maximizer ETF use cash accounts and do not track an index but rather a compounding rate of interest paid on the cash deposits that can change over time.

*The indicated rates of return are the historical annual compounded total returns including changes in per unit value and reinvestment of all dividends or distributions and do not take into account sales, redemption, distribution or optional charges or income taxes payable by any securityholder that would have reduced returns. The rates of return shown in the table are not intended to reflect future values of the ETF or returns on investment in the ETF. Only the returns for periods of one year or greater are annualized returns.