In order to provide comfort to our clients with respect to the personal information Georgian Capital Partners that is either required to gather or which accumulates in the course of doing business with a client, Georgian Capital Partners has implemented the following policy with respect to the collection and disclosure of its clients’ personal and non-public information.
Collection of Information
Collection of information is based on the Know Your Client (“KYC”) rules mandated by the CFA Institute and Provincial regulators. In complying with the KYC rules Georgian Capital Partners collects the following information from its clients, which provides not only client contact information, but also allows Georgian Capital Partners to consider the appropriateness and suitability of investment recommendations or actions for each client:
Information including but not limited to, client’s full legal name, social insurance/security number, date of birth, citizenship, home address and phone number, type of business client is employed in, employers name, business address, business phone and fax number, position held, name of lawyer/accountant, approximate net worth of client, investment experience, investment objectives, income needs, risk attitude, consultant information, and various information about a client’s spouse and immediate family; and
Information obtained through client’s transactions with Georgian Capital Partners, its affiliates, or others, including but not limited to, account balances, transaction reports, and parties to transactions.
A client profile is also prepared which primarily summarizes the client’s investment guidelines, their investment knowledge and their investment return expectations.
Disclosure of Information
No confidential or non-public information will be disclosed to any external parties without either the client’s consent, or unless such information is required, by legal process, statutory authority or in the normal course of providing Georgian Capital services and products to the client. Investors resident in Ontario should be aware that the Partnership is required to file with the Ontario Securities Commission a report setting out the Subscriber’s name and address, the class and series of Units issued, the date of the issuance and the purchase price of Units issued to the Subscriber. Such information is collected indirectly by the Commission under the authority granted to it in securities legislation, for the purposes of the administration and enforcement of the securities legislation of Ontario. By submitting this subscription, the Subscriber authorizes such indirect collection of the information by the Commission.
Privacy on the Internet
Georgian Capital Partners has taken the following measures in order to protect the privacy of all individuals who visit our website:
Georgian Capital Partners does not sell, share or exchange personal information of clients with any other organization over the internet.
Georgian Capital Partners does not require personal information from you prior to accessing our website.
Application of Privacy Act as follows:
A client may withdraw their consent for the use of all or any part of personal information collected by Georgian Capital Partners at anytime, subject to legal or contractual restrictions and reasonable notice. The client should be aware that once consent is withdrawn Georgian Capital Partners may not be able to provide the client with the services and/or products chosen by them.
Georgian Capital Partners has appointed a Privacy Officer to oversee all aspects of this policy and the handling of any client or employee complaints. The Privacy Officer will deliver a report to the Management Committee of the company annually, or more frequently as needed, with respect to all privacy issues that have arisen.
Questions or concerns regarding this policy or the non-compliance of same should be directed in writing to the Privacy Officer at:
Georgian Capital Partners
40 King Street West, Suite 3405
Toronto, Ontario M5H 3Y2