VenGrowth is committed to protecting the privacy and security of the shareholders of all of our VenGrowth managed funds. Our privacy policy outlines the protection of personal information provided by VenGrowth and complies with applicable legislation.
This privacy policy describes the principles that VenGrowth follows to ensure that we protect our shareholders’ personal information when we collect, use or disclose it in the course of carrying on our business.
1. Accountability
VenGrowth is responsible for personal information in its possession, custody or control. VenGrowth has delegated responsibility for compliance with the provisions of this privacy policy to a privacy compliance officer, who can be contacted by e-mail at privacycomplianceofficer@vengrowth.com or by mail at:
VenGrowth Asset Management Ltd.
105 Adelaide Street West
Suite 1000
Toronto, Ontario
M5H 1P9
Attention: Privacy Compliance Officer
VenGrowth is committed to training its staff and executives on its policies and procedures for managing personal information and the Privacy Compliance Officer, with the assistance of senior management, will endeavor to implement policies and practices to ensure that there are procedures in place to protect our shareholders’ personal information and to receive and respond to complaints and enquiries in a timely manner.
VenGrowth will seek to ensure a comparable level of protection while information is being processed or stored by any third party outside of VenGrowth by providing a copy of this privacy policy to the third party and receiving in return a written acknowledgement that it will be bound by its terms. VenGrowth will also ensure that any third party agrees not to use personal information except for the purposes permitted by VenGrowth and, after completion of its work, returns all personal information to VenGrowth and destroys any remaining records in the possession of the third party.
VenGrowth is committed to ensuring that appropriate security measures are employed in the transfer of sensitive information; however, in the case of e-mail and wireless communication, complete confidentiality is not assured.
2. Identifying Purposes for Collection of Personal Information
VenGrowth believes that the responsible use of personal information is is necessary for the proper provision of services to its shareholders, and in particular for the following purposes:
- To identify and contact shareholders
- To establish and administer shareholder accounts
- To execute transactions
- To develop, improve and offer additional VenGrowth services
- To understand shareholders’ needs and preferences
- To meet legal regulatory requirements
- To protect against error and fraud
- To manage VenGrowth’s operations and investments
3. Consent for the Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use or disclosure of personal information, except where otherwise provided by law. VenGrowth will generally seek consent to use and disclose personal information at the same time that it collects the information. Consent to use personal information is voluntary, unless required by law, and it is not necessary to provide personal information that is not essential to the purpose of the collection, use and disclosure. We will make every reasonable effort to ensure that you are advised of the purposes for which the personal information will be used.
If, after the collection of personal information, VenGrowth wishes to use such information for any other purpose other than those outlined in Section 2 above, we will then seek your consent in advance to use your personal information for the new purpose. If we use your personal information for a new purpose we shall document the purpose for which the personal information was collected.
Subject to legal or contractual restrictions and reasonable notice, you may withdraw your consent or discuss the implications of such withdrawals by contacting VenGrowth’s Privacy Compliance Officer at the contact details listed Section 1 above. Your decision to withhold consent may limit the products and services that VenGrowth is able to provide to you.
4. Limiting Collection, Use, Disclosure and Retention of Personal Information
The collection of personal information shall be limited to that which is necessary for the purposes identified in this policy. VenGrowth will not use or disclose personal information for any other purposes, except with the consent of the individual or as required or permitted by law.
Only VenGrowth’s employees whose business duties reasonably so require are granted access to personal information about shareholders.
Occasionally, VenGrowth may need to disclose personal information to other parties about its shareholders and ensures that, when it transfers shareholders’ personal information, it is done with the strict understanding that it is for a specific, legitimate business purpose. Personal information may be disclosed for the following specific reasons:
- To enable the provision of services
- To assist an advisor or other agent acting on behalf of a shareholder
- To protect VenGrowth’s interests
- Research or business planning
- To a company within the VenGrowth Group of Companies or an acquiror of any of same
VenGrowth keeps personal information only as long as it remains necessary or relevant for the purposes identified in this policy or as required by law and will destroy, erase or make anonymous any personal information no longer needed or required.
5. Accuracy of Personal Information
VenGrowth will use reasonable efforts to keep personal information in its possession and control accurate, complete and up-to-date if the information is going to be used on an on-going basis and will rely on its clients and employees to ensure that certain information such as shareholders’ address, telephone number and contact information is current, complete and accurate.
Shareholders can, by written request to the Privacy Compliance Officer at the address given in Section 1 above, check your personal information to verify, update and correct it and to have any obsolete information removed. There is no charge for verifying or correcting your information but VenGrowth may charge a reasonable fee for accessing the information. We would suggest that you check your personal information on your account statements and confirmation slips to ensure that it is accurate.
6. Security Safeguards
VenGrowth will safeguard personal information in its possession or control from such risks as loss or theft and from unauthorized access, disclosure, duplication, use or modification. The safeguards we employ to protect personal information vary depending on the sensitivity, amount, format and storage of personal information, through appropriate security measures regardless of the format in which it is held. On site security measures will include physical security, organizational security and electronic security.
VenGrowth will use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
7. Shareholder Access to Personal Information
Except in limited circumstances prescribed by law, upon written request to the Privacy Compliance Officer, a shareholder shall be informed, and in no case not later than 30 days after receipt of the request by the shareholder, of the existence, use and disclosure of its personal information and shall be given access.
VenGrowth will promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness will be noted in the individual’s file. Where appropriate, the amended information or the existence of any unresolved differences shall be transmitted to third parties having access to the information in question.
VenGrowth will also provide to you, upon written request, an account of third parties to which it has disclosed your personal information.
8. Challenging Compliance
If you have any questions or concerns or wish to lodge a compliant concerning compliance with the VenGrowth privacy policy, please contact the VenGrowth Privacy Compliance Officer at the address set out in Section 1, who will assist you in resolving your concerns or compliant in a timely manner. We will investigate all complaints concerning compliance with our privacy policy and respond within 30 days of receipt of the compliant. If the compliant is found to be justified, we shall take appropriate measures, amending our policies and practices, if necessary.
Should you not wish to accept VenGrowth’s conclusion, or at any time in the process, you may also write to The Office of the Privacy Commissioner of Canada, 112 Kent Street, Ottawa, K1H 1H3 or call toll free 1-800-282-1376 or you may contact the relevant securities regular in the jurisdiction in which you reside. For further information regarding privacy legislation in Canada, please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca
VenGrowth may, from time to time, make changes to this policy to adapt to changing business conditions or for other reasons.
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