At BloombergSen Investment Partners ("BloombergSen"), we recognize that all personal information is private and confidential.
BloombergSen acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all BloombergSen employees of the need to use the utmost discretion when dealing with client information. BloombergSen's Privacy Officer has the responsibility to carefully analyze and alter collection procedures both on a preliminary basis and ongoing basis to assure maximum privacy protection.Purpose:
BloombergSen will only use client information for the purposes identified either before or at the time of collection. It is our policy that we will not sell your information.
In connection with the offering and sale of units (the “Units”) of any pooled funds managed by BloombergSen (the “Funds”), we collect and maintain personal information about subscribers. We collect their personal information to enable us to provide them with services in connection with their investment in the Funds, to meet legal and regulatory requirements and for any other purpose to which they may consent in the future. Their personal information is collected from the following sources:
Unless a subscriber otherwise advises, by providing us with their personal information they have consented to our collection, use and disclosure of their information as provided herein. We collect and maintain their personal information in order to give them the best possible service and allow us to establish their identity, protect us from error and fraud, comply with the law and assess their eligibility in our products.
We may disclose their personal information to third parties, when necessary, and to our affiliates in connection with the services we provide related to their subscription for Units of the Funds, including:
BloombergSen will only use information for identified purposes and if the information is required for any new use, BloombergSen will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by the client or a client authorized representative.Collection:
BloombergSen will only collect information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation, such as the Money Laundering (Terrorist Financing) Act. BloombergSen's employees will do their best to explain why collection of information is necessary in a clear and informative fashion.Use, Disclosure and Retention:
BloombergSen will only retain personal information as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individual’s personal information is no longer required, BloombergSen will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that information cannot be found or used by an authorized party.Accuracy and Access:
When requested and supported by sufficient identity information, BloombergSen will provide clients with their personal information, as maintained in client files. We recognize a client's right to his or her own information, how the information is used and to whom it is disclosed.
BloombergSen strives to maintain accurate client information, which not only help us provide better client service but also minimizes the potential misuse of personal information. If an error or discrepancy is found in your personal information, we will act efficiently to correct the mistake in less than thirty days. An extension will only be applied if the request will unreasonably interfere with our business affairs.Safeguards:
Investors' personal information is maintained on our networks or on the networks of our service providers which could be located inside or outside of Canada. Personal information may also be stored on a secure off-site storage facility. An investor may access their personal information to verify its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting the Privacy Officer. Please note that an investor’s ability to participate in the Funds may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above.Directness:
Personal information collected by BloombergSen may be used to determine how many people visit the website and which sections of the website are visited the most frequently. When you visit the website, move from page to page, or download content, the following information may be recorded: the address you are connecting from; which pages are visited; and what content is downloaded.
Certain BloombergSen employees will be provided with information about the website visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products.
Information obtained by registering on this website or attending a BloombergSen event will reside in an internal database at BloombergSen. If you wish to have your information removed from the BloombergSen database at any time, please send your request to the Privacy Officer.Complaints and Recourse:
BloombergSen's Privacy Officer will deal with any complaints or conflicts arising in regard to the collection, use and disclosure of personal information. In order to adequately address the complaint, all details will be recorded and a file will be created. All individuals involved will be notified of an enquiry into the complaint. BloombergSen's Privacy Officer can provide clients with a more complete description of the recourse process. Individuals who are not satisfied with BloombergSen's recourse procedure can bring the complaint to the attention of the office of the Privacy Commissioner of Canada.Questions or Concerns
If you have any questions or concerns about the privacy and confidentiality of personal information, or if you would like access to your personal information that we have on file, you may contact Danielle Skipp, our Privacy Officer, by telephone at 416 594 9090, by email at or by mail to BloombergSen Inc., 77 King Street West, Suite 4220, TD North Tower, P.O. Box 135, Toronto, Ontario M5K 1H1 Attention: Privacy Officer. A complete version of PIPEDA can be found on the Department of Justice website.
Investors resident in Ontario should be aware that the Investment Manager is required to file a report, setting out the Subscriber’s name and address, the class and series of securities issued, the date of issuance and the subscription price of securities 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. In Ontario, the following official can answer questions about the Commission’s indirect collection of the information:
Administrative Support Clerk
Suite 1903, Box 55, 20 Queen Street West
Toronto, Ontario M5H 3S8
Telephone: (416) 593-3684
Facsimile: (416) 593-8122