CRIMSON Asset Management (“CRIMSON”) is a Canadian company and it is our intention to comply with Canadian federal and provincial privacy legislation, including the Canadian Personal Information Protection and Electronic Act (PIPEDA). We also have clients who reside outside of Canada and we will adhere to privacy legislation impacting those clients, as applicable. We are committed to protecting the privacy and confidentiality of the personal information belonging to our clients in our possession.

This Privacy Policy governs CRIMSON’S collection, use and disclosure of personal information including information such as your name, address, date of birth, email and tax identification numbers.

This Privacy Policy is intended to provide you with an outline of how we fulfill our privacy commitments to you.

We have a Privacy Officer.

We have appointed a Privacy Officer to monitor the fulfillment of our privacy commitments, oversee our compliance with privacy legislation and to train our employees in Privacy Policy matters. More information on how to contact our Privacy Officer can be found at the end of this document.

We only ask you for necessary personal information and we only use it to provide you with our services.

We collect personal information about you in connection with the offering of units in the funds we manage (the “Funds”). Specifically, we collect your personal information to help us maintain a client relationship with you and for other purposes such as contractual, income tax reporting, transaction and regulatory requirements, including but not limited to know-your-client requirements and anti-money laundering regulations. For example, we use the information you provide to us to understand your investment goals and objectives.

We collect your personal information from the following sources:

  • subscription agreements or other forms you complete in hard copy or digitally;
  • transactions with us and our affiliates; and
  • meetings, telephone conversations and electronic communications.

It is our policy that we will not sell your information.

We ask for your consent and we ask you to keep your personal information up to date.

We ask for your consent to our use of your personal information in our subscription documents. We ask that you notify us of any personal information changes, deletions or corrections.

CRIMSON will only use information for identified purposes and if the information is required for any new use, CRIMSON will take the necessary steps in order to seek additional consent from you.

How we will use, retain and disclose your personal information.

We will 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, CRIMSON 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.

We may disclose your personal information to third parties, when necessary, and to our affiliates in connection with the services we provide related to you, including:

  • financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, the Funds;
  • technology service providers, such as software providers and managed technology and cloud services; and
  • other service providers to the Funds, such as accounting, legal, or tax preparation services.

We may be required to disclose your personal information to domestic and international governments, government agencies, tax authorities, law enforcement agencies, securities regulators, and will only do so when required by law.

Request for access to personal information.

Upon request, CRIMSON will provide you with the personal information we hold or process on your behalf. To protect the security of your information, we follow strict storage and disclosure procedures. If we receive a request from you to delete or return personal information, to the extent permitted by law and to the best of our ability, we will remove such data from our records and provide you with evidence of its removal. A request to have your data deleted or removed or the withdrawal of your consent to use your personal information for the purposes outlined in this Privacy Policy may impact your ability to receive our services.

The security of personal information.

CRIMSON is serious about protecting our data including your personal information and we have implemented a number of safeguards against unauthorized access or improper disclosure. Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continual maintenance of our network security infrastructure. CRIMSON employees are subject to a strict code of conduct concerning personal information.

Investors’ personal information is maintained on computer networks belonging to us and our service providers and various cloud networks which could be located inside or outside of Canada. Personal information may also be stored on a secure off-site storage network or facility. While we have implemented reasonable and effective security controls to protect the data, complete privacy, security and confidentiality cannot always be assured. You acknowledge your personal responsibility to protect your Client Portal usernames and passwords and to exercise care and judgment when sending personal information to us via email. CRIMSON shall not be responsible for any harm that you or any other person may suffer in connection with your failure to safeguard your usernames and passwords and any electronic communications sent or received in relation to the services we provide to you.

Reporting privacy breaches.

A privacy breach is the loss of, unauthorized access to, or disclosure of, personal information resulting from a breach of an organization’s security safeguards. Upon the occurrence of a privacy breach or a potential privacy breach, CRIMSON will investigate and evaluate the implications of the breach as soon as feasible. Notification to regulators and affected individuals – where the breach creates a real risk of significant harm to an individual – will be considered and action taken, as required, as soon as feasible and with reference to relevant legislative requirements.

Our website.

If you access our website, certain information about your computer (such as the address you are connecting from) may automatically be generated, collected and logged by web servers. We may use this information to monitor website usage, resolve technical issues and improve functionality and content.

If you have a complaint about how we have handled your personal information.

If you would like to access your personal information we have on file or if have a complaint relating to how we have handled your personal information, you can contact our CRIMSON Privacy Officer who will investigate the matter, notify all individuals involved with the enquiry and record all details of the matter in a file. If you are not satisfied with our response and recourse procedure you may bring the complaint to the attention of the office of the Privacy Commissioner of Canada.

CRIMSON Privacy Officer: Ken Jesudian, 416-861 9002, or by mail to CRIMSON Asset Management, Brookfield Place, 161 Bay St., Suite 2210, Toronto, Ontario M5J 2S1.

A complete version of PIPEDA can be found on the Department of Justice website.

Note: 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