(last updated March 2020)
Scope of Policy
Collection and Use of Personal Information
In the course of our provision of investment management services to clients, 3iQ collects information about such clients and their beneficial owners (“Personal Information”) including residential address, telephone number, e-mail address, social insurance number, bank account numbers and other “know your client” information, including identity verification records required under applicable laws including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), regulations and policies made thereunder and other statutes and regulations that take legislative measures against money laundering, terrorist financing and against financial dealings with certain sanctioned individuals and entities.
Personal Information is used for the following purposes:
• conducting an analysis of the suitability of a proposed investment in a fund for which 3iQ acts as a portfolio manager or investment fund manager (a “Fund”);
• processing the subscription for Fund securities, opening and servicing the account;
• developing an investment policy statement under an investment management agreement;
• verifying identity and other information provided to 3iQ (including bank account);
• if applicable, reporting the investment to the relevant securities regulatory authority;
• completing books and records information for the Funds or managed accounts;
• detecting and preventing fraud and other unauthorized or illegal activities; and
• meeting other legal and regulatory requirements.
3iQ may use Personal Information to send client communications by mail, email or telephone marketing or to promote its Funds or other products and services that may be of interest to clients. Clients can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting 3iQ as set out under Contact Us below. Please note that clients will continue to receive certain transactional or informational electronic communications from 3iQ after opting out.
How Personal Information is Collected
3iQ collects Personal Information directly from clients (such as information provided in the subscription agreement or account-opening documents).
Disclosure of Personal Information
3iQ will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein.
Exempt Trade Report: Clients’ Personal Information, including the number of and purchase price for Fund securities purchased, may be disclosed to the relevant Canadian securities regulatory authorities and become available to the public in accordance with the requirements of applicable securities and freedom of information laws. Clients authorize such indirect collection of the Personal Information and acknowledge that: (i) the Personal Information is being collected indirectly by the applicable Canadian securities regulatory authority under the authority granted to it in securities legislation; (ii) the Personal Information is being collected for the purposes of the administration and enforcement of applicable Canadian securities legislation; and (iii) clients have been notified of the title, business address and business telephone number of the public official in their jurisdiction in the subscription agreement.
Service Providers: Personal Information may be transferred (or otherwise made available) to 3iQ’s affiliates and other third parties in Canada and the U.S. who provide services on 3iQ’s behalf. 3iQ may use service providers to verify Personal Information (such as identity and bank account number), administer the Funds or managed accounts, send email or other communications, or manage and analyze data. In the event Personal Information is transferred to the U.S. or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws. Service providers are given the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
Legal/Compliance: 3iQ, its affiliates and other service providers may provide Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, U.S. or other law. Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Personal Information may be transferred as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of 3iQ’s business or as part of a corporate reorganization or stock sale or other change in corporate control.
Safeguards and Retention
3iQ has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in its custody and control against theft, loss and unauthorized access, use, modification and disclosure. 3iQ restricts access to Personal Information on a needto-know basis to employees and authorized service providers who require access to fulfil their job requirements. 3iQ has record retention processes designed to retain Personal Information of its clients for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of a client’s relationship with 3iQ).
Access to Personal Information
Clients have the right to access, update and correct inaccuracies in their Personal Information in 3iQ’s custody and control, subject to certain exceptions prescribed by law. Clients may request access, updating and corrections of inaccuracies in Personal Information in 3iQ’s custody or control by emailing or writing to 3iQ at the contact information set out below. 3iQ may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.