In connection with the management of client portfolios, opening accounts and the provisions of services, we collect and maintain personal information about clients. We collect personal information to enable us to provide professional and responsible portfolio management, to correspond with service providers, to meet legal and regulatory requirements, and for any other purpose to which the client may consent in the future. Personal information is collected from the following sources:
- portfolio management agreements;
- account opening forms or other forms submitted to us;
- transactions with us and our affiliates; and
- client meetings and telephone conversations.
Unless clients otherwise advise, by providing personal client information to us, they are consenting to our collection, use and disclosure of this information as provided herein. We collect and maintain personal client information in order to give our clients the best possible service and allow us to establish our clients' identity, protect us from error and fraud, comply with the law and assess the clients' eligibility in our products. We may disclose personal information to third parties, when necessary, and to our affiliates in connection with the services we provide including:
- financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of the accounts;
- other service providers to us and the accounts, such as accounting, legal or tax preparation services;
- securities regulatory authorities; and
- taxation and regulatory authorities and agencies.
BAM may also disclose personal information on its own initiative if there are reasonable grounds to believe a crime or a violation of applicable regulations is involved.
BAM will not collect specific client information from its website visitors unless personal information is provided or contact is requested. If information is provided, it will be collected for the purpose of answering inquiries, providing marketing materials, corporate background and to invite guests to access services and/or events. BAM's website may employ standard technology to collect information about how its website is used for the purpose of improving website design. Website information is collected in many forms including by obtaining the domain name of visitors, user preferences, personal information that is volunteered, and geographic location. Website visitors may occasionally receive emails from BAM informing them of events and services.
We seek to carefully safeguard clients' private information and, to that end, restrict access to that personal information to those employees and other persons who need to know the information to enable us to provide services to clients. Each of our employees is responsible for ensuring the confidentiality of all personal information they may access. Personal information is maintained on our networks or on the networks of our service providers. Information may also be stored on a secure off-site storage facility. Clients may access their personal information to verify its accuracy, to withdraw their consent to any foregoing collections, uses and/or disclosures being made of their personal information by contacting us. Clients should be requested to advise BAM of any changes to their client information.
The foregoing policy must be communicated to all clients. In addition, investors in any of BAM Funds, if resident in Ontario, must be advised of the following:
'"Investors resident in Ontario should be aware that the Fund is required to file with the Ontario Securities Commission a report setting out the full name, residential address and telephone number of the Subscriber, the number and type of securities purchased, the total purchase price paid in respect of the Subscriber's Units, the exemption relied upon in connection with such purchase, and the date of such distribution. 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 Cotn1nission. The following official can answer questions about the Commission's indirect collection of the information:
Ontario Securities Commission
20 Queen Street West, 22nd Floor
M5H 3 S8
Telephone: ( 416) 593-8314 Toll free in Canada: 1-877-785-1555
Facsimile: ( 416) 593-8122
Investor personal information is maintained on our secure networks. Your information may also be stored on or at a secure off-site storage facility. You may access your personal information to verify its accuracy, to withdraw your consent to any of the foregoing collections, uses and/or disclosures being made of your personal information and may update your information by contacting the Chief Compliance Officer at firstname.lastname@example.org. Please note that your ability to participate in the Funds may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information as outlined above due to our inability to comply with regulatory requirements if this consent is not provided.
If you have a complaint regarding the use of your personal information, you may contact the Privacy Officer by writing at Bromma Asset Management Inc., 44 Victoria Street, Suite 712, Toronto, Ontario, Canada M5C 1Y2 or emailing email@example.com.
Consent to Electronic Delivery of Documents
As part of the account opening process, BAM provides its clients with the possibility to consent to the electronic delivery of documents if they wish to receive electronic delivery of the documents which relate to their investment in the Funds. Clients can consent to this electronic delivery of documents by signing the applicable section of the Subscription Agreement for the applicable Fund. Clients’ consent may be revoked or altered, including any change in the electronic mail address provided, at any time by notifying BAM of such revoked or altered consent by telephone, regular mail, or electronic mail.
Updates of this Document
Dated: December 19, 2016