The privacy of our investors is very important to us and we are committed to keeping personal information confidential and secure.  Bedford Park Capital Corporation (“Bedford Park’, “we”, “our” and “us”) has established policies regarding the collection, use, disclosure and protection of personal information of current and former clients, subscribers and  investors and potential investors. In this policy we outline what information we have, why we need it and how it is used, shared and protected. We also describe your rights with respect to your privacy.
 

Our business requires that we collect and process personal information of our investors who come to us either directly or through dealers and other intermediaries. We keep all personal information in strict confidence and control access to, and use of, such information based on the practices and procedures described in this policy statement.

Bedford Park does not collect any personal information from visitors browsing our website although personal information may be requested if a visitor chooses to send Bedford Park an email message. In addition, in the course of saving the contact information you enter in the forms on this site, Bedford Park uses a cookie to store information locally on your computer.

Information Collected, Purpose and Consent
 

Personal information refers to information that identifies you. It is primarily collected when you first establish your relationship with Bedford Park or as circumstances change over time. For a personal account this information would include, among other things, your name, address, contact information, date of birth, occupation, marital status, social insurance number, current financial position, investment experience, risk tolerance and intended use of your account. We are also required to directly examine certain government issued identification to assist in addressing anti-money laundering requirements. For corporate, trust, estate and other non-personal accounts we will need to obtain personal information about all persons authorized to provide directions and for all beneficial owners.

We collect your personal information in order to establish your identity, meet regulatory requirements, protect you and us from error and fraud, assess your eligibility in our products and services and for any other purpose to which you may consent in the future. Your personal information is also used to establish and administer your accounts, execute transactions and to provide you, or your authorized representative, with account statements, tax receipts and any other information that may be requested or needed to service your account. Your information is also used in our internal business operations and is necessary in fulfilling our legal and regulatory requirements.
 

Personal information is received directly from you or from your investment advisor with your consent. You always have the option of not providing the personal information that is requested, however, we may not be able to open or maintain your account or provide services to you. Personal information is collected from the following sources:

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• subscription agreements or other forms that you submit to us;

• your transactions with us and our affiliates; and

• meetings and telephone conversations with you.

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Unless advised otherwise by you, by providing Bedford Park with you personal information you have consented to our collection, use and disclosure of your personal information as provided in this policy statement.

Disclosure and Retention

We may share personal information with other parties as required by law and with third parties assisting us in providing services, including investor recordkeeping, statement preparation and printing. We may be required to provide personal information when responding to a search warrant, court order or other legally valid request. In particular, we disclose your Social Insurance Number in order to comply with Canada Revenue Agency's income reporting requirements and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Additionally, we may disclose your personal information to third parties, when necessary, in connection with the services we provide, including, without limitation:

 

• to financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, investment funds managed or advised by Bedford Park;

• to other service providers, as necessary, such as accounting, legal or tax preparation services;

• taxation and regulatory authorities and agencies including to applicable securities regulatory authorities; and

• your financial advisors, only where we have your consent to do so.

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We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.

Subscribers in funds managed or advised by Bedford Park should be aware that the funds are required to periodically file reports with securities regulatory authorities, setting out the subscriber’s name and address, the class and series of units issued, the date of issuance and the purchase price of units issued to the subscriber.

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Your personal information in our possession may be kept in electronic or paper format at the offices of Bedford Park or our third-party service providers. Your information may also be kept in secure off-site storage facilities. Any personal information collected from an investor will be used for the specified purposes and will be retained for as long as is necessary to provide the service or as required by law. Personal Information no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous in a secure manner.
 

Safeguards
 

Bedford Park will take reasonable physical, electronic and procedural safeguards to protect all personal information against loss or theft as well as unauthorized access, disclosure, copying, use or modification by security safeguards appropriate to the sensitivity of the information. We maintain such security measures as passwords and restricted access to our offices and records to protect personal information against unauthorized access, theft or misuse. Access to personal information will be restricted to our employees who have a need to know such information, when possible. All of our employees are subject to confidentiality requirements to ensure that confidential information is not inappropriately utilized or divulged to any other person, except as required. We ensure that our employees and service providers are familiar with this privacy policy.
 

Openness and Access
 

Upon request, 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 your personal information and may update their information. Access to requested information will generally be provided within 30 days of the request being made. If our clients and investors require more information, or have concerns, regarding ours personal information management please contact the Chief Compliance Officer at:
 

Bedford Park Capital Corporation
106 Avenue Road
Toronto, Ontario
M5R 2H3 
Tel: 416-623-8190
 

You may withdraw your consent for the use of your personal information by notifying Bedford Park in writing of your intention to do so. Legal and other requirements may prevent you from withdrawing consent. Please note that our ability to provide services may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information as outlined above.

Bedford Park may update this privacy policy from time to time. Updated versions will be posted to our website.