In accordance with current federal privacy legislation, we have adopted new privacy practices to protect personal information for the following Labour Sponsored Investment Fund (LSIF) corporations:
- Covington Fund II
- Covington Venture Fund
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal e-mail address and home telephone number.
How do we obtain your personal information?
Unless you call us and ask to be placed on our Supplemental Mailing Lists in order to receive annual or semi-annual reports for certain of our investment products, we do not collect any information directly from you. Instead, you provide personal information when you supply the information required in order to complete subscription forms to purchase our products or RSP loan applications in order to borrow money to buy our products. Those forms and applications are sent directly to our third party service providers.
How is your personal information used?
Your personal information is used for the following purposes:
- To identify you;
- To ensure records are accurate;
- To establish and administer your account;
- To execute your transactions;
- To maintain, store, record and determine your account holdings and transaction records;
- To verify previously given information when necessary;
- To provide you and your representatives with account statements, tax receipts, proxy mailings, transaction confirmations and any other information that may be requested or needed to service your account;
- To provide you with quality customer service and support on your investment needs;
- To protect the interests of the Fund; and
- To meet legal and regulatory requirements.
We do not sell your personal information to third parties and we will not market directly to you. Your personal information will only be used to assist us and our service providers in providing you with the best possible service. We may also provide your personal information to other third parties, only, however, to meet your service requirements and our (and in many cases, your) legal obligations. Third parties that may be provided with your personal information include:
- Your financial respresentative;
- Contracted third-party service providers;
- Canadian governments, government agencies and regulators; and
- Any other legally required institutions.
Disclosing your personal information when required or permitted by law
We may be required to provide your personal information in response to a search warrant, court order or other legally valid request. We may also disclose your personal information to help enforce our legal rights.
Obtaining your consent
Your consent is implicitly obtained when you complete subscription forms to purchase our products, complete RSP loan applications in order to borrow money to buy our products or call us and provide us with your personal information so we can place you on our Supplemental Mailing List. If we plan to use your information for any purpose other than those stated in this policy, we will contact you to obtain your consent.
Withdrawing your consent
You may withdraw your consent for the use of your personal information by contacting us at any time. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products is able to provide to you, and may in certain circumstances result in the loss of certain of your benefits, e.g., tax credits.
Access to and accuracy of your personal information
Upon request we will arrange for you to have access to your personal information. In addition, we will provide you with a list of third parties to whom your personal information was provided In certain circumstances we may not be able to arrange access to specific pieces of information. For example: (i) information containing references to other persons, (ii) information containing propriety information confidential to us or our affiliates (iii) information that has been destroyed or (iv) information that is too costly to retrieve.
Where is your personal information kept?
Your personal information will be kept in electronic or paper format in the offices of our third-party service providers. Other than supplemental mailing lists, we do not maintain any personal information at our offices. We have put in place certain safeguards to protect your personal information. In addition, service providers who we deal with also have also implemented policies, procedures, guidelines, and safeguards to protect personal information that they collect on our behalf. We urge you to visit the “privacy” links on each of the following websites to review those polices: www.ci.com.