Privacy

Effective January 1, 2004, organizations in Canada that collect, use or disclose personal information in the course of commercial activities are required to comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"). Similar legislation is, or soon will be, enacted at the provincial level in Quebec, British Columbia, and Alberta. As required by the legislation, VL Advisors Inc. ("VentureLink") has put in place policies and procedures to effectively safeguard any confidential information that we have on file or collect. To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA. For information in addition to this policy, please read the Question & Answer sheet that we have prepared for you.

How we collect, use and disclose personal information We ask you for only the information we need.

We collect only the information we need for the purposes we have identified to you.

Our files are kept for the purpose of providing and servicing financial and insurance products and services that we believe are right for you, over your lifetime.

We will not sell your personal information. ˆtop

Why we need the information

Generally, we need to collect personal information to:
  • understand your needs,
  • determine your eligibility,
  • continue to offer you the full range of products and services that we believe meet your changing needs and to service such products and services,
  • meet regulatory or contractual requirements relating to the products and services provided to you.

We will make sure you understand why we need the information by using clear, understandable language when we identify the purpose. ˆtop

We will limit how long we keep information

We are responsible for your information
We will keep your personal information as long as it is necessary, including updating the product or service or as required by law. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.

We will protect your personal information
We are responsible for all personal information in our possession, including information transferred to a third party service provider or agent, so that we can provide you with a product or service. All employees, agents and authorized service providers of VentureLink are required to protect the confidentiality of your personal information.

How we protect information Access to your personal information is restricted to those of VentureLink's employees, agents and authorized service providers who need it to do their jobs. We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a "need-to-know" basis, and technological measures such as the use of passwords and encryption. ˆtop

Your right to access your personal information

Your rights
You have the right to ask whether we hold any personal information about you and to see that information, as provided by law.

You have the right to know:
  • how we collect your personal information,
  • how we are using it, and
  • to whom it may have been disclosed.

How to request an update or correction If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it.

If you show that your personal information is inaccurate or incomplete, we will make the necessary changes.

If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.

How to register complaints
You may register a privacy-related complaint by contacting VentureLink's Privacy Officer. We will explain VentureLink's complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.

For more information
For more information, please contact VentureLink's Privacy Officer at (416) 681-6372 or by email at ghorton@venturelinkfunds.com. ˆtop

VentureLink's Privacy Code

Principle 1 - Accountability
Each member, employee or agent of VentureLink is responsible for personal information under his or her control and each member company shall designate an individual or individuals to be accountable for compliance with this Code.

Principle 2 - Identifying Purposes
The purposes for which personal information is collected shall be identified before or at the time the information is collected.

Principle 3 - Consent
The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.

Principle 4 - Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.

Principle 5 - Limiting Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.

Principle 6 - Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.

Principle 7 - Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness
VentureLink will make readily available to its customers and employees specific information about our policies and procedures relating to the management of our personal information.

Principle 9 - Individual Access
Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Handling Customer Complaints and Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Privacy Officer at ghorton@venturelinkfunds.com. ˆtop

Privacy Issues - Questions and Answers

Q1. Is my privacy protected by VL Advisors Inc.?
VL Advisors Inc. follows the fundamental principles of privacy protection contained in the Personal Information Protection and Electronic Documents Act ("PIPEDA"). These standards ensure that you have control over your personal information by requiring that we obtain your consent to collect, use or disclose information about you.

Q2. What exactly is PIPEDA?
PIPEDA is federal legislation that sets out the ground rules for how organizations may collect, use or disclose information about you in the daily course of business. It came into effect for securities and mutual fund dealers and advisers, including investment fund managers like VL Advisors Inc., on January 1, 2004. It gives you the right to see and ask for corrections to information an organization may have collected about you. It also sets out the right to complain if you think an organization covered by the Act is not living up to its responsibilities under the law.

Q3. What is personal information?
"Personal information" under PIPEDA means information about an "identifiable individual." VL Advisors Inc. will only collect the information we require. But under PIPEDA, certain information from other groups may include:

  • name, age, weight, height
  • medical records
  • income, purchases and spending habits
  • race, ethnic origin and colour
  • blood type, DNA code, fingerprints
  • marital status and religion
  • education
  • home address and phone number

"Personal information" does not include the name, job title, business address or office telephone number of an employee of an organization that is covered by the new law.

Q4. Why does VL Advisors Inc. need to collect and use personal information about me?
We collect a lot of information every time we open an account. Regulators require that dealers have a complete understanding of each client's personal and financial circumstances to open an account and make suitable investment recommendations. We are also required to keep additional information on file to comply with anti-money laundering and tax reporting requirements. Because we need to have access to certain fundamental personal information about every client to operate an account within the boundaries of regulatory restrictions, we require consent to the collection and use of this information before we can open the account. Some of the purposes and uses for the information are as follows:

  • operate an account
  • to provide additional services requested by the client
  • to properly report account status back to the client
  • to provide all required tax reporting
  • to properly discharge our regulatory responsibilities with respect to securities rules
  • to properly discharge our obligations under federal anti-money laundering and suppression of terrorism
  • legislation

Q5. How is consent for the collection and use of information given?
Consent may be express or implied and may be obtained in a variety of different ways under the legislation - in writing or verbally. We collect most of the information we require at the time an account is opened through the completion of an account application form. By signing an account application form, clients consent to VL Advisors Inc. collecting and using the information. In some cases, we may require additional personal information and we will ask for your written consent for the use and collection of this at the time it is collected.

Q6. What protections are available under PIPEDA?

PIPEDA gives you the right to:

  • know why an organization collects, uses or discloses your personal information;
  • expect an organization to collect, use or disclose your personal information reasonably and appropriately, and not use the information for any purpose other than that to which you have consented; know who in the organization is responsible for protecting your personal information;
  • expect an organization to protect your personal information by taking appropriate security measures;
  • expect the personal information an organization holds about you to be accurate, complete and up-to-date;
  • obtain access to your personal information and ask for corrections;
  • complain about how an organization handles your personal information.

PIPEDA requires all organizations to:

  • obtain your consent when they collect, use or disclose your personal information;
  • collect information by fair and lawful means;
  • have personal information policies that are clear, understandable and readily available.

Exceptions to these principles may exist where, for example, the information is required by law or is being compelled by an enforcement agency for an investigation.

Q7. Are there other rules on privacy issues?
PIPEDA will apply federally, unless provincial legislation that is substantially similar to it has been enacted. At present, Quebec is the only province with a personal data protection law in effect that applies to the provincially regulated private sector. This law, in addition to regulating the collection, use and disclosure of personal information held by commercial enterprises, also provides Quebecers with a general right of access to and correction of personal information. The provinces of British Columbia and Alberta have advised that they also intend to put privacy legislation into effect in the near future. There are also some sector-specific privacy rules that apply to certain types of information, such as medical information. We will also observe these rules as they apply to information we obtain at VL Advisors Inc.

Q8. How do I have any concerns about privacy issues addressed?
We have appointed a Privacy Officer to deal with any concerns you may have on privacy issues. You may contact this individual in writing at the following address:

Privacy Office VL Advisors Inc.
3 Church Street, Suite 602
Toronto, Ontario
M5E 1M2
Attn: Privacy Officer

Alternatively, you may contact us by phone at (416) 681-6372 or e-mail at ghorton@venturelinkfunds.com.

Q9. How can I see the personal information VL Advisors Inc. has about me?
Send a written request addressed to our Privacy Officer. You should provide enough detail to allow us to identify the information you want. For example, include dates, account numbers, and the names or positions of people you may have dealt with at VL Advisors Inc.

Q10. How can correct errors or omissions in my personal information?
Again, send a written request to our Privacy Officer and explain the correction you are requesting. Supply copies of any documents that support your request, if you have them.ˆtop