Privacy Policy
At CanFirst Capital Management, we are committed to protecting the privacy and confidentiality of personal information entrusted to us. This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws.
1. Scope and Application
This policy applies to all personal information collected by CanFirst Capital Management, including in relation to:
Investors and prospective investors in CanFirst funds (e.g., CIPREF)
Financial advisors and intermediaries
Service providers and business partners
Visitors to our website(s), including www.canfirst.com
This policy does not apply to aggregated or anonymized information that cannot be associated with an identifiable individual.
2. What Personal Information We Collect
We may collect the following types of personal information:
Identification and Contact Details: Name, mailing address, phone number, email address, date of birth, occupation.
Financial and Investment Information: Net worth, investment preferences, tax residency status, banking information, and details required to assess accredited investor status.
Regulatory and Compliance Information: SIN (where required by law), Know-Your-Client (KYC) data, anti-money laundering (AML) due diligence records.
Website and Communications: IP addresses, browsing behavior on our website, and communication preferences.
3. How We Use Personal Information
We use personal information to:
Establish and manage investor accounts
Determine investor eligibility and suitability
Comply with legal and regulatory requirements
Facilitate subscriptions, redemptions, and distributions
Communicate with investors, advisors, and service providers
Improve our services, operations, and digital experience
Send marketing materials where permitted by law (opt-out available)
4. Consent
We collect, use, and disclose personal information only with your consent or as otherwise permitted or required by law. Consent may be express or implied depending on the circumstances and the sensitivity of the information. You may withdraw consent at any time, subject to legal or contractual restrictions.
5. Sharing and Disclosure of Information
We may share your personal information with:
Authorized representatives acting on your behalf
Our affiliated funds and companies for fund administration
Financial institutions, custodians, and transfer agents
Legal, tax, compliance, and other professional service providers
Government regulators, tax authorities, or law enforcement where required
We do not sell or rent personal information to third parties.
6. Cross-Border Transfers
In some cases, your information may be stored or processed outside Canada by our service providers. In such cases, the information may be subject to the laws of that foreign jurisdiction. We use contractual and other safeguards to protect personal information processed on our behalf.
7. Retention of Personal Information
We retain personal information only as long as necessary for the purposes for which it was collected, or as required by applicable law or regulation. When no longer required, information is securely destroyed or anonymized.
8. Security Measures
We employ administrative, technical, and physical safeguards to protect personal information from unauthorized access, use, or disclosure. These include:
Role-based access controls
Secure servers and encrypted storage
Cybersecurity monitoring and firewalls
Ongoing employee training and confidentiality agreements
9. Your Rights
Subject to applicable law, you have the right to:
Access your personal information held by us
Request corrections to your information
Withdraw consent to processing
File a complaint with the Office of the Privacy Commissioner of Canada
Requests may be submitted in writing to our Privacy Officer (see below).
10. Website & Cookie Practices
Our website may use cookies and similar technologies to enhance your browsing experience. You can control cookie preferences through your browser settings. Third-party analytics tools may also collect anonymized traffic data.
Our website may contain links to external sites. This Privacy Policy does not apply to those sites, and we are not responsible for their content or privacy practices.
11. Changes to This Policy
We may update this Privacy Policy periodically. Any changes will be posted on our website with the updated effective date. We encourage you to review this policy regularly.
12. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact:
Privacy Officer
CanFirst Capital Management
20 Eglinton Avenue West, Suite 1400
Toronto, ON M4R 1K8
Phone: 416-924-9009
Email: info@canfirst.com