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PRIVACY POLICY

Introduction
We at Picton Mahoney Asset Management ("Picton Mahoney" or "we") are committed to keeping your personal information confidential and secure. We have adopted a comprehensive privacy policy and have implemented practices to protect the confidentiality of personal information. 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.

Picton Mahoney keeps all personal information in strict confidence and controls access to, and use of, such information based on the practices and procedures described in this statement.

Personal Information and Obtaining Consent
Personal information is any information that identifies an individual, including the person's name, address, age, financial records, social insurance number, credit history, personal email address and home telephone number.

As a fund dealer and manager, we obtain investors' personal information directly from clients and obtain their consent to appropriate use of that information, in account forms and subscription agreements. Where investors are introduced to our products through dealers or other intermediaries, those firms also may provide us access to the investors' personal information. In those cases, such firms are required to obtain their customers' personal information as well as consent for its use. An investor's personal information allows us to:
  • Establish an investor's identity;
  • Determine an investor's eligibility for a product or service;
  • Protect all parties against errors or fraudulent activity; and
  • Comply with the law.

Our Use of Personal Information
Picton Mahoney may use personal information to:
  • Identify the investor;
  • Ensure our records are accurate;
  • Establish and administer an investor's account(s);
  • Execute transactions;
  • Maintain, store, record, and determine investor account holdings and transaction records;
  • Provide investors and their authorized advisors with statements/information;
  • Provide investors with financial statements, tax receipts, unitholder mailings, transaction confirmations and other information that may be requested or needed to service their accounts;
  • Provide investors with quality customer service and support; and
  • Meet legal and regulatory requirements.

An investor's personal information will only be used for the purposes for which it was collected. Picton Mahoney 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. Picton Mahoney has legal agreements with such third party providers to ensure the proper handling and protection of personal information. Additionally, 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.

An investor should contact Picton Mahoney's Privacy Officer to withdraw consent to any use and disclosure of their personal information; however this may limit the investor's opportunity to access our services or products.

An investor who wishes to access or correct his or her personal information should contact our Privacy Officer and we will accommodate the request to the extent possible.

Storage and Security
Personal information in our possession may be kept in electronic or paper format in the offices of Picton Mahoney or our third party providers. Personal information may also be kept in secure offsite storage facilities. At Picton Mahoney 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.

Picton Mahoney ensures that our employees and service providers are familiar with this privacy policy, and agree to abide by it.

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.

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

Questions and Concerns
Any inquires and complaints received will be reviewed by Picton Mahoney's Privacy Officer and, if required, forwarded to an investor's dealer or other intermediary. Contact information for Picton Mahoney's Privacy Officer is provided below.

ONLINE PRIVACY POLICY
By using or accessing the website in any way, you acknowledge that you accept the practices and policies outlined in this Online Privacy Policy, and you hereby consent to our collection, use and disclosure of your information in the manner described herein. Please read this Online Privacy Policy carefully in order to understand what information Picton Mahoney collects about visitors to the website, and how Picton Mahoney uses that information. If you do not agree with the content of this Online Privacy Policy, please do not use this website. We encourage you to check our website frequently to see the current Online Privacy Policy and Terms of Use in effect and any changes that may have been made to them. If we make material changes to this Online Privacy Policy we will post the revised Online Privacy Policy and the revised effective date on this website. If you use the website after any changes to the Online Privacy Policy have been posted, this means you agree to all of the changes. This Online Privacy Policy is part of our Terms of Use. Please click here to see that agreement. You may withdraw your consent to collection, use and disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable notice.

What information is collected and how is it used?
Picton Mahoney Asset Management (“Picton Mahoney”) collects personal and other information provided by you. Picton Mahoney also collects information about your device through our website, such as device model, unique device number, browser type, and Internet Protocol address. Information provided by you or about your device helps us improve the website functionality, meet our clients’ needs, provide information that may be of interest to you, measure the effectiveness of our services, enhance security measures and protect our customers. We track user activity of individuals who log in to allow our wholesalers to review your use of the site and use this info to contact you with recommendations for portfolio construction as well as other articles or links that may be of interest to you. (There is detailed event driven tracking of your use of the site).

Does Picton Mahoney collect information about physical location?
No, Picton Mahoney does not collect information about your device’s approximate physical location.

Will Picton Mahoney share the information?
For the purposes stated above or as described within the website, Picton Mahoney may share the information collected with our employees or third parties acting as our service providers or agents, who are required to maintain the confidentiality of the information. We may share the information collected with government agencies, public bodies, regulators or other entities where permitted or required by law.

Does Picton Mahoney use Cookies?
Picton Mahoney may use Persistent Cookies, Non-Persistent Cookies and Web Beacons to monitor and improve your website experience and as part of the functionality and security of the website. These Cookies do not contain personal or financial information. They gather information about things like whether you are a new or returning visitor, the name of the referring URL (website that sent you to www.pictonmahoney.com), which version of the site you're visiting (desktop or mobile), they track session ID and user authentication status, and they keep track of actions a user is only permitted to do once (e.g. voting in a poll, or rating content). This kind of information helps Picton Mahoney to evaluate the design, content, navigation, use and functionality of its website to better tailor a user’s experience and use this information to compile data about website usage and patterns. Picton Mahoney may also use Cookies to collect information about online activities and preferences. Examples include web pages visited, length of visits, and successful downloads. This information may be used together with other information to: (a) help us better understand the user’s interests and needs, (b) provide the user with a customized online experience, and (c) present new tools and website functions. For a full list of cookies see: https://docs.kentico.com/display/K8/Reference+-+Kentico+cookies.

Picton Mahoney may use Cookies as part of the functionality of a particular service and the choice not to accept these Cookies may prevent certain features within the service from operating. Please refer to the documentation for your browser or device regarding how to allow or refuse Cookies.

How does Picton Mahoney update our Online Privacy Policy?
This Online Privacy Policy is to be read together with and forms part of the Picton Mahoney Legal Terms of Use.

Security
Picton Mahoney uses appropriate physical, organizational and technological measures to protect the personal information you provide to us against loss or theft, and unauthorized access, disclosure, copying, use, or modification. However, no online data transmission or storage can be guaranteed to be secure from access by unintended recipients and Picton Mahoney will not be responsible for any breach of security unless this breach is due to its gross negligence.

Contact Us
If you have a question or concern about any collection, use or disclosure of personal data by Picton Mahoney or wish to access or correct your personal data, please contact our privacy officer by sending an e-mail to privacy@pictonmahoney.com.

DEFINITIONS

Cookies
A small file containing a unique identification number that a website sends to your computer's web browser. When you visit a website, a cookie may be used to track the activities of your browser as well as provide you with a consistent, more efficient experience. The two common types of cookies are persistent and non- persistent. Cookies cannot view or retrieve data from other cookies, or capture files or information stored on your computer. Only the website that sends you cookies is able to read them.

Persistent cookies
Persistent cookies are stored on your computer's hard drive where they remain resident until they are either deleted or they reach a predetermined expiration date. Persistent cookies are most commonly used to provide visitors with a customized experience by recording preferences such as how a visitor prefers to have his/her web pages displayed. Additionally, cookies are commonly used to gather statistical information such as the average time spent on a particular page. This kind of information provides insight on how organizations can improve the design, content and navigation of their website.

Non-persistent cookies
Non-persistent cookies do not permanently record data and they are not stored on your computer's hard drive. Rather, non-persistent cookies are stored in memory and are only available during a single active session. Once a session ends, the cookie disappears. Non-persistent cookies are used primarily for technical reasons, like providing seamless navigation so users can navigate through webpages without having to log on to each separate page they visit.

Web-Beacons
Web Beacons are small and transparent images embedded in web pages that, when combined with Cookies, help provide a website operator with information about the use and effectiveness of a website.