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Privacy Policy

METIS SETTLEMENTS DEVELOPMENT CORPORATION - PRIVACY POLICY

The privacy and security of personal information is very important to Metis Settlements Development Corporation and its affiliates, including its investment funds and related general partners (collectively, “MSDC”, “we”, “us” or “our”). It is our policy to protect and respect the privacy of personal information in accordance with applicable privacy laws. This Privacy Policy (the “Policy”) explains our privacy and security practices with respect to all personal information in our possession and control, and may be supplemented by specific policies, procedures, and practices.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

Why does MSDC collect personal information?

We may collect personal information from individuals (such as from clients, staff, sub-contractors, and third-party suppliers and providers) for the following purposes:

  • To administer, plan, and manage the relationship with individuals and to communicate with individuals;

  • To provide individuals with requested information, products, and/or services;

  • To better understand how we may improve our investment strategies, to develop and conduct our business and operations, and for other internal business purposes;

  • To execute transactions for MSDC and its partners;

  • To provide tax receipts, fund information and other information that individuals may request or require;

  • To maintain information on an individual’s account regarding holdings, capital contributions and distributions;

  • To provide individuals with information on developments with respect to MSDC and its affiliates, partners and portfolio companies (in accordance with Canada’s Anti-Spam Legislation – see below); and

  • To comply with applicable legal and regulatory requirements or to protect our legal rights and property;

(collectively, the “Authorized Purposes”).

The type of information that we may collect from individuals includes, for example, name, title, email address, address, phone number, social insurance number, business and tax identification number, beneficiary information, employment information, personal bank account information, contribution and distribution history, and other information individuals choose to provide.

 

We may collect personal information for other purposes where we have a legal duty or right to do so or where we have a good faith belief that it is necessary to protect our property or other rights.

We do not collect personal information for any other purposes unless we have the consent of the individual to whom it relates.

How does MSDC collect personal information?

We only collect personal information about an individual with the individual’s knowledge and consent. Generally, this means that we collect personal information directly from the individual to whom it relates, whether via our website, e-mail, telephone, fax, personal or electronic delivery of document or in person. Occasionally, we may collect personal information from third party sources, but only with the knowledge and consent of the individual or where otherwise authorized by law.

 

Visitors to our website should also be aware that anonymous technical information may be collected by us as a result of a visit to our website. For example, this information may include the visitor’s IP address, browser type, operating system, domain name, access times and referring website addresses. We use this anonymous technical information for purposes such as diagnosing problems with our servers, improving the operation and content of our websites and compiling aggregate and statistical information.

 

We will not attempt to link or match such anonymous technical information with any personally identifiable information unless we have an individual’s consent, we (or our service providers) have detected or reasonably suspect any unlawful use of our services or a security breach, or we have a legal duty or right to do so.

We may use “cookies” on our website. “Cookies” are small text files placed on computers that can collect and store a variety of information. Permanent cookies are stored indefinitely on a user’s hard drive unless manually deleted, while temporary cookies are automatically deleted from the user’s browser upon logging out of a website. Web browsers typically allow users to disable permanent and/or temporary cookies.

Please note that we use third party analytics services for our website, such as Google Analytics. There is more information about how these service providers including Google collect, use, and process data on their respective websites including at http://www.google.com/policies/privacy/partners/. 

Pages of our website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Please note that our website contains links to other websites. We are not responsible for the privacy practices used or followed by other websites. You are encouraged to be aware of when you leave our website, and to read the privacy statements of every website you may visit that may collect personal information from you.

When does MSDC use or disclose personal information?

We only use or disclose personal information as reasonably required to facilitate the Authorized Purposes listed above.

In some cases, we may share personal information with third party service providers performing functions on our behalf, including, for example, vendors that provide information technology services, fund administration, legal advice or provide analytics or assessment services.

MSDC has a close working relationship between the affiliated companies within its corporate structure. Personal information may be shared between these organizations to facilitate the Authorized Purposes listed above in accordance with this Policy.

We do not otherwise use or disclose personal information unless we have an individual’s consent, we have a good faith belief that disclosure of the information is necessary to protect the rights or property of MSDC, or we have a legal duty or right to do so.

We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of MSDC or any of its affiliates, or a portion of MSDC or any of its affiliates, or in connection with a strategic investment by a third party in MSDC or its affiliates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.  We do not rent, sell, or trade client lists or other personal information.  

Consent – Is there a choice?

Individuals provide their consent to the collection, use, and disclosure of personal information by MSDC when they provide their information to us or use our products or services, including investing in or receiving investment from one of our investment vehicles.

Individuals can deny or withdraw their consent to our collection, use and disclosure of their personal information at any time upon reasonable notice, subject to any legal or contractual requirements. However, if consent is denied or withdrawn, we may not be able to provide certain products or services.

MSDC and its affiliates may use personal information to inform individuals of developments that MSDC or its affiliates or partners believe will be of interest to individuals in accordance with applicable laws including Canada’s Anti-Spam Legislation. Such communications may be made by way of telephone, text message, direct messaging, e-mail, fax, or regular mail. Individuals provide their consent to MSDC and its affiliates and partners contacting them in this manner when they use MSDC’s products or services. Individuals may opt-out of receiving such communications by contacting us at the address below.

How does MSDC protect the security of personal information?

We have in place reasonable policies, procedures and safeguards (including physical, administrative, technological, and organizational measures) designed to protect the security of personal information under our control and to secure individuals’ personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The protection of personal information is of paramount concern to us, and we are prepared to take appropriate and timely steps in the event of any incidents involving personal information in accordance with applicable privacy laws.

 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect individual’s personal information, we cannot guarantee the security of personal information transmitted to our website or otherwise via the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect individual’s personal information, we cannot ensure or warrant the security or privacy of any information individuals transmit to us, and such individuals do so at their own risk.

We make every reasonable effort to ensure that personal information is accurate and complete. This may involve requesting further information or updates from individuals. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with MSDC.

We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.

Does MSDC provide access to personal information?

We will provide individuals with access to the personal information we hold about them in accordance with applicable laws. We reserve the right to require that any request for access to personal information be made in writing. Generally, there is no cost for such access. However, we reserve the right to charge such costs on a case-by-case basis in accordance with applicable laws. The individual will be notified in advance if charges apply.

We will correct or amend the personal information in our files where it can be shown that the information is incorrect or incomplete.

Storage and Processing

We store personal information on our with our services providers.

Our service providers may store and/or process personal information outside of Canada (including in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. We have taken appropriate technical, organizational, and legal steps to secure this information.

Contact MSDC

For further information about our privacy practices, to make a request for access to personal information to exercise any other rights outlined in this Policy, please contact our Privacy Officer at the following address:

 

Email:  info@msdcorp.ca

This Policy is effective as of August 1, 2024  We reserve the right to change this Policy at any time in accordance with applicable laws – please check our website for updates to this Policy.

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