Personal Information Policy

BY OPENING AN ACCOUNT AT ACUMEN CAPITAL FINANCE PARTNERS LIMITED (“ACUMEN”), YOU ARE PROVIDING CONSENT TO ACUMEN TO COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION AS SET OUT IN THIS AGREEMENT.

 

1. Collection and Use of Personal Information by Acumen

When you open an account with Acumen, we will obtain personal information about you, which will be kept on file in accordance with industry regulations. We have implemented safeguards so that your person information remains strictly confidential and is protected against loss or theft, as well as unauthorized use, disclosure, access, copying, or modification. Safeguards include organizational measures such as access limited to authorized individuals and entities, physical measures and technological measures. The information that we collect allows us to identify you, to protect you against possible fraud, and to assess your potential investment needs so that we may suggest products and services to you, which are appropriate for you and to comply with legal and regulatory requirements.

 

2. Consent
By opening an account at Acumen, you are providing consent to Acumen to collect, use and disclose your personal information as set out in this agreement. This consent is required before we may provide your information to any third parties. The consent that you provide to Acumen with regards to the collection, use and disclosure of your personal information may be cancelled at any time by providing written notice to Acumen. Acumen does not require your consent for the collection, use and disclosure of your personal information where:
• Such collection, use and disclosure is reasonably required in the
normal course of providing service to your account,
• For the collection of a debt owed to Acumen by you (ex. under-margined account or delinquent cash account),
• To a law enforcement agency, securities regulatory authority or Self-Regulatory Organization,
• To legal counsel for the purpose of obtaining advice


3. Disclosure of Personal Information to Third Parties

By opening an account at Acumen, you consent that Acumen may from time to time disclose your personal information to third parties. We contract with outside services providers to ensure the proper administration of products, or to provide you with the services you require. These outside services providers include credit agencies, other financial institutions and other parties who provide services to Acumen. Our service providers are carefully selected and, when we contract outside service providers, they are only given the information necessary to perform the required services. Acumen may also rely on external sources to collect personal information about you.

 

4. Social Insurance Number
If you are an individual and open and account at Acumen, you consent that Acumen may collect, use and disclose your Social Insurance Number for income tax reporting purposes.


5. Affiliated Companies
By opening an account at Acumen, you consent that Acumen may from time to time disclose your personal information to affiliated companies (such as Acumen Financial Planning Services Ltd.) for the purpose of making related products and services available for you.


6. Accuracy, Access and Amendments to Personal Information

We take reasonable measures to keep personal information accurate, complete and current. You may request access to the information we have about you by contacting Acumen’s Chief Compliance Officer in writing. We rely on you to inform us of any change, errors or inaccuracies concerning your information. You may address access requests, amendments, questions or privacy-related complaints to the Chief Compliance Officer, Acumen Capital Finance Partners Limited, Suite 800, 500 4th Ave SW Calgary, AB T2P 2V6.


7. Retention of Personal Information
Acumen may retain your personal information on file after you cease to be a client of Acumen for as long as Acumen requires such information or as long as is demanded by our regulatory requirements.

 

8. Updating this Policy

We reserve the right to update this policy at any time. Any change will come into effect on the date of the most recent update. By continuing to use our services after this date, you accept the changes made to the policy.