Privacy Policy




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Introduction

We at Arrow Capital Management Inc. ("Arrow" or "we") take the protection of personal information seriously. We have adopted a comprehensive privacy policy and have implemented practices to protect the confidentiality of personal information. As part of our services, Arrow also routinely collects and processes individual personal information of our Clients ' customers. In this statement, we refer to these customers as "investors".

What is PIPEDA?

Personal Information Protection and Electronic Documents Act (PIPEDA) is the privacy legislation introduced by the Federal Government. It is based on ten principles that form the ground rules for the collection, use and disclosure of personal information. Its purpose is to give individuals greater control over how their personal information is handled by the private sector. PIPEDA is implemented in three stages with the final stage slated to become effective on January 1, 2004. After this final stage is implemented PIPEDA, or an equivalent form of provincial legislation, will cover virtually all commercial activities within Canada. In accordance with PIPEDA, we are committed to protecting the privacy of investors' information and regard this as an integral part of our service. Our Clients collect an investor's personal information and obtain the necessary consent for using that personal information. Arrow keeps all personal information in strict confidence and controls access to, and use of, such information, based on practices and procedures described in this statement.

Personal Information and Obtaining Consent

Personal information is any information that identities an individual. This includes an individual's name, address, age, financial records, social insurance number, credit history, personal e-mail address and home telephone number.

Why do we need personal information?

In our capacity as a fund manager, our Clients provide us access to their customer's personal information. It is our Clients' responsibility to obtain their customers personal information as well as consent for its use. Arrow will ensure such personal information is processed in a protected manner and is used to provide the best possible service to our Clients and their investors. 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;

Comply with the law. How do we obtain personal information and the consent to use it?

Typically, an investor's consent is obtained by our Clients at the time of account opening, either through the application process, by means of verbal consent, or in some form of disclosure document. There may be occasions when personal information is collected from the investors themselves, their advisors or dealers, credit bureaus or other financial institutions. In these instances we would ensure the necessary consent has been obtained before collecting and using their personal information. How do we use personal information?

Arrow 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, proxy mailings, transaction confirmations and other information that may be requested or needed to service their accounts;
  • Provide investors with quality customer service and support;
  • Protect the interests of Arrow and our Clients, in areas such as debt recovery; and

Meet legal and regulatory requirements. Who do we disclose personal information to?

An investor's personal information will only be used for the purposes for which it was collected. Arrow may share personal information with other parties as required by law and with third parties assisting us in providing services, including investor statement preparation and printing. Arrow 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. We may also disclose personal information to help us collect a debt owed by the investor to Arrow or our Clients. Withdrawing consent

Investors are able to withdraw consent to use their personal information by contacting the provider of the product or service. Legal or other requirements may prevent investors from withholding consent and a decision to withhold personal information may limit the services or products Arrow and our Clients may be able to provide to investors. Investors should contact Arrow's Managing Director and CFO to withdraw consent to any use and disclosure of Investor Information.

Accessing Personal Information

Individuals have the right to verify the accuracy and completeness of their personal information, and may request that it be amended. We will work with our Clients to facilitate any investor request to access and review their personal information held by Arrow on the Client's behalf. An investor who wishes to change or update his or her personal information may do so at any time. Please note that we may not make the change if the changed information is no longer needed to fulfill the stated purpose.

Under certain circumstances, Arrow may not be able to provide investors with access to specific portions of the information. For example: (i) information containing references to other persons, (ii) information containing proprietary information confidential to Arrow or our Clients, (iii) information that has been destroyed or (iv) information that is too costly to retrieve.

Where is personal information kept?

Personal information in our possession may be kept in electronic or paper format in the offices of Arrow or our third party providers. Personal information may also be kept in secure offsite storage facilities.

Protecting Personal Information

Policies, procedures, guidelines, and safeguards have been put in place at Arrow to ensure personal information is protected in accordance with Canadian privacy legislation. Security measures including passwords, restricted access to our offices and records, physical access security have been put in place to protect personal information against unauthorized access, theft or misuse.

Our employees and service providers have access to personal information to enable them to perform their duties. Each Arrow employee is responsible for ensuring the confidentiality of all personal information accessed. As a condition of employment, every employee must sign a code of conduct, which includes comprehensive provisions ensuring the protection of personal information.

Any personal information collected from the investor will be used for the purposes identified at the time of collection and will be retained for as long as is necessary to fulfill the service or as required by law.

Arrow does not collect any personal information from visitors browsing our web site although personal information may be requested if a visitor chooses to send Arrow an email message.

Questions and Concerns

Inquires and complaints received will be reviewed by Arrow's Chief Privacy Officer and if required forwarded on to our Clients for their follow up. Contact information for Arrow's Chief Privacy Officer is provided below:

Arrow Chief Privacy Officer
Rob Parsons, COO & Managing Director
Tel: 416.323.0477
Toll Free Tel: 1.877.327.6048
Fax: 416.323.3199
E-Mail: rparsons@arrow-capital.com

Mailing Address
Arrow Capital Management Inc.
36 Toronto Street, Suite 750
Toronto, Ontario
Canada M5C 2C5

We will respond to all questions and concerns in a timely fashion.