Privacy Policy

Privacy Policy

This Privacy Policy describes the policies and procedures followed by SGGG Fund Services Inc. (together, “SGGG-FSI”, “we”, “our” or “us”) regarding the collection, use and disclosure of your personal information when you visit our website or otherwise interact with SGGG-FSI. This Privacy Policy applies to “Personal Data,” which is Customer Data that is associated with an identified or identifiable natural person and is protected as personal data or personal information under applicable data protection law.

SGGG-FSI is a data processor/service provider for its clients. SGGG-FSI customers, and not SGGG-FSI, determine how and why Personal Data submitted to us is used, either by or at the direction of such customers. With respect to such Personal Data, (1) SGGG-FSI is a “data processor” (“Data Processor”) under the EU General Data Protection Regulation (“GDPR”) and under Canadian privacy regulations, and (2) SGGG-FSI’s customers are the controllers under GDPR. (“Data Controller”). This Privacy Policy describes how SGGG-FSI processes Personal Data as a Data Processor for the purpose of providing fund administration services to our customers pursuant to the applicable data processing terms with those customers.

As Data Controllers, SGGG-FSI’s customers are responsible for disclosing the rights of individuals (“Data Subjects”) with respect to their Personal Data and other information regarding the collection and use of that Personal Data, in accordance with the GDPR, and other laws requiring such disclosures.

Definition of Personal information. When used in this Privacy Policy, personal information means any information about an identifiable individual. This may include, for example, your name, contact information, email-address, information relating to your account, including your identity and the services you use and subscribe to, as well as credit and banking information, billing records and any complaints documented in a file. It may also include other types of more technical information (such as information collected from visitors to the website) but only when this information can identify you as an individual. Personal information that is aggregated and or anonymized and cannot be associated with an identifiable individual is not considered to be personal information.

Collection of Personal Information. We process personal information to enable us to provide our clients the services they have engaged us for. in connection with fund administration investment in our funds, in order to give you the best possible service, allow us to establish your identity, protect us from error and fraud, assess your eligibility in our products, to comply with the law and to meet legal and regulatory requirements, for any other purpose to which you may consent in the future or for the purposes listed in section “Use of your Personal Information” below. When you visit the website, receive services from us or otherwise interact with SGGG-FSI or in connection with the offering and sale of units of our funds, we may collect and process the following data about you:

Information that we collect about you – Our clients may give us personal information including your name, company name, contact details including address(es), telephone number(s) and email address.

We may automatically collect basic technical information from all visitors to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (see section on Cookies below). These tools collect certain standard information that your browser sends to the website such as your browser type and language, access times, and the address of the site from which you came to the website. They may also collect your Internet Protocol (“IP”) address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.

Use of your Personal Information. We may use personal information to carry out the following purposes:

  • To contact you and to respond to your requests, enquiries and other communications
  • To deliver services to you on behalf of our customers
  • For employment recruitment purposes
  • For business administration, including statistical analysis
  • To personalize your visit to the website and to assist you while you use the website
  • For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice including complying with any obligations that derive from anti-money laundering and counter-terrorism legislation

Sharing your Personal Information. We may use selected third parties to provide us with services or technical support for the website and our systems who may have access to your personal information. All service providers are permitted to use data only for the purpose of performing services on our behalf. Similarly, we may share your personal information as required by law to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial, regulatory and taxation authorities.

International Transfer. Our computer systems are currently based in Canada, which means that information we collect will be processed by us in Canada, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. If you use or visit our website from outside Canada, you consent to the collection and/or processing in Canada of information we collect from you. In some cases, personal information that we manage may be transferred, processed and stored outside your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable there. You hereby consent to the transfer of your personal information to recipients as described in this Privacy Policy which are located outside of your country of residence.

Consent. Unless you otherwise advise, by providing us with your personal information you have consented to our collection, use and disclosure of your information as provided herein. You have a right to object to processing of your personal information where that processing is carried out for our legitimate interest and/or this processing is not core to the services or products provided. You may withdraw your consent at any time by contacting SGGG-FSI at the following number: (416) 967-0038.  The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal, and it will not preclude the future processing of personal information if within our legitimate interest. Please note that your ability to participate or invest in a fund may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information. Security. Your personal information is maintained on our networks or on the networks of our service providers accessible at 121 King Street West, Suite 300, Toronto Ontario Canada. Your information may also be stored on a secure off-site storage facility. SGGG-FSI maintains physical, electronic and procedural safeguards reasonably designed to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.  SGGG-FSI can make no guarantee that these procedures will prevent all unauthorized access, and as a result, personal information submitted through or contained on the website or on our systems may be vulnerable to unauthorized disclosure to unknown third parties.

Retention. SGGG-FSI may retain your personal information as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Children’s Privacy.  No part of our website is targeted to attract anyone under 18.

Cookies. The website may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of the website. Cookies may also help us diagnose problems with our server and the website. If you do not want us to use cookies when you use the Website, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org.  The website will also explain how you can delete cookies which are already stored on your device.

Revisions to this Privacy Policy. We may revise or supplement this Privacy Policy from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a notice on our website, prior to the change becoming effective and obtain your consent when required by law. We encourage you to refer to this Policy on an ongoing basis so you understand our current privacy practices.

Contact Us. If you have any questions or comments about our Privacy Policy, please feel free to contact us (416) 967-0038