Disclaimers & Policies

The privacy of our investors is very important to us. Sevenoaks Capital Inc. ("Sevenoaks") is committed to protecting your privacy and maintaining confidentiality of your personal information. This Policy may be updated from time to time without notice.

Sevenoaks complies with the requirements of Part 1 and Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") and all applicable provincial personal information laws. Attached is an overview of the privacy principles set out in Schedule 1 of PIPEDA.

What is Personal Information?
The term "personal information" refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number, birth date, assets and/or income information, employment history and credit history.

How do we collect your Personal Information?
We collect and maintain personal information about you when you open an account with or through us. We collect your personal information directly from you or through your advisor in order to provide you with services in connection with your investment, to meet legal and regulatory requirements and for any other purposes to which you consent. Your personal information may be collected from a variety of sources, including:

(a) subscription agreements, applications, questionnaires or other forms that you submit to us or contracts that you enter into with us;
(b) your transactions with us;
(c) meetings and telephone conversations with you; and
(d) our website (http://www.sevenoaks.com)

How do we use your Personal Information?
We collect and maintain your personal information in order to give you the best possible service and allow us to establish your identity, protect us from error and fraud, comply with the law and assess your eligibility for our products. In addition, we may use your personal information for:

(a) executing your transactions;
(b) verifying and correcting your personal information; and
(c) providing you and/or your advisor with confirmations, tax receipts, proxy mailings and financial statements in order to service and administer your account.

Who do we share your Personal Information with?
We may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the services we provide related to your account, but they will not share this information with others. Such information is only used for the purposes identified above. Sevenoaks will use contractual or other means to provide a comparable level of protection while the information is being handled by a third party service provider or agent. The following is a list of such third party service providers and agents:

(a) your advisor/dealer;
(b) financial service providers, such as investment dealers, custodians, banks and others used to finance or facilitate transactions or operations of your account;
(c) other service providers such as accounting, legal, or tax preparation services; and
(d) transfer agents, portfolio managers, brokerage firms and similar service providers, in connection with distributions to our limited partners

We may also be required by law to disclose information to government regulatory authorities (for example, we may be required to report your income to taxation authorities). As a member of the self-regulatory organizations ("SROs"), we may also be required to disclose your personal information to these SROs, which, collect, use and disclose such personal information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings. SROs may, in turn, disclose such personal information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.

We do not sell, lease, barter or otherwise deal with your personal information with third parties.

Sevenoaks may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, Sevenoaks may disclose your personal information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

How do we obtain your consent to the collection, use and disclosure of your personal information?
By signing an application form and/or continuing to do business with us, you are consenting to the collection, use and disclosure of your personal information for the purposes identified in this Privacy Policy. Sevenoaks will not, as a condition of the supply of products or services, require you to consent to the collection, use or disclosure of your personal information beyond that required to fulfill those purposes.

Can you withdraw your consent?
You may withdraw all or part of your consent for us to collect, use or disclose your personal information subject to legal restrictions and reasonable notice. Sevenoaks will inform you of the implications of such withdrawal of consent for the continued provision of services.

How do we safeguard personal information?
We carefully safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. Sevenoaks' employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of Sevenoaks' employees is required to sign a code of conduct, which contains policies on the protection of personal information.

Where is your personal information kept?
Your personal information is maintained on our networks or on the networks of our service providers accessible at 2 Bloor Street West, Suite 1720, Toronto, Ontario M4W 3E2. Your information may also be stored on a secure off-site storage facility.

How you can access your personal information?
You may request access to your personal information by writing to 2 Bloor Street West, Suite 1720, Toronto, Ontario M4W 3E2. We will respond to your written request promptly. Sevenoaks may be unable to provide you with full access to your personal information if we are prohibited by law or regulatory reasons or it has been destroyed. Sevenoaks will provide you with an explanation, if we are unable to fulfill your access request.

Summary of Privacy Principles set out in Schedule 1 of PIPEDA

1. Accountability: Sevenoaks is responsible for personal information under its control and the Chief Privacy Officer is accountable for Sevenoaks' compliance with the principles described in this Policy.
2. Identifying Purpose: The purposes for which personal information is collected will be identified by Sevenoaks at or before the time the information is collected. Sevenoaks will also document the purposes for which personal information is collected at or before the time the information is collected.
3. Consent: The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information by Sevenoaks, except where inappropriate.
4. Limiting Collection: Sevenoaks will limit the amount and type of personal information collected to that which is necessary for the purposes identified by Sevenoaks. The personal information will be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention: Sevenoaks will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
6. Accuracy: Sevenoaks will keep personal information as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. Sevenoaks will minimize the possibility that inappropriate information is used to make a decision about the individual.
7. Safeguards: Sevenoaks will protect personal information with security safeguards appropriate to the sensitivity of the information.
8. Openness: Sevenoaks will be open about its policies and procedures with respect to the management of personal information. Sevenoaks will ensure that individuals are able to acquire information about Sevenoaks' policies and procedures without unreasonable effort. Sevenoaks will make this information available in a form that is generally understandable.
9. Individual Access: Upon a request in writing, Sevenoaks will inform the individual of the existence, use and disclosure of his or her personal information and the individual will be given access to that information, except where the law requires or permits Sevenoaks to deny access.
10. Questions and Concerns: An individual will be able to direct a challenge concerning compliance with the above principles to Sevenoaks.