Privacy Policy

CHARLES BRIDGEFORD ASSET MANAGEMENT INC.

PRIVACY POLICY

Charles Bridgeford Asset Management Inc. (“Charles Bridgeford” or “we“) recognizes that all Personal Information is private and confidential.

Whether you are a prospective investor looking to invest in one of Charles Bridgeford’s investment vehicles, or a farmland operator wishing to partner with Charles Bridgeford to become a tenant of farmland owned by Charles Bridgeford, we are committed to protecting and respecting the privacy and confidentiality of your Personal Information.

It is the intention of Charles Bridgeford, by way of this Privacy Policy (the “Policy“), to comply with applicable privacy legislation. This Policy briefly describes why and how we collect, hold, use and, if necessary, disclose your Personal Information. It also summarizes your right to have access to the information so as to correct same if necessary. We reserve the right to change or remove this Policy at our discretion. If we decide to change it, we will post those changes here. We encourage you to visit this area frequently to stay informed.

Charles Bridgeford will only use your Personal Information for the purposes identified in this Policy or as set out in any other agreement between Charles Bridgeford and yourself. If your Personal Information is required for any additional use, Charles Bridgeford will take necessary steps in order to seek your additional consent which, in such cases, may be expressed in writing, orally or may be implied directly by yourself or your authorized representative. You may withdraw your consent for the use of your Personal Information by contacting Charles Bridgeford at any time subject to legal or contractual restrictions and reasonable notice. Your decision to withdraw your consent to the use of Personal Information may also limit your eligibility for a lease or an investment in Charles Bridgeford’s investment vehicles.

What is Personal Information and why do we obtain it?

Personal Information refers to information that identifies you and it includes personal financial information. It may include information such as your age, marital status, employment history, social insurance number, financial history, credit history, home address, personal e-mail address and home telephone number.

For investors, we generally collect your Personal Information in order to assess your eligibility and suitability for an investment in Charles Bridgeford’s investment vehicles and to administer any such investments made. In addition, your signature, financial history, current financial position, social insurance number, age and other similar Personal Information allow us to:

establish your identity;
fulfill our obligations with respect to money laundering and anti-terrorist financing laws; and
protect you and us from error and fraud.

For tenants, Charles Bridgeford collects Personal Information from farmland operators wishing to partner with Charles Bridgeford to become tenants of farmland owned by Charles Bridgeford. Charles Bridgeford generally collects Personal Information to:

determine your suitability for a lease, including assessing the suitability of potential tenants both from an agrological and financial perspective (including creditworthiness); and
administer your lease and your obligations thereunder, including ongoing monitoring of farming activities on behalf of our investors.

How will Personal Information be collected?

We may collect Personal Information about you from the following sources:

In many cases, Personal Information will be collected directly from you or, with your consent, from your representative.
We may collect your Personal Information from third parties such as your financial advisor/dealer, affiliates of Charles Bridgeford and other financial institutions, including, with your consent, credit bureaus, credit reporting agencies and background check providers.
We may sometimes collection Personal Information from third party service providers: We may, with your consent, collect information about you from third party service providers to confirm and verify your identity and other information that you provide in connection with your investment in a Charles Bridgeford investment vehicle.

How will it be stored?

Your Personal Information may be kept in electronic or paper format at the offices of Charles Bridgeford, its affiliates or its third-party service providers. Your information may also be kept in secure off-site storage facilities. Charles Bridgeford will only retain your Personal Information for as long as needed in order to satisfy the stated purposes identified when the information was collected and to comply with applicable laws. In the event it is determined that an individual’s Personal Information is no longer required, Charles Bridgeford will take the necessary measures to securely destroy, dispose, or erase the information in a manner that will ensure that the information cannot be found or used by an unauthorized party.

The Personal Information that we collect from you may be transferred to, and stored at, a destination outside your home country, where it will be subject to the laws of that destination country. By submitting your Personal Information, you agree to this transfer, storing or processing. We will take all reasonable steps necessary to ensure that your Personal Information is treated securely and in accordance with this Policy.

How will Personal Information be used?

We may generally use your Personal Information for the purposes, noted above, for which it was collected, including the following specific purposes:

to identify you;
to ensure our records are accurate;
to maintain, store, record and determine your investments and transaction records;
to verify previously given information when necessary;
to provide you and your representatives with financial statements, tax receipts or other information;
in the case of prospective tenants, to determine your creditworthiness and your eligibility or appropriateness for a lease;
in the case of tenants, to monitor your farming practices;
to meet legal and regulatory requirements, including, in the case of investors, investment eligibility and suitability obligations, as well as the collection of information under money laundering and anti-terrorist financing laws
to develop and offer additional products and services that we feel may be of interest to you; and
to communicate with you regarding additional products, services and opportunities that we feel may be of interest to you.

If you do not wish to receive communications regarding additional products, services or opportunities, feel free to let us know by contacting our Privacy Office at the address set out below.

When will Personal Information be disclosed?

Charles Bridgeford is not in the business of selling or distributing its investors’ Personal Information to others, and it is Charles Bridgeford’s policy not to sell any information collected. Client confidentiality and privacy remains one of our fundamental principles.

Your Personal Information will only be disclosed:

(i)             within the Charles Bridgeford group in connection with Charles Bridgeford’s use of your Personal Information as described above;
(ii)           as may be necessary to meet Charles Bridgeford’s regulatory and legal obligations;
(iii)          to credit bureaus, credit reporting agencies, and background check providers to determine your creditworthiness and certain background information;

(iv)          to third parties at your request, including your financial adviser;
(v)           to Charles Bridgeford’s third party service providers who assist in the performance of services to you; and
(vi)          as may otherwise be permitted by law.

We may share your information with others outside the Charles Bridgeford group in limited circumstances, including:

as we hire third party service providers to perform services on your behalf, we may provide them with a limited amount of information in order that they may provide services, including, but not limited to, data processing, document storage, and imaging. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide and are not permitted to disclose information to others;
we may also have to contact other financial advisors or institutions, dealers or brokers or mutual fund companies in order to gather necessary information;
we may be compelled to disclose Personal Information in response to regulation, court order, subpoena, search warrant or other legally valid request or enquiry, including the disclosure of such information to foreign, Canadian, provincial or municipal governments, governmental agencies or organizations (for example, CRA or OSFI); and
we may disclose information to our accountants, auditors and lawyers in connection with the enforcement or protection of our legal rights, each of which is bound by its own confidentiality obligations with respect to Personal Information.

In addition to the foregoing, your information may be provided to a successor of Charles Bridgeford or an acquiror of Charles Bridgeford or a portion of Charles Bridgeford’s business.

Safeguards

Charles Bridgeford understands the importance of protecting Personal Information and, therefore, implements a number of safeguards against unauthorized access or improper disclosure, including physical, technical and organizational measures.

Charles Bridgeford’s employees and advisers have access to your Personal Information only to the extent required to enable them to perform their duties in servicing you, and are subject to strict confidentiality and information protection obligations.

Access to Personal Information

Except in limited circumstances prescribed by law, you are entitled to access, through a written request, the Personal Information contained in your record. You may verify this Personal Information and request that any inaccurate information be corrected. When requested and supported by sufficient identity information, Charles Bridgeford will provide you with your Personal Information as maintained in your files. We recognize your right to your own information, how it is used and to whom it is disclosed. If an error or discrepancy is found in your Personal Information, we will act efficiently to correct the mistake.

Responsibility for Compliance with our Privacy Policy

Our Chief Privacy Officer is responsible for overseeing Charles Bridgeford’s compliance with this Policy and may be contacted at the following address:

Chief Privacy Officer
Charles Bridgeford Asset Management Inc.
Suite 1000
2042 Mills Road West
Sidney, British Columbia
V8L 5X4
(778) 351-0869 ext:19
E-mail: cara@charlesbridgeford.com

Questions or Concerns about our Privacy Practices

Please address any questions or concerns about our compliance with this Policy or our privacy practices generally to the Chief Privacy Officer.

Complaints and Recourse

Charles Bridgeford will deal with any complaints or conflicts arising in regards to the collection, use and disclosure of Personal Information. In order to adequately address the complaint, all details will be recorded and a file will be created.

Should you have a complaint or enquiry, please contact our Chief Privacy Officer.

If you remain unsatisfied after discussing the matter with our Chief Privacy Officer, you may wish to contact the privacy Commission appropriate to your province of residence.

Residents of Alberta may contact the Office of the Information and Privacy Commissioner for Alberta at www.oipc.ab.ca or at the following address:

#410, 9925 – 109 Street NW
Edmonton, Alberta
T5K 2J8
Telephone: (780) 422-6860
Toll-Free: 1-888-878-4044
Fax: (780) 422-5682
E-mail: generalinfo@oipc.ab.ca

Residents of British Columbia may contact the Office of the Information and Privacy Commissioner for British Columbia at www.oipc.bc.ca or at the following address:

PO Box 9038 Stn. Prov. Govt.
Victoria, British Columbia
V8W 9A4
Telephone: (250) 387-5629
Toll-Free: 1-800-663-7867
Fax: (250) 387-1696
E-mail: info@oipc.bc.ca

Residents of Québec may contact the Commission d’accès à l’information du Québec at www.cai.gouv.qc.ca or at the following address:

575 Saint-Amable Street, Suite 1.10

Québec, Québec

G1R 4Y8

Telephone: (418) 528-7741

Fax: (418) 529-3102

Email: cai.communications@cai.gouv.qc.ca

Residents of the other provinces may contact the Privacy Commissioner at www.privcom.gc.ca or at the following address:

30 Victoria Street
Gatineau, Quebec
K1A 1H3
Telephone: (819) 994-5444
Toll-free: 1-800-282-1376
Fax: (819) 994-5424
E-mail: info@privcom.gc.ca