politique de confidentialité

1. Introduction

Bonnefield Financial Inc., (“Bonnefield”, “we”, “our”, “us”) is committed to ensuring that the collection, use, processing, and disclosure of your personal information is performed in compliance with applicable data protection laws. The purpose of this privacy policy (the “Policy”) is to explain how and for what purposes we collect, use, share or otherwise process your personal information and how we safeguard the confidentiality of your personal information, whenever you interact with Bonnefield, use our services or access Bonnefield’s website bonnefield.com (the “website”), including when you create and access your online Bonnefield investor portal or tenant portal account (“Account”).

By using our website or services, you signify your agreement with the Policy. Use of our website is also subject to the Conditions d'utilisation.

2. What is “Personal Information”?

Personal information is any information that identifies you as an individual and includes your name, address, age, gender, marital status, social insurance number, banking information and financial information, as well as information you share with us concerning your investments. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or anonymized and cannot be used alone or in combination with other available information to identify you as an individual is not considered to be personal information.

3. What Personal Information We collect

Bonnefield may collect, use and store the following categories of information in connection with informing you about our services and providing you with our services.

• Identity information, such as your name, date of birth, marital status, Social Insurance Number (SIN), information requested pursuant to Anti-Money-Laundering (AML) legislation, and other data on government-issued identification documents;
• Contact information, such as your email address, mailing address, and telephone number;
• Financial information, such as your bank account details, and information about your income, account balances, net worth, credit history, investment history, tax information, trade or banking references, credit scores, and investor risk profile;
• Profile information, such as your username and password information that you use to create and access your Account on our website, preferences, and feedback;
• Online information, such as information from your online activity; for example, information about your web browser, time zone, Internet Protocol (IP) address, mobile network information, website use, links clicked, time spent on our website, pages viewed, and conversion information.

4. How we Collect Personal Information

Personal information is collected from the following sources, and is for the most part collected directly from you:

Information Collected From You

Bonnefield obtains most of the information it requires directly from you when you subscribe for an investment in a Bonnefield investment fund (“Bonnefield Fund(s)”) or otherwise interact with us during meetings or through email correspondence or telephone conversations. For example, Bonnefield collects your personal information when you fill out subscription agreements, documents relating to a transaction with us or our affiliates, or when you submit other forms to us.

Information Collected From Third Parties

Bonnefield may receive additional information, including creditworthiness or credit history, from other financial institutions or service providers whom you may have authorized to provide us with such information and/or credit bureaus, verification services or references, or public sources.

Information Collected Automatically

Les cookies sont de petits fichiers texte que notre site Internet demande à placer sur le disque dur de votre ordinateur. Si votre navigateur est configuré pour accepter les cookies, votre navigateur ajoute le texte dans un petit fichier. Nous utilisons la technologie des cookies lorsque vous demandez quelque chose sur notre site Web, comme des informations sur nos produits. Nous n'utilisons pas de cookies pour lire d'autres informations sur le disque dur de votre ordinateur. La plupart des navigateurs sont initialement configurés pour accepter les cookies. Si vous préférez, vous pouvez configurer votre navigateur pour refuser les cookies, ou pour vous avertir avant qu'un cookie ne soit déposé sur votre disque dur. Si vous choisissez de ne pas accepter les cookies, vous devrez peut-être saisir manuellement votre identifiant et votre mot de passe ou saisir manuellement des informations telles que votre nom, votre adresse e-mail et d'autres informations facultatives chaque fois que vous souhaitez recevoir des informations de notre site Web.

5. How do we Use Personal Information

Bonnefield uses your personal information to provide you with our services, as described under What Personal Information We Collect above.  For example, this includes assessing your eligibility to invest with us in accordance with securities legislation, and establishing and administering your investment in a Bonnefield Fund. We may also use your personal information for the following purposes, or otherwise with your consent or as permitted or required by law:

• To verify your identity, as required by statutory and regulatory requirements when you pursue an investment in a Bonnefield Fund;
• To provide or deliver our products and services, including to establish and administer your investments, understand your investment needs and objectives, ensure our records are accurate, determine your eligibility for products and services (i.e. accredited investor status), execute your transactions, provide you with account statements, reports, tax receipts, transaction confirmations, and to maintain, store, record and determine your investment holdings and transaction records;
• To communicate with you, including to provide you with the material that you have requested and to provide you with updates to that material or other material that we believe may be of interest to you (e.g., through our newsletter). You may unsubscribe from receiving communications such as our newsletter by following the instructions provided in said communications.
• To manage our business operations, including managing and facilitating the use of our website and your Account (including through cookies and similar technology), ensuring the security of our website and your Account, and detecting fraudulent activity.
• To elaborate and improve our product offerings and our services, including to respond to any of your inquiries or feedback, and to provide you with customer service.
• To comply with legal requirements, including but not limited to record-keeping, reporting and tax obligations.

Note that Bonnefield does not sell your personal information to third parties.

6. With Whom We Share Personal Information

Bonnefield may, in the circumstances described below and from time to time, disclose your personal information to regulatory agencies, companies affiliated with Bonnefield, and other third parties to perform services on behalf of Bonnefield for the purposes explained in the How Do We Use Personal Information section of this Policy and as permitted or required by law:

• Among Bonnefield’s entities. Bonnefield and our related entities, for example, Bonnefield Funds and other Bonnefield affiliates, may share personal information among themselves and use it for the purposes described in this Policy. This allows each entity to comply with applicable laws, regulations and requirements, and ensures that your information is consistent, accurate and up to date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with Bonnefield through easier access to your information within the group.
• Services providers. Bonnefield transfers personal information to third parties that provide us with financial, accounting, legal, credit review, transfer agency, banking, securities compliance or tax services, as well as service providers we hire to do our data processing or prepare your account statements.
• Business transactions. To the extent permitted by law, in the event of a sale, amalgamation, re‐organization, transfer or financing of parts of some or all of our business, your personal information may be disclosed to an acquiring organization, either as part of due diligence and/or on completion of the transaction.
• To comply with our legal obligations. From time to time, Bonnefield may be compelled to disclose personal information in response to a law, tax legislation, land ownership rules, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry. Such requests will generally be submitted to Bonnefield for purposes of surveillance of trading-related activity, for investigation purposes relating to securities compliance reviews and other regulatory audits, to update regulatory databases, and to enforce disciplinary proceedings. We may also share personal information with law enforcement agencies where we are made aware of any activity that we believe to be unlawful, or in the case of an emergency that threatens the life, health or safety of a person.

7. How We Protect Personal Information

We protect your personal information with appropriate safeguards and security measures. We have security standards to protect our systems and personal information against unauthorized access, use, and disclosure, and, to that end, restrict access to personal information about clients to those employees and other persons who need to know the information to enable us to provide services to clients. All of our employees, agents and suppliers, as part of their agreements with Bonnefield, are bound to maintain client confidentiality and may not use the information for any unauthorized purpose. We monitor and review our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate. 

8. Links to Third Party Websites

Our website may contain links to other websites. We cannot be responsible for the privacy practices or the content of these other websites.

9. Your Rights

Withdrawing your consent.  You may withdraw your consent to our collection, use and sharing of personal information at any time, subject to contractual and legal restrictions and reasonable notice.  Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain of our services.

Access and correction. You are entitled to access your personal information and request the rectification of information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws. Please be advised that in order for you to modify, access or review your personal information, we may ask you to provide us with sufficient identification.

To exercise any of your individual privacy rights, contact us using the information provided in the Contactez-nous section below.

10. Minors

We do not knowingly solicit or collect personal information from children under the age of 14 and you may not pursue an investment in a Bonnefield Fund if you are under the age of majority. If we learn that a child under the age of 14 has provided us with personal information without the verifiable consent of a parent or legal guardian, we will take reasonable steps to delete that information.

11. Retention of Personal Information

Bonnefield will only retain personal information as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise authorized or required by law. For example, Bonnefield may be subject to legislative requirements with respect to information retention periods. When your personal information is no longer needed for the purposes set explained in this Policy or for Bonnefield’s compliance with legal requirements, we have procedures to destroy or convert it to an anonymized form.

12. Cross-Border Transfers of Personal Information

Some of our external third-party service providers have data-centers or operations outside of Canada and outside of Quebec, including in the United States, the United Kingdom, and the European Union, and their processing of your personal information will therefore involve a transfer of information outside of Canada and outside of Quebec. Organizations based outside of Canada may not be subject to privacy laws that provide you with the same rights and protections as in Canada. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

13. Changes to this Policy

We may review and update this Policy as required to keep current with rules and regulations, new technologies and standards.  Our Policy may therefore change from time to time.  We will post any changes on our website and, if the changes are significant, we will provide a more prominent notice where required by law. This Policy is effective as of the Effective Date which appears at the top of this page.

14. Contact Us

If you have any questions, concerns or complaints about your privacy and the confidentiality of your personal information, or if you would like to exercise any of your privacy rights, you may contact the Manager’s Chief Compliance Officer at compliance@bonnefield.com.