Privacy Policy

Website

You are welcome to visit Bonnefield’s website while remaining anonymous and not revealing any personally identifying information. Providing us with your personal information is strictly voluntary. The following explains our policy with respect to any personal information you may provide to us when you visit our website. If you do not agree with the terms of our privacy policy please do not use this website.

How Personal Information is Collected and Used

Cookies are small text files that our website asks to place on your computer’s hard drive. If your browser is set to accept cookies, then your browser adds the text in a small file. We use cookie technology when you request something from our website, such as information about our products. We do not use cookies to read any other information on your computer’s hard drive. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to refuse cookies, or to warn you before a cookie is placed on your hard drive. If you choose not to accept cookies, you may have to manually input your user ID and password or manually input information such as your name, email address and other optional information each time you want to receive information from our website.

We collect personal information in order to provide you with information regarding our services. If you chose to provide personal information to Bonnefield, we will only use the information 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. If you do not want us to use this information as a basis for further contact with you, please advise and we will respect your wishes.

Bonnefield will not sell this personal information to other companies.

Links to Other Websites

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

Accuracy, Access, and Opting Out

We will use all reasonable efforts to protect the quality and integrity of your personal information. If you wish to find out the details of any personal information we hold about you or if you wish to correct or update the personal information or have us delete that personal information, please contact us at info@bonnefield.com. If you have any concerns with our privacy policy or if you have any concerns with our use of your personal information, please contact us at info@bonnefield.com.

By using this site, you signify your agreement with the Bonnefield Privacy Policy. Bonnefield reserves the right to modify this Privacy Policy at any time. Use of the Bonnefield website is subject to the Terms of Use.

Investors

1. Collection and Use of Personal Information

We collect, maintain and use the personal information of stakeholders of securities of Bonnefield’s investments funds and we recognize how important privacy is for stakeholders. Set forth below are our policies with respect to the personal information we collect. 

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 and other ID information, banking information and financial information. It may also include any communication you have had with us concerning your investments.

3. Why do we Collect Personal Information?

We collect your personal information for the following reasons:

• to verify your identity and protect against fraud;
• to fully understand your investment needs and objectives;
• to facilitate, maintain and administer your investment;
• to provide you with, and manage any other services you have requested; and
• to comply with legal and regulatory requirements.

4. How do we Collect Personal Information?

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

• subscription agreements, documents relating to the transaction, or other forms that are submitted to us;
• transactions with us and our affiliates; and
• meetings, email correspondence and telephone conversations.

5. Use of Personal Information:

Unless you otherwise advise us in writing, by providing us with your personal information and signing a subscription agreement for Bonnefield’s investment funds, you have consented to us collecting, using and disclosing your personal information, or that of your advisors and related parties, as provided therein.

Bonnefield Financial Inc. does not sell your personal information to third parties.

We may disclose your personal information to third parties and to our affiliates in connection with the services we provide, including to:

• service providers who provide financial, accounting, legal, or tax preparation services;
• service providers we hire to do our data processing or prepare your account statements; and
• taxation and regulatory authorities and agencies, where required or permitted by law.

Such disclosure to third parties will occur:

• where we have your consent pursuant to this Subscription Agreement;
• where the third parties are agents or suppliers who assist us in serving you; and/or
• where we are required or permitted to do so by law, including to taxation authorities and securities regulatory authorities.

6. How We Handle and Protect Client Information

We protect your personal information with appropriate safeguards and security measures. We have security standards to protect our systems and client information against unauthorized access and use 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 Financial Inc., 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. 

When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required – otherwise we will seek your consent prior to disclosing any information. 

Subscriber personal information is maintained on our networks or on the networks of our service providers. Personal information may also be stored on a secure off-site storage facility. A subscriber may access their personal information to verily its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting the Manager. Please note that a subscriber’s ability to participate in the Fund may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above.

We only collect personal information that is necessary. We make every reasonable effort to keep subscriber information accurate and up-to-date. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections. For information that remains in dispute, we will note your opinion in the file.

We retain subscriber information for only as long as we require it for the reasons it was collected or as required by law. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form. 

Upon request and unless prohibited by law, regulation or self-regulation, you will be given access to your personal information, be informed of its existence, use, disclosure and we will also make available to you the policies and procedures that apply to the management of your personal information.

7. Questions, Concerns and Complaints

If you have any questions, concerns or complaints about your privacy and the confidentiality of your personal information, or if you would like access to your personal information that we have on file, you may contact the Manager’s Chief Compliance officer Jeremy Rutke at jrutke@bonnefield.com.