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K2 Privacy Policy

K2 & Associates Investment Management Inc. (together, “K2”, “our”, “us” and “we”) was built as a tool for families to build wealth while protecting what matters to them. This principle includes protecting your privacy and safeguarding all the personal information in our care. Our privacy management practices, including K2’s Code of Ethics and Standards of Professional Conduct, are based on our core principles and comply with applicable data protection legislation and regulations.

This Privacy Policy describes the policies and procedures followed by K2 regarding the collection, use, and disclosure of your personal information when you visit our website or otherwise interact with K2. This policy applies to all our dealings with our prospective, current, and former investors. It also forms part of each product or service agreement with K2 and if there is a conflict between them, this notice governs. We may update this notice from time to time, but the most current version is always posted here on our website.

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 with us, 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 made anonymous and cannot be associated with an identifiable individual is not considered to be personal information.

Accountability

By opening an account with K2, you have disclosed to us personal identifiable information and financial data which we require to service your needs. Clients will disclose additional non-public, personal, and financial details throughout your ongoing relationship with us. K2 restricts access to personal information about you to those employees and other persons who need to know the information to enable the Fund to provide services to you. Each employee of K2 is responsible for ensuring the confidentiality of all personal information they may have access.

Your personal information is maintained on our networks or on the networks of our service providers accessible at 2 Bloor Street West, Suite 801, Toronto, Ontario, M4W 3E2. Your information may also be stored on a secure off-site storage facility. You may access your personal information to verify its accuracy, to withdraw your consent to any of the foregoing collections, uses and/or disclosures being made of your personal information, and may update your information by contacting us:

K2 & Associates Investment Management Inc.
Attention Designated Chief Privacy Officer
2 Bloor Street West, Suite 801
Toronto, Ontario, M4W 3E2.

Please note that if you withdraw your consent to the collection, use and disclosure of your personal information as outlined above, K2 may not be able to provide all the services you require. K2, at its sole discretion, shall have the right to require any Limited Partner to redeem some or all of the Class A Units owned by such Limited Partner by notice in writing to the Limited Partner given at least 30 days before the date of redemption or such lesser period as is acceptable to the General Partner.

No part of our website is targeted to attract anyone under 18.

Collection

  • K2 is committed to only collecting personal information that is required for specific purposes related to, conducting business, providing products and services, better understanding your needs, or where it is required or allowed by law.
  • K2 collects personal information and financial data directly from you and other sources in compliance with applicable laws.
  • The personal information we collect is limited to what is reasonably required to achieve the purposes for which it was collected and may include your name, contact information, information about how you use our products and services, and information about your preferences, demographics, and interests.
  • Internet e-mail and instant messages, along with their attachments, as well as phone calls to certain registered personnel, in each case which are received by or sent from K2 are subject to recording and review by supervisory personnel.
  • Electronic communications are retained by and may be produced to regulatory authorities or others with legal rights to the conversations, messages and/or their contents.
  • K2 may also collect information when you visit our websites or use our mobile applications such as your IP address, information about your operating system, the time and duration of your visit to our sites, Internet locations you came from, and the web pages you visit within our sites to track usage and improve our websites and improve your experience. 
  • K2 may also disclose such non-public information to regulatory bodies and/or as required by law.

Retention and Use

  • K2 only uses and retains your personal information for the purposes for which it is collected, for other purposes you consent to, or when it is required or allowed by law.
  • K2 may use your personal information for purposes such as:
  • To contact you and to respond to your requests, enquiries and other communications 
  • Delivering our products and services
  • Responding to inquiries or requests
  • Improving our services and your interactions with us
  • Managing our business, including statistical analysis
  • For employment recruitment purposes
  • To personalize your visit to the website and to assist you while you use the website
  • In connection with corporate sales or other restructuring events
  • Fulfilling our legal, regulatory, and security obligations
  • 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
  • K2 may analyze your information to better understand your needs and what products, services, and interactions may be of interest to you.
  • K2 aim to keep our records of your personal information as accurate and up to date as is necessary to fulfill the purposes for which it is collected, used, and retained.
  • K2 will keep your personal information only as long as is reasonably necessary to satisfy the purposes for which it was collected or as required or allowed by law.
  • Once no longer required, K2 will ensure your personal information is securely destroyed or made anonymous, in compliance with applicable laws. 

Sharing

  • K2 only shares your personal information for the purposes for which it’s collected, for other purposes you consent to, or when it is required or allowed by law. This may include sharing personal information with regulators, insurers, with our agents or representatives, or with our service providers.
  • Your personal information may be transferred, stored, accessed, or used in jurisdictions outside where it was collected, and where permitted by law. It would therefore be subject to the laws of those jurisdictions.
  • K2 is responsible for personal information in our possession, including data transferred to service providers who perform duties on our behalf such as fund administrators, custodians, financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of a fund, broker-dealers, accountants, auditors and lawyers, as necessary to administer our funds and enforce our rights.
  • K2 can specifically identify the following service providers:
  • Fund administrator is SGGG Fund Services Limited and its affiliates
  • Prime Brokers and custodians include BMO, CIBC, Scotia, TD, and Goldman Sachs
  • Auditor is Goodman & Associates LLP.
  • Legal Counsel is Aird & Berlis LLP.
  • When K2 shares personal information with our service providers, they must protect it and handle it in ways that are consistent with our privacy policies, our procedures, and applicable laws.
  • K2 may also share your information within the K2 affiliates in some cases, and where permitted by law
  • K2 does not share your personal information without your consent with any organization outside our group of companies for the purpose of that organization marketing its products or services to you.

Protection

  • K2 has implemented controls to protect your personal information and designated individuals who are responsible for monitoring our ongoing compliance with this Policy.
  • K2 will protect personal information with security safeguards that are appropriate to the sensitivity of the information to protect it from unauthorized access, release, modification or use.
  • K2 staff are required to complete annual privacy and security training.

Access and Permissions

  • K2 will make information about our privacy policies and practices available to you.
  • K2 will provide you, upon written request with reasonable access to your personal information including a description of its use or disclosure, as required or permitted by law.
  • Clients can also verify the accuracy and completeness of your information, and request that it be amended or deleted, if appropriate or permitted by law.
  • While we make every effort to ensure that all information, we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information. 
  • Clients may have additional privacy permissions and rights depending on your products or location.
  • Please contact us if you would like more information about any additional privacy permissions, or if you have questions, requests, concerns, or a complaint about your privacy 
  • More information is found in our Relationship Disclosure Information document.

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. 

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 the hard drive of your computer.
  • 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.

Revisions

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.