Privacy Policy

At Hamilton Capital Partners Inc. (“HCP”) we strive to protect your privacy and the confidentiality of personal information that you provide to us. The following is a description of our privacy policy regarding the collection, use and disclosure of personal information that you provide to us or that is shared with us from other sources:

Personal Information

Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and home telephone number. Personal information does not include your name, business address and business contact information, such as your business title, email address or phone number, which you provide to us for business purposes.

Accountability

HCP acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all HCP employees of the need to use the utmost discretion when dealing with client information.

Purpose

HCP collects information required to complete necessary documentation, determine eligibility and/or in order to allow us to meet regulatory or contractual requirements relating to the products and services provided to you. HCP does not sell your personal information.

Consent

HCP will obtain your consent prior to collecting, using or disclosing personal information for any purpose, except where otherwise permitted or required by law. Consent may be expressed in writing, orally or may be implied directly by you or your authorized representative.

Collection

Personal information is received by us from you or from your representative with your consent. Other sources from which we may receive your information with your consent include, but are not limited to, financial institutions. We may also collect personal information through our website.

Use, Disclosure and Retention

HCP will only use personal information collected from you for the identified purposes and it will be retained for as long as is necessary to fulfill the service or as required by law. However, we may share your information with others outside HCP in limited circumstances including third party service providers (such as data processing and the preparation and mailing of client statements). In these circumstances, third party service providers are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. Third party service providers are not permitted to disclose this information to others.

HCP has procedures dealing with the destruction or deletion of personal information no longer required for the purposes for which it was collected.

Safeguards

HCP understands the importance of treating personal information as private, confidential information and we strive to ensure that your personal information, regardless of format, is protected and kept secure at all times. For example, HCP’s computer network, employee computers, laptops, and phone message centres are all password protected. In addition, filling cabinet units and storage rooms containing personal information are locked and can only be accessed by authorized individuals.

Our safeguards are supported by our internal code of ethics that requires all HCP employees to maintain client confidentiality. Each year, our employees receive a current copy of our code of ethics and are required to certify in writing that they will comply with it.

Access

By providing any personal information to HCP, whether through the website or otherwise, you consent to the collection, use or disclosure of that information in accordance with this privacy policy. You have the right to verify and amend your personal information collected by us. You are also free at all times to withdraw your consent to such collection, use and disclosure of your personal information. You have the right to access your personal information; however, in certain circumstances, we may not be able to provide you with access to specific pieces of information. If we deny your request for access, we will provide reasons for doing so. For example, (i) information containing references to other persons; (ii) information containing proprietary information confidential to HCP or its affiliates; (iii) information that has been destroyed or may be too costly to retrieve.

If you wish to access, verify and/or amend your personal information or make a complaint under this Policy, please send us a written notice, at the address below:

Privacy Officer
c/o Hamilton Capital Partners Inc.
55 York Street, Suite 1202
Toronto, ON
M5J 1R7

Our Website

Personal information collected by HCP may be used to determine how many people visit the website and which sections of the website are visited most frequently. When you visit the website, move from page to page, or download content, the following information may be recorded: the address you are connecting from; which pages are visited; and what content is downloaded.

Certain HCP employees will be provided with information about the website visitor in order to serve that visitor’s needs and provide the visitor with information regarding specific products.

Information obtained by registering on this website or attending an HCP event will reside in an internal database at HCP. If you wish to have your information removed from the HCP database at any time, please email your request to info@hamilton-capital.com.

We reserve the right to change or remove this privacy 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.

Are you an accredited investor?

Products offered by Hamilton Capital Partners Inc. have a minimum subscription amount of $150,000, unless you meet the definition of an "accredited investor" under National Instrument 45-106 Prospectus and Registration Exemptions.

If you meet the definition of an "accredited investor", you may invest a minimum of $25,000. Please consult the offering documents to determine your qualification status. Investment Advisors should consult their company's internal policies.

The Subscriber must be (and will be at the time the Subscription is executed) an accredited investor under National Instrument 45-106 Prospectus and Registration Exemptions ("NI 45-106")

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