“Personal information” is any information that identifies you. It includes such information as your date of birth, marital status, home address, home telephone number, personal e-mail address, social insurance number and history of employment. Personal information does not generally include your name, title, business address or business e-mail address.

Your personal information is important as it allows us to:

• establish your identity,
• verify previously provided information,
• ensure the accuracy of our records,
• understand your needs,
• determine your eligibility to invest in our products or receive our services,
• execute your transactions,
• maintain your account holdings and transaction records,
• establish and administer your account,
• provide you with quality customer service and support,
• provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other documentation and information that may be required or requested to service your account,
• provide you and your investment advisor with account information and account statements,
• protect against fraud and error, and
• meet legal and regulatory requirements.

We may collect your personal information in various ways, including through the completion of an application form, when opening an account, through subscription agreements or other forms that are submitted to us, or through other interactions with either you or your investment advisor. No matter how we collect your personal information, we strive to ensure its accuracy and completeness. To this end, we count on you to notify us as soon as possible of any changes to your personal information so that we may update our records accordingly.

Personal information will only be collected, used or disclosed with your permission. Your permission may be expressly provided to us in writing, or it may be implied. Permission may be given to us verbally, electronically or through your investment advisor. You may withdraw all or part of your consent for us to collect, use or disclose your personal information within certain legal restrictions. If you withdraw consent, however, we may be limited in the services or products that we can provide to you.

We do not disclose any non-public personal information to any third party except as outlined in this Privacy Policy. Your personal information will not be sold to a third party.

Personal information may be disclosed to our service providers in limited circumstances solely for the purpose of performing contracted functions, such as data processing, document storage or mailing information or documentation to you. In such cases, we ensure that our service providers agree not to use or disclose such information except as directed by us and then solely for the purposes defined in our Privacy Policy and/or applicable legislation.

In some instances, we may engage service providers located outside of Canada and, where we do, personal information may be disclosed in accordance with the laws of the jurisdiction in which the service provider is located, including to the government in that jurisdiction and its agencies.

We may also share your personal information with your investment advisor and the dealer with whom he or she is registered. From time to time, we may also need to contact other financial institutions or dealers in order to ensure that we have the accurate and complete information necessary to service your needs.

Personal information may also be provided to third parties in response to a legal or regulatory requirement.

Your personal information may also be shared with our associated companies, solely for the purpose of product development and marketing on our behalf.

Your personal information may be kept in electronic or paper format at our offices or at the offices of our third-party service providers such as RBC Investor & Treasury Services. Additionally, your personal information may be kept at a secure, off-site storage facility.

We have implemented various policies, procedures, safeguards and other physical and electronic controls to ensure the protection of your personal information against loss, theft or misuse. Access to your personal information is restricted to only those employees, agents and service providers who require such information in order to service your needs, or as may be required by law. All of our employees, agents and suppliers are bound to maintain client confidentiality and may not use the information for any unauthorized purpose. Our controls are reviewed and updated from time to time to address changing requirements and advances in technology. Your personal information will only be retained for as long as necessary to fulfill the service, or as required by applicable legislation.

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.

In the event of a data breach that exposed your personal information, there are serious risks that can arise, including with respect to identity theft, theft and fraud.

Upon reasonable prior request, we will provide you with access to your personal information. We may also provide you with a list of third parties to whom your personal information has been provided. If you wish to change or update your personal information, you may request to do so at any time by contacting us using the contact information set forth below. In certain circumstances, we may not be able to provide you with access to specific pieces of information. This may include: i) information containing references to other persons; ii) information containing proprietary information which is confidential to Starlight Investments Capital LP or its affiliates; iii) information that has already been destroyed or that may be too costly to retrieve; or iv) information that we are otherwise legally prohibited from disclosing to you.

When you visit our website, we may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. This information may be used, for example, to alert you to software compatibility issues, improve our web design and functionality, or to provide you with customized service.

We use cookies and other similar technologies to support the operation of our website. Cookies are small amounts of data that a website sends to a web browser on a visitor’s computer. Our cookies help us to collect information about visitors to our website, including the date and time of visits, pages viewed, or amount of time spent on our website. Cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout or remembering your language preference.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on our website, or if you delete cookies, you may experience some inconvenience in your use of our website. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device or your online preferences.

Privacy-related questions, concerns or complaints may be registered by contacting our Privacy Officer:

E-mail: privacy@starlightcapital.com

Phone: 1-833-752-4683

Regular mail addressed as follows:
Starlight Investments Capital LP
3280 Bloor Street West, Suite 1400
Toronto, Ontario, Canada
M8X 2X3

When contacting us regarding a privacy-related question, concern or complaint, we will explain to you our review process and we will take all appropriate steps to address the matter. If after contacting us, you feel that your question, concern or complaint has not been adequately addressed, we can direct you to the appropriate federal or provincial privacy commissioner for further information.

We will occasionally update this Privacy Policy to reflect your feedback as well as to address changes in company policy or privacy legislation. It is important for you to periodically review this Privacy Policy by visiting our website at: www.starlightcapital.com. If you access our website after we have posted any changes to this Privacy Policy, you are agreeing to accept such changes.

Last updated: April 24th 2020.