Personal Information Protection Policy

Our Privacy Commitment

Cougar Global Investments is committed to protecting the privacy and security of your personal information obtained by reason of your relationship with Cougar Global Investments. This policy explains the types of personal information we collect, how it is used, and the steps we take to ensure that the privacy of your personal information is appropriately protected.
Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and corresponding current provincial privacy acts.
This policy applies to individuals who we deal with in Canada including employees, shareholders, directors, customers, consumers and others.

Who is Cougar Global Investments?

For the purposes of this Privacy Policy, "Cougar Global" means Cougar Global Investments. Cougar Global Investments is a private investment counsel firm dealing with high net worth individuals.

What is Personal Information?

Personal information is information that refers to an individual specifically and includes information recorded in any form. Personal information includes such things as age, income, date of birth, unique identification numbers, medical and financial data.

What Personal Information does Cougar Global collect and how is it used?

Cougar Global collects two types of information: personal information and non-personal information. We will identify the purpose for which your personal information is collected, either before or at the time that we collect your personal information.

Listed here are some examples of the purposes for which we may collect, use or disclose your personal information:

1. For employees, we collect information such as employment and education history, medical/spousal information for benefit plans, social insurance numbers for government filings, photo ID for legal and filing purposes, banking information for payroll or any financial transactions, activity logs, performance evaluations and sick reports.
2. For shareholders, Directors & Officers, certain employees, consultants and other individuals as required, certain information is collected and disclosed in compliance with the information requirements of various securities laws.
3. For customers, information will include bank information, contact name, client name, address and contact information.

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Our Web Sites

Information Cougar Global Collects Automatically

Like many other Web sites, we automatically collect certain non-personal information regarding Web site users that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Web Site, the Internet address of the Web site from which you linked directly to the Web Site, the operating system you are using, the sections of the Web Site you visit, the Web Site pages read and images viewed, and the content you download from the Web Site. This non-personal information is used for Web Site and system administration purposes and to improve the Web Site.

Cookies

The Web Site uses "cookies", a technology that installs a small amount of information on a Web Site user's computer to permit the Web Site to recognize future visits using that computer. Cookies enhance the convenience and use of the Web Site. For example, the information provided through cookies may be used to recognize you as a previous user of the Web Site, to offer personalized Web page content and information for your use, to track your activity at the Web Site, to respond to your needs, and to otherwise facilitate your Web Site experience.

Links to Other Web Sites

Our Web Site may contain links to other Web sites or Internet resources. When you click on one of those links you are contacting another Web site or Internet resource. Cougar Global has no responsibility or liability for or control over those other Web sites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.

How Does Cougar Global Obtain Consent to Collect, Use and/or Disclose My Personal Information?

Generally, Cougar Global obtains your consent to collect, use or disclose personal information. The method of obtaining consent is appropriate to the type and sensitivity of personal information being collected, used or disclosed.

Does Cougar Global Limit the Collection of My Personal Information?

The following are some examples of why we collect your personal information;
To process any résumés submitted for any existing or potential positions within Cougar Global;
Cougar Global may disclose or collect your information as permitted or required to by law, for example:

1. To a government institution or other person or entity that has asserted its lawful authority to obtain the information;
   
2. Where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity;
   
3. To comply with a subpoena or warrant or an order made by a court, person or entity with jurisdiction to compel the production of information;
   
4. In the establishment, administration or termination of an employment relationship;
   
5. To meet ethical requirements or obligations imposed by regulatory and self-regulatory bodies;
   
6. If the information is publicly available;
   

Cougar Global retains your personal information only as long as it is required for our business relationship or as required by federal or provincial laws, subject to reasonable industry practices for records retention.

Does Cougar Global Keep My Personal Information Up To Date and Accurate?

Cougar Global makes reasonable efforts to keep your personal information up to date, accurate and relevant for its intended use, however we rely on you to update us with your information as it changes.

How Does Cougar Global Protect My Personal Information?

The security of your personal information is a high priority for Cougar Global. We maintain appropriate safeguards and security measures to protect your personal information, whether recorded on paper or captured electronically, against unauthorized access, disclosure, or misuse, including;

1. Physical security measures such as restricted access facilities;
   
2. Electronic security measures for computerized personal information such as password protection and encryption where appropriate;
   
3. Organizational processes such as limiting access to personal information to a selected group of individuals; and
   

Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party, we take reasonable precautions to prevent such occurrences.

Is Cougar Global Open About its Privacy Policy?

Cougar Global is committed to providing you with understandable and easily available information about our privacy policy and practices related to the management of your personal information. This policy, and any related information, is available at all times on our website, www.cougarglobal.com under "Privacy Policy" or upon request. To contact us, please refer to the "How Can I Contact Cougar Global" section below.

Will Cougar Global Respond to My Questions, Concerns and Complaints About Privacy?

 

Cougar Global will respond in a timely manner to your questions, concerns and complaints about the privacy of your personal information and our privacy policy and practices.

 

How Can I Contact Cougar Global?

Send us an email at: info@cougarglobal.com
Call us at: 416-368-5255
Toll free (in Canada): 1-800-378-3779
Write us at: Cougar Global Investments
357 Bay Street, Suite 1001
Toronto, ON
M5H 2T7

Will this Privacy Policy Change?

To accommodate changes in our service, the technology, and legal developments, this Policy may change over time. We may add, change, or remove portions of this Policy when we feel it is appropriate and such changes become effective upon posting.
This Policy was last updated on November 15, 2007.

Children's Privacy Protection

The Site does not target children or provide products or services for use by children. We do not knowingly collect Information from persons under 13 years of age. If you are under 13 years of age, you may review the Site only with involvement of a parent or guardian, and you may not use any portion of the Site that would require collection of personal information from you.