Cougar Global Investments Limited is committed to protecting the privacy of all client personal information collected and maintained in the course of business. Please review the Privacy Policy below, which describes how your personal information is treated.



We collect only the information we need for the purposes we have identified to you. Our files are kept for the purpose of providing portfolio management and investment services.

We will not sell your personal information.

Why we need the information
Generally, we need to collect personal information to:

  • understand your needs
  • determine your eligibility,
  • continue to offer you the products and services that we believe meet your changing needs to service such products and services,
  • meet regulatory or contractual requirements relating to the products and services provided to you.

We will make sure you understand why we need the information by using clear, understandable language when we identify the purpose.

We will obtain your permission
We collect, use or disclose your personal information with your permission. Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative. You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. Before we make information available to third parties, other than an agent or service provider who needs it, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we want to share with them and why.

We will limit how long we keep information
We will keep your personal information as long as it is necessary including updating the product or service or as required by law. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.


We are responsible for your information
We are responsible for all personal information in our possession, including information transferred to a third party service provider or agent, so that we can provide you with a product or service. All employees, agents and authorized service providers of Cougar Global are required to protect the confidentiality of your personal information.

How we protect information
Access to your personal information is restricted to those of Cougar Globals’ employees, agents and authorized service providers who need it to do their jobs. We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.

In the case of a privacy breach where personal client information has been disclosed to an unauthorized person, we will take the following course of action;

  • If the breach has been uncovered by a Cougar Global associate

    1. Immediately inform Management and Compliance personnel.
    2. Contact the unauthorized person and obtain confirmation that they have not used and destroyed the client related material.
    3. Compliance staff will investigate the incident, determine if the client is to be notified and come up with a remedial action plan.
    4. Once the action plan has been approved by the CCO, it will be communicated to all associates and be implemented immediately.
    5. The CCO and/or Compliance manager will report the incident in the quarterly compliance report.


  • If the breach has been uncovered by a person other than a Cougar Global associate

    1. Immediately inform Management and Compliance personnel.
    2. Request and obtain confirmation that the client related information has been used and destroyed.
    3. Compliance staff will investigate the incident, determine if the client is to be notified and come up with a remedial action plan.
    4. Once the action plan has been approved by the CCO, it will be communicated to all associates and be implemented immediately.
    5. The CCO and/or Compliance manager will report the incident in the quarterly compliance report



Your rights
You have the right to ask whether we hold any personal information about you and to see that information, as provided law.

You have the right to know:

  • how we collect your personal information,
  • how we are using it, and
  • to whom it may have been disclosed.

How to request an update or correction
If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it. If you show that your personal information is inaccurate or incomplete, we will make the necessary changes. If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.

How to register complaints
You may register a privacy-related complaint by contacting Cougar Global’s Chief Compliance Officer. We will explain the complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.

For more information
For more information, please contact Cougar Global’s Chief Compliance Officer.



Principle 1 – Accountability
Each employee is responsible for personal information under his or her control and Cougar Global shall designate an individual or individuals to be accountable for compliance with this Code.

Principle 2 – Identifying Purposes
The purpose for which personal information is collected shall be identified before or at the time the information is collected.

Principle 3 – Consent
The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.

Principle 4 – Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.

Principle 6 – Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.

Principle 7 – Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.

Principle 8 – Openness
Cougar Global will make readily available to its customers and employees specific information about our policies and procedures relating to the management of our personal information.

Principle 9 – Individual Access
Upon request an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 – Handling Customer Complaints and Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Chief Compliance Officer.


  • Collection and Use of Personal Information By Cougar Global
    When you open an account with Cougar Global, we will obtain personal information about you which will be kept on file in accordance with industry regulations. Only authorized individuals and entities have access to this information. The information that we collect allows us to identify you, to protect you against possible fraud, to assess your potential investment needs so that we may provide wealth management advice and services which are appropriate for you, and to comply with legal and regulatory requirements. We also may collect or receive information when you access and use the services of our website. We collect some of this information through cookies, web beacons, and other technologies. This information that we collect automatically may be combined with information that you provide us directly in order to personalize content. Depending on how you access and use our Services, we may receive, store and access log, device and location information.

    Pages on our website and content of our emails may contain “web beacons” (also known as internet tags, pixel tags and clear GIFs). The web beacons allow us to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed or the email was opened up, and the information in cookies set by us. We use log files to store the data that is collected through web beacons.


  • Social Insurance Number
    For individual clients, Cougar Global may collect, use and disclose your SIN for income tax reporting purposes.

  • Disclosure of Personal Information to External Sources
    Cougar Global may from time to time disclose your personal information to external sources such as reporting services, other financial institutions (such as our custodian) and other parties who provide services to Cougar Global.

  • Consent
    Your consent is required before we may provide your information to third parties. The consent that you provide to Cougar Global with regards to the collection, use and disclosure of your personal information may be cancelled by you at any time by providing written notice to Cougar Global. Cougar Global does not require your consent to the collection, use and disclosure of your personal information where such collection, use and disclosure is reasonably required in the normal course of providing service to your account, or to a law enforcement agency, securities regulatory authority of Self-Regulatory Organization, or to legal counsel for the purpose of obtaining advice. By opening an account at Cougar Global you are providing consent to Cougar Global to collect, use and disclose your personal information as set out in this agreement.

  • Retention of Personal Information
    Cougar Global has international affiliates and operates certain parts of its business in the United States of America. Accordingly, your information may be transferred to, maintained, and processed by Cougar Global or its affiliates or service providers in the United States and therefore, this information may be available to government authorities under lawful orders and laws applicable in the U.S. Please note that U.S. privacy laws, regulations, and standards may not be equivalent to the laws in your country of residence and such information may be subject to lawful access by U.S. courts, law enforcement, and governmental authorities. By using our services or by providing us with your information, you consent to this collection, transfer, storage, and processing of information to, in, and out of the United States.

    Cougar Global may retain your personal information on file after you cease to be a client of Cougar Global for as long as Cougar Global requires such information or as long as is demanded by our regulatory requirements.


  • Corrections to Personal Information
    You may review the information you have provided to Cougar Global and make corrections to it. We may request that you provide corrections in writing. You may address corrections, questions or privacy-related complaints to the Chief Compliance Officer, Cougar Global Investments Limited, Scotia Plaza, 40 King Street West Suite 2706, Toronto, ON M5H 3Y2