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Sarona

Privacy Policy

Sarona Asset Management ("Sarona") respects your privacy and is committed to protecting it. Sarona provides this Privacy Statement to inform you of its privacy policy ("Privacy Policy") and practices and of the choices you can make about the way your information is collected online and how that information is used. This notice is readily available at the bottom of every Sarona web page.

Please note that the practices of Sarona, with respect to data collected and used by Sarona in connection with this website ("Site") and Sarona products and services available via the Site, are governed by this online Privacy Policy as amended from time to time, and not the privacy policy in effect at the time the data was collected. Please regularly review our Privacy Policy. If you have objections to the Privacy Policy, you should immediately discontinue use of the Site and the Products and Services enabled by the Site. To the extent that any terms of the Privacy Policy conflict with the terms of an existing written (including electronic) agreement between you and Sarona regarding the use of specific areas of the Site or specific Products and Services (including Product- and Service-specific licenses, terms of use, or privacy disclosures) (collectively, "Product Agreements"), the terms of the Product Agreements shall govern.

The Site and the Products and Services are intended for adult audiences, and Sarona does not knowingly collect any personal information from anyone under 13 years of age.

Entities collecting personal information

Personal information on this Site is collected on behalf of Sarona.

The Site contains links to other sites at which personal information is collected. In such instances, unless expressly provided to the contrary, the collection and use of your personal information will be governed by the privacy policy applicable to that site. That privacy policy should identify the entity that is collecting your personal information.

Personal information submitted through this Site or in connection with the Products and Services that is not Registration Information is not accessible online. To access and/or correct such information and privacy preferences (such as whether you wish to receive promotional communications), you may write Sarona at:

Sarona Asset Management
1B-110 Frobisher Drive
Waterloo, ON N2V 2G7
Canada

All users may also email: [email protected]

Collection of personal information

As a visitor to this Site, you can engage in many activities without providing any personal information. In connection with other activities, such as utilizing online or hosted Products and Services, Sarona may ask you to provide certain information about yourself by filling out and submitting a form. It is optional for you to engage in these activities. If you elect to engage in these activities, however, Sarona may ask that you provide certain personal information (as well as certain non-personal information that may be tied to personal information), such as your first and last name, phone number, and e-mail address.

When you use the Site and the Products and Services, Sarona may also collect certain information about your computer to facilitate, evaluate and verify your use of the Site and the Products and Services. For example, we may log environmental variables, such as browser type, operating system, CPU speed, referring or exit webpages, click patterns, Session ID (a unique identifier assigned to the browser in connection to the Site), and the Internet Protocol (IP) address of your computer. Sarona also uses such information to measure traffic patterns on the Site and usage of the Products and Services. We do not match such information with personal information held about you by Sarona unless we have your consent, except as otherwise described in this Privacy Policy.

By using this Site and the Products and Services, you agree and acknowledge that personal information collected through the Site or in connection with the Products and Services may be transferred across national boundaries and stored and processed in any of the countries around the world in which Sarona maintains offices, including Canada. You also acknowledge that in certain countries or with respect to certain activities, the collection, transfer, storage, and processing of your information may be undertaken by trusted third party vendors or agents of Sarona such as web hosting providers, mail and email service providers, communication services, and web analytic providers, to help facilitate Sarona in providing certain functions. Another instance where this could occur is in conjunction with framed pages in which the URL for the pages is not visible, and the pages are hosted for Sarona by such third party vendors. For example, on the sign up pages for some newsletters, the pages may be hosted by a third party vendor, but appear to be Sarona.com pages and they are therefore governed by this Privacy Policy. Personal information may be shared with these providers to fulfill the service. Such third parties are bound by contract with Sarona not to use your personal information for their own purposes or provide it to any third parties.

Sarona has established relationships with various providers of services and products who are not part of Sarona and who may not themselves be providing products and services to Sarona or on Sarona's behalf ("Providers"). Providers do not include third parties contracted by Sarona to perform services on Sarona's behalf. The services of these Providers may be available to you from the Site, from websites that are linked to the Site, or in connection with the Products and Services. Typically, these Providers offer services that Sarona customers might find useful, such as those that can be used in conjunction with Products and Services. In order to use Providers' products and services, you may be required to provide personal information to the Providers or agree to allow Sarona to share your personal information with such Providers. Unless expressly provided to the contrary, personal information that you provide while you are visiting a Provider's website will be subject to the privacy policy posted on that site, and personal information that you provide while on the Site will be subject to this Privacy Policy.

Protection of confidential business information

The protection of confidential business information is vital to the interests and the success of Sarona. Confidential business information includes any information regarding:

The above information is the property of Sarona (or of the client or Investor, as applicable) and should be kept strictly confidential. In addition, in the course of duties of staff at Sarona, including acting as a director of a company in which a fund or other client invests, or in connection with the review of potential investments, you and Sarona may be provided with or have access to confidential information of other companies and you and Sarona may be bound by duties of confidentiality or non-disclosure agreements not to disclose confidential information relating to such companies. You may not disclose any such Sarona, portfolio company or other information to any third party without the permission of the Chief Compliance Officer or another officer of Sarona, except for a purpose properly related to the business of Sarona or a client or investor and in accordance with your duties of confidentiality and the terms of any relevant non-disclosure agreement (such as to a client's or investor's independent accountants or administrator).

It is Sarona's policy to comply with applicable provisions of the Gramm-Leach-Bliley Act and Regulation S-P. Sarona shall deliver to applicable investors and individual retirement account investors a copy of its Privacy Policy at the time of initial investment and annually thereafter.

How your personal information is used

Sarona collects your information in order to record, support and facilitate your participation in the activities you select and to prevent fraud and unlawful use. Sarona does not share personal information it receives. Sarona will not sell, rent or lease your personal information to others. Sarona will not share your personal information with third parties except in responding to your requests for products or services. Your permission will be requested when you submit your information.

Sarona may collect information about the use of the Products and Services and the Site, such as the number of downloads, types of Services used, how many users we receive daily, Site pages visited, and the IP address of your computer. This information is generally collected in aggregate form, without identifying any user individually, although IP address and Session ID in relation to purchases and downloads may be tracked as part of Sarona's customer order review and fraud prevention efforts. Other exceptions to this, where an individual may be identified individually, are noted in this Privacy Policy or in additional privacy terms connected to a specific Product, Service or website.

Sarona may use aggregate, non-identifying statistical data for improving the Site and the Products and Services, providing more relevant experiences to our customers and for statistical analysis.

Privacy complaints

Sarona takes its users' privacy concerns seriously. If you believe that Sarona has not complied with this Privacy Policy with respect to your personal information, you may write to Sarona.

Sarona Asset Management
1B-110 Frobisher Drive
Waterloo, ON N2V 2G7
Canada

Email: [email protected]

In your letter, please describe in as much detail as possible the ways in which you believe that the Privacy Policy has not been complied with. We will investigate your complaint promptly.