2. Policy Statement
As a matter of policy, Sarona seeks to protect the “non-public personal information” of natural person consumers, customers and members of the public. Non-public personal information includes non-public “personally identifiable financial information” plus any list, description, contact information or grouping of customers that is derived from non-public personally identifiable financial information. This Policy explains the types of information that Sarona collects from its investors and members of the public, how it uses and discloses that information and the measures in which Sarona takes to safeguard that information.
This policy governs all private information shared by investors and members of the public during their interactions with Sarona.
4. Review Period
Sarona will conduct a review of this Policy when significant business process changes occur, to ensure that the information contained herein is still current and applicable.
4.1 Sarona’s use of private information
We may use your information for the following purposes:
- to operate, manage, develop and promote our business and our relationship with the organisation you represent (if any) and related transactions – this includes, for example, marketing and billing/payment purposes;
- to operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations;
- to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
- to comply with our legal and regulatory obligations and bring and defend legal claims.
We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us –for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left Sarona).
We will only process your personal information as necessary so that we can pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our business or compliance purposes (as described above). If you are uncertain as to Sarona’ need for information that we request from you, please contact the Sarona representative asking for the information, or contact us, with your query.
4.2 Deleting personal information held by Sarona (upon request)
Sarona will also have in place a process to delete personal information from investors and members of the public if this is requested from those individuals. Due to securities laws, Sarona must maintain certain information on investors and members of the public. However, if a member of the public requests their personal information to be deleted from Sarona’s systems, we will ensure this is deleted from our Salesforce customer relations management system and contacts held by Sarona staff.
4.3 Your rights
You may have a right of access to the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You can object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all your personal information (and require them to be deleted) in some other circumstances. If you wish to exercise any of these rights, please contact us as set out below. You can also lodge a complaint about our processing of your personal information with the Office of the Privacy Commissioner of Canada.
Any disclosure of information in a document that has been completed and submitted by you to Sarona to facilitate a business relationship between you and a third party provider (i.e., banker, account custodian, insurance company, etc.) will automatically be considered as having been authorized by you with respect to the non-affiliated third party service provider.