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| We consider your
personal privacy to be an important part of our service to you. Our Privacy
Policy incorporates the following key principles: |
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Collecting and Using Personal
Information - We will explain
for what purposes we intend to use and disclose your personal information prior
to or when we are collecting it, and will obtain your consent for such use and
disclosure. We will limit the personal information we collect to what we need
for those purposes and we will use it only for those purposes. We will obtain
your consent if we wish to use your personal information for any other purpose
and before collecting information from outside parties such as credit
bureaus.
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Disclosing Personal Information to
Others - We may provide your
personal information to other parties, such as service providers, who assist us
in serving you and to other persons where we are required or permitted to do so
by law. We may also provide your personal information to other persons where we
have your consent.
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Retaining and Protecting Personal
Information - We will retain
your personal information only for the time it is required for the purposes we
explain or as otherwise required or permitted by law. We will protect the
personal information we obtain about you with appropriate safeguards and
security measures.
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Access
and Accuracy - We will provide
you with reasonable access to your personal information and we will make every
reasonable effort to keep your personal information accurate and
up-to-date.
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Accountability and Openness to Your Privacy
Concerns - We will hold
ourselves accountable to you and we will investigate and respond to your
concerns about any aspect of our handling of your personal information. We will
explain the application of our privacy policy to your personal information and
explain your options of refusing or withdrawing consent to the collection, use
and release of your personal information, and we will record and respect your
choices.
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| Why and how we obtain your personal
information |
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We collect, use and disclose your
personal information to establish and serve you as a client and to satisfy
regulatory requirements and/or laws. We obtain information directly from you or
from an authorized representative of yours. We only ask for the information we
need for the particular product or service requested. With your explicit
consent, for credit or margin purposes, we may contact lenders or credit
agencies to collect information on your credit history or employers or other
personal references to verify information that you have given us. In order to
comply with Canada Revenue Agency’s income reporting requirements, your
social insurance number is required for products which earn investment income.
We may also use your personal information for such other purposes for which you
provide your consent, or as otherwise permitted or required by law. |
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| When do we disclose your personal
information |
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We do not sell, barter, or lease client
lists or personal information to others. We will provide personal information,
as required, to government agencies or investigative bodies pursuant to
applicable laws. We will also provide it, as required, to securities
regulators, including any self-regulating organizations that we are subject to,
who collect, use or disclose personal information of current and former
clients, employees, directors and others for regulatory purposes, including for
the purpose of conducting compliance audits, investigations of potential
regulatory and statutory violations, and information-sharing with other
securities regulators and law enforcement agencies. We may also provide your
personal information, only as is necessary, to other parties in order to
provide you with a product that you have specifically requested, such as to a
mutual fund company or a trustee of a government registered investment plan, or
to parties who assist us in serving you, such as carrying broker(s) and other
service providers. We may also provide it to other parties at your request, or
with your consent, or as otherwise permitted or required by law. |
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| How long do we retain your personal
information |
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We retain your personal information
only as long as it is required for the purposes for which it was collected or
as otherwise permitted or required by law. The length of time we retain it
varies depending on the product or service and the nature of the information
and may extend beyond the end of your relationship with us but only for so long
as it is necessary for us to have sufficient information to respond to any
issue that may arise at a later date. When your personal information is no
longer needed as set out above, we have procedures to destroy, delete, erase or
convert it to an anonymous form. |
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| How do we protect your personal
information |
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We maintain security standards and
procedures to protect your personal information against unauthorized access and
use. All employees are familiar with the procedures that must be taken to
safeguard your personal information and we limit employee access to those
employees with a business need to know that are involved in the provision of
the particular service to you. Other parties who assist us in serving you, such
as service providers, are bound to maintain your confidentiality and may not
use it for any unauthorized purpose. |
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| Your right to access your personal
information |
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You may request access to your personal
information that we have about you by contacting us in writing as set out
below. We will advise you if a reasonable charge will be required for
conducting the search and we will generally respond to your request within 30
days. Please note that we may not provide information about you which reveals
personal information about a third party, is subject to legal privilege, or
cannot be disclosed for other legal reasons. |
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| Keeping your personal information
accurate |
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We attempt to keep your personal
information as accurate and up-to-date as is necessary. You can help us by
promptly notifying us of any required changes or apparent errors or omissions
in your personal information. |
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| Your options |
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It is always your choice whether to
provide us with your personal information or to consent to our collection, use
or release of it. As well, usually you are free to withdraw your consent at any
time, however, without certain of your personal information or consents, we may
not be able to provide or make available certain products or services to you.
We will be pleased to explain your options and any consequences of refusing or
withdrawing your consent. |
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| Contacting us regarding privacy
issues |
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If you have any questions, concerns or
complaints about privacy issues, you may contact the Privacy Officer of the
particular MIDDLEFIELD® company by: |
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| Fax |
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(416) 362-7925, or |
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| Mail |
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1 First Canadian Place, 58th Floor, P.O. Box
192
Toronto, Ontario M5X 1A6. |
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1 MIDDLEFIELD® means
Middlefield Capital Corporation, Middlefield Realty Services Limited,
Middlefield Group Limited, MFL Management Limited, Middlefield Venture Group,
Middlefield International Limited, Middlefield Mutual Funds Limited and
Middlefield Limited. |
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