Last updated on April 2024
Privacy Policy
At 3L Capital Inc. (“3L Capital”, “we”, or “our”), protecting your privacy and safeguarding personal information is of utmost importance. This Privacy Policy outlines how 3L Capital collects, uses, and protects personal information in accordance with Canadian federal privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
Definition of Personal Information
Personal information, as defined under the Privacy Act, encompasses any factual or subjective information, recorded or not, about an identifiable individual. This includes but is not limited to:
- Age
- Name (except when related to a business)
- ID number (e.g., driver’s license or passport number)
- Ethnic origin
- Social status, disciplinary action, credit files, loan records
- Income, assets, and other information specific to an individual
Exceptions include information such as a person’s name, title, and contact information as a partner or employee, which is not considered private information, and publicly available information not covered by the Act.
Principles of Privacy Legislation
3L Capital adheres to the principles outlined in PIPEDA, including:
1. Accountability
- We appoint an individual responsible for privacy compliance.
- Personal information held by our organization is protected, and we develop and implement policies and procedures regarding personal information.
2. Identify Purposes
- We identify and document the purpose of collecting personal information before or at the time of collection.
- Individuals are informed why their information is needed and how it will be used.
3. Obtain Consent
- We inform individuals of the purpose of collecting, using, or disclosing their personal information and obtain their consent.
- Consent is obtained before or at the time of collection, or when a new purpose for the information is identified.
4. Limit Collection
- We do not collect unnecessary information and do not mislead individuals about the reasons for collecting personal information.
5. Limit Use, Disclosure, and Retention
- Personal information is used or disclosed only for the purposes for which it was collected, unless consent for other uses is obtained.
- We retain personal information only as long as necessary to fulfill its intended purpose and have procedures for retention and destruction.
6. Accuracy
- We encourage individuals to review and update their information periodically to ensure accuracy.
7. Safeguards
- We maintain physical, electronic, and procedural safeguards to protect personal information against loss, unauthorized access, or modification.
- Access to personal information is restricted to employees who require it for business purposes, and staff are trained on confidentiality obligations.
8. Openness
- We publicly disclose how we handle personal information through our privacy policy, which is readily available on our website or by contacting our Privacy Officer.
9. Individual Access
- Upon request, we provide individuals with access to their personal information, including how it has been used and disclosed.
- Individuals may verify the accuracy of their information and request amendments if necessary.
10. Challenging Compliance
- Individuals may challenge our compliance with this policy by contacting our Privacy Officer.
- We review all complaints received and take appropriate measures to ensure compliance.
Handling of Private Information
- 3L Capital partners and employees are prohibited from using private client information for purposes other than disclosed to the client.
- Private information is only disclosed to external parties as required by contract or business function, such as our carrying broker or regulators.
Storage of Private Information
- Client’s private information must be securely stored, with access restricted to authorized personnel.
- Documents containing personal information are retained for the required period and securely disposed of afterward.
Privacy Officer
- Our Chief Compliance Officer serves as the Privacy Officer responsible for overseeing our privacy policy and handling client complaints regarding privacy.
If you have any questions or concerns about our privacy practices or wish to exercise your privacy rights, please contact:
Privacy Officer
3L Capital Inc.
Mark Souvenir
150 King Street West, Suite 200
Toronto ON M5H 1J9
Email: contact@3L-capital.com
We are committed to protecting your privacy and ensuring the confidentiality of your personal information.