Privacy

Background and Scope

RPIA (“us”, “we”) is committed to fair information practices, and to protect the privacy and confidentiality of the personally identifiable information (“personal information”) that we collect, use and disclose, of individuals who open and maintain client accounts with RPIA, or who otherwise invest in one or more investment funds managed by RPIA (collectively referred to as “investors”). This may include individuals who are acting on behalf of, or who are deemed to be beneficial owners of, or who otherwise control or have an interest in a named entity account holder.RPIA’s Privacy Policy (the “Policy”) sets out the principles and guidelines that RPIA follows in the collection, use and protection of personal information of investors who are identifiable individuals, and which may include, but is not limited to their name, age, address, date of birth, identification numbers such as Social Insurance Numbers, income and other financial information, as applicable. As described in this Policy, RPIA collects personal information of investors to enable us to provide them with professional services in connection with their investments in the RPIA managed investment funds (each a “Fund” and collectively the “Funds”), to meet applicable legal and regulatory requirements and for reasonable other purposes to which they consent. This Policy incorporates the provisions of Part 1 of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) - Protection of Personal Information in the Private Sector, as well as the related PIPEDA Fair Information Principles as set out in Schedule 1 of the act.

Responsibilities

RPIA has designated its registered Chief Compliance Officer (“CCO”) as the Privacy Compliance Officer. The CCO is responsible for reviewing, maintaining and enforcing this Policy and related procedures aimed at ensuring that RPIA's is meeting its privacy goals and objectives while at a minimum ensuring compliance with applicable federal and provincial legislation and regulation. The CCO and RPIA’s Compliance Group is responsible for assessing and overseeing compliance with this Policy, while applicable employees of RPIA are responsible for the application of this Policy in the day-to-day collection, processing and safeguarding of personal information. The Head of Information Technology oversees the implementation and maintenance of systems and controls aimed at protecting and safeguarding personal information that is stored in electronic format.

Non-compliance with this Policy and privacy related incidents are considered to be of high significance and will be escalated and addressed in accordance with RPIA’s documented internal policies and procedures and applicable laws and regulations.

Principles

By implementing, monitoring and disclosing this Policy, RPIA abides by the PIPEDA Fair Information Principles in the collection and use of personal information.

Accountability

RPIA is responsible for all investor personal information under its control, including such information disclosed to third parties as per this Policy.

Identifying Purposes

RPIA will identify the purposes for which personal Information is collected at or before the time that the personal information is collected. The purposes for which RPIA collects personal information described in this Policy shall be those that a reasonable person would consider appropriate in the circumstances.

Consent

RPIA will inform each investor in a meaningful way of the purposes for the collection, use or disclosure of personal data. RPIA will obtain documented consent before or at the time of collection, as well as when a new use is identified.

In obtaining consent, RPIA will use reasonable efforts to ensure that the investor is advised of the identified purposes for which personal information will be used or disclosed. RPIA will seek consent to use and disclose personal information at the same time it collects the personal information as described in this Policy. However, RPIA may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.

By completing and submitting a subscription agreement to purchase units of one or more of the Funds, investors provide reasonable and explicit consent to the collection, use and disclosure of their personal information. Consent may be withdrawn at any time as described in the Policy but may result in material limitations to RPIA’s ability to continue providing professional services, maintain accounts or process transactions for such investors.

Limiting Collection

RPIA will not collect personal information indiscriminately. RPIA will not deceive or mislead individuals about the reasons for collecting personal information and will limit the amount and type of information gathered to what is necessary for the identified purposes.

Limiting Use, Disclosure, and Retention

Personal information will not be used or disclosed by RPIA for purposes other than those for which it was collected, except with the consent of the individual, or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes and as per RPIA’s internal recordkeeping and retention policies and procedures.

Accuracy

RPIA will take reasonable steps to keep personal information as accurate, complete, and up to date as necessary, considering its use and the interests of the individual and applicable regulatory obligations. Investors may access, review, challenge and update their personal information as described in this Policy.

Safeguards

RPIA will protect personal information with security safeguards it deems to be appropriate to the sensitivity of the personal information. Security safeguards aim to protect personal information against loss or theft as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the personal information is held.

Openness

RPIA will implement its personal information related policies and practices in a transparent manner and will make its Privacy Policy understandable and easily available including in investor facing documents and RPIA’s public website.

Individual Access

Upon written request, and unless prohibited by law, RPIA will inform investors of the existence, use and disclosure of their personal information and provide access to that personal information. An individual will be able to challenge the accuracy and completeness of personal information and have it amended as appropriate. RPIA will respond to such requests within a reasonable time and at minimal or no cost. The requested personal information will be provided or made available in a form that is generally understandable.

Investors that require more information, or have concerns, regarding RPIA’s personal information management can contact RPIA’s Privacy Compliance Officer by mail - 39 Hazelton Avenue, Toronto, Ontario M5R 2E3, or by phone - 647-776-1777 or by email - compliance@rpia.ca.

If access to personal information cannot be provided, RPIA will provide the reasons for denying access on request unless prohibited by law from doing so.

When an individual successfully challenges the accuracy or completeness of personal information, RPIA will correct, delete or add personal information as required. When appropriate, the amended personal information will be transmitted to any third parties having access to the personal information in question.

Challenging Compliance

Investors can address challenges concerning compliance by RPIA with this Policy to the designated Privacy Compliance Officer. Individuals also have recourse to the Office of the Privacy Commissioner of Canada, at the address noted below if they consider that RPIA has not responded satisfactorily to their complaint or inquiry.

Office of the Privacy Commissioner of Canada

Policy

Consent to the Collection and Use of Personal Information

Unless an investor advises otherwise, by completing a subscription agreement to invest in one or more Funds, and by providing us with their personal information, the investor explicitly consents to our collection, use and disclosure of their personal information as provided herein. If RPIA proposes to use personal information for a purpose not previously identified, the new purpose will be identified and documented prior to the new use. Except as authorized by law, the consent of the individual is required before the personal information can be used for a purpose not previously disclosed.

RPIA may collect, use or disclose personal information about an investor without consent if it is clearly in the interests of the investor and consent cannot be obtained in a timely way, such as when an individual is seriously ill or incapacitated, in cases of emergencies threatening life, health or security, when seeking consent may defeat the purposes of collecting the personal information for an investigation of a breach of an agreement or contravention of a federal or provincial law, when personal information is disclosed to a lawyer representing RPIA, to comply with a subpoena, warrant or other court order, pursuant to lawful and authorized requirements or requests for disclosure from government institutions, or as may otherwise be required or authorized by law.

Consent may be implied or express. In determining the appropriate form of consent, RPIA will take into account the sensitivity of the personal information and the reasonable expectations of the investor. In certain circumstances, and only as specified and permitted by applicable laws and regulation, RPIA may collect, use, or disclose personal information without the knowledge or consent of investors.

Collection of Personal Information

Personal information may be collected directly from investors or third parties as per RPIA’s policies and procedures and as permitted by applicable law.

RPIA collects and maintains personal information of investors in order to:

• provide investors with high quality professional service,
• process investor transactions and maintaining accounts,
• preparing and delivering investor reporting,
• where applicable, comply with applicable laws and regulations including those that require that we establish and assess their identity for anti-money laundering and know-your-client related obligations,
• protect us from error and fraud, and/or
• determine their eligibility to invest in the Funds and where applicable assess the suitability of such investments in accordance with securities laws.

Investor personal information is collected from the following sources:

• account opening and “know-your-client” forms, subscription agreements and/or other investor related forms and agreements, as applicable;
• investor transactions with us and our service providers,
• investor meetings, discussions, and conversations, and/or 
• applicable third parties such as wealth managers, investment dealers, as family offices, where applicable

Use, Disclosure, and Safeguarding of Personal Information

RPIA will use personal information only for the business-related purposes described in this Policy. If RPIA proposes to use personal information for a purpose not previously identified, the new purpose will be identified and documented prior to the new use. Except as authorized by law, the consent of the investor is required before the personal information can be used for that purpose.

RPIA may disclose investor personal information to third parties, when necessary, in connection with the services we provide related to their account or investment in the Funds, including:

• financial service providers, such as banks and others used to facilitate transactions by, or operations of, the Funds or investors;
• other service providers to the Funds, such as fund administration, accounting, legal, or tax preparation services; and
• taxation and regulatory authorities and agencies, which may include foreign authorities such as the U.S. Internal Revenue Service, where required by applicable laws.

RPIA will use contractual or other reasonable means to protect personal information that has been disclosed to third parties.

The Funds may be required to file with the Ontario Securities Commission and with other relevant Canadian securities regulatory authorities an annual report setting out the investor’s name and address, and details of the relevant Fund purchase(s). Such information is collected by securities regulators under the authority granted to them in securities legislation, for the purposes of the administration and enforcement of their governing securities legislation. By completing a subscription agreement, the investor authorizes such indirect collection of the information by each such regulatory authority.

RPIA seeks to carefully safeguard personal information and, to that end, restricts access to personal information about investors to those employees and other persons who need to know the information to enable us to provide appropriate services to them and to comply with applicable laws and regulations. Each employee of RPIA is bound by the RPIA Code of Conduct which includes being responsible for ensuring the confidentiality and safekeeping of all personal information they may access.

Investors’ personal information is maintained in a secure physical format or electronically on our secure networks or on the networks of our service providers and is accessible at 39 Hazelton Avenue, Toronto, Ontario M5R 2E3. Personal information may also be stored off-site in secured physical format with storage providers and electronically on secure third-party storage facilities including internet, virtual and cloud-based storage. Information stored electronically by RPIA is subject to our internal information technology and cybersecurity policies and procedures.

Access and Withdrawal of Consent

An investor may access their personal information to verify its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting RPIA at the following number: (647) 776-2566.

RPIA’s ability to provide necessary services to an investor, an investor’s ability to invest in one or more of the Funds and/or maintaining an account with RPIA may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above. Where applicable, RPIA will clearly disclosure the consequences of consent withdrawal to such investors.

Privacy Events, Breach Assessment, and Reporting

A privacy event or breach generally refers to actual or potential loss of, unauthorized access to, or disclosure of, personal information despite RPIA’s controls and safeguards. Upon the occurrence of a privacy event, the CCO (or appointed Compliance delegate) will document, investigate, and evaluate the facts, circumstances, and implications of the incident. Where it has been confirmed that event has resulted in a breach of investor personal information it will immediately be escalated to RPIA’s Risk Committee and may also be referred to external legal counsel as needed to aid in the assessment and appropriate actions related to the incident.

In its assessment of the breach, and for the purpose of determining its reporting obligation, RPIA will follow the guidelines provided under PIPEDA and/or the guidelines provided by the Commission d’Accès à l’Information (if applicable and in relation to information of a resident of Quebec) to determine if the incident resulted in a real risk of significant harm and/or a serious risk to the individual (as applicable).

In instances where such a risk has been deemed to exist, RPIA shall

• report the breach to the appropriate regulatory body as soon as practicable and in any event within the prescribed timelines of the applicable regulatory body, and
• affected individuals if the breach creates a real risk of significant harm or a serious risk to the individual as soon as feasible after RPIA has determined that the breach has occurred, unless giving notice is otherwise prohibited by law.