TIMBERCREEK CAPITAL INC. PRIVACY POLICY

Last updated: November 17, 2025

Timbercreek Capital Inc., including its subsidiaries and affiliated entities  (collectively “Timbercreek“) is committed to maintaining the accuracy, confidentiality and security of your personal information. We have developed this document (the “Privacy Policy“) to describe our privacy policies and practices and how we collect, use and disclose the personal information of our clients and other individuals who visit our website. If you are unsure whether this Privacy Policy applies to you, please contact our Privacy Officer for more information.

Privacy Policy Effective for Canada

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

Timbercreek takes its commitment to the privacy of client information seriously. In doing so, Timbercreek follows these 10 principles:

  1. Accountability: We are responsible for personal information under our control. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
  2. Identifying purposes: The purposes, for which personal information is collected, will be identified by us, or through our, or your, authorized representatives before or at the time the personal information is collected.
  3. Consent: Your consent is required for the collection, use and disclosure of personal information, subject to certain exceptions. Such exceptions are set out in the law and include where legal, medical or security reasons make it impossible, or impractical, to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our, or your, authorized In certain circumstances, it may also be implied.
  4. Limiting collection: The collection of your personal information must be by fair and lawful means, and be limited to that which is necessary for the purposes identified.
  5. Limiting use, disclosure and retention: Your personal information may be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
  6. Accuracy: Any personal information that is collected, used or disclosed should be as accurate, complete and as up-to-date as is necessary for the purpose for which it is to be used. Accordingly, please keep us informed of any changes to your personal information.
  7. Safeguards: Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.
  8. Openness: This Privacy Policy provides information about our practices for managing your personal information.
  9. Individual access: Upon written request to our Privacy Officer, you will be informed of the existence, use and disclosure of your personal information and you will be given access to it, subject to certain exceptions, as permitted or required by You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate, in accordance with applicable laws.
  10. Inquiries and concerns: You may contact us if you have any inquiries or concerns about our privacy policies and practices.

The Information We Collect

Personal information is information about an identifiable individual (such as name, home address, personal phone number, personal email, and date of birth), other than business contact information (such as name, title, work address, work phone number, and work email) used or disclosed for the purpose of business communications. We may collect, use, and disclose personal information for the purposes set out in this Privacy Policy, other purposes to which you consent, and as otherwise permitted or required by law. In general, we will collect the required information directly from you, or from your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet, and through your business dealings with us. In some cases, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers we retain, financial institutions, your employer or credit reporting agencies.

In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). From time to time, we may use the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

What We Need to Know and Why

You can visit our website without telling us who you are or revealing any information about yourself, including your email address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes personal information such as your name, address, telephone number(s) or other identifying information, such as your Social Insurance Number (SIN) or date of birth. The information gathered may be financial, which would include such information as place of employment, annual income, assets and liabilities. It may be investment or advice related, requiring information on such things as your financial goals and retirement plans, and any other contact or other information that you choose to provide by:

  • using the “contact” portion of this website or a third-party website (e.g. recruiting services) used by Timbercreek;
  • applying for a position with Timbercreek through this website or a third-party website used by Timbercreek; or
  • by corresponding with a representative of Timbercreek, g., via email or telephone.

We collect information from you and about you with your consent, or as required or permitted by law. Generally, we collect, use and disclose your personal information to:

  • confirm your identity, and to protect both you and us against errors, fraud, theft, damage to goods and property, or other misrepresentations;
  • evaluate your financial needs and determine the suitability of our products and services for you;
  • determine your eligibility for products and services;
  • properly administer the products and services we provide;
  • comply with a variety of legal requirements, including any tax reporting obligations under the federal Income Tax Act; or
  • achieve any other purposes for which you consent, or any other purpose permitted or required by law.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.

Where you request information from us, we may use the contact information that you provide to send you information about offers on services that we provide to, or receive from, you, or that we believe may be of interest to you. We may also contact you to provide you with, or collect from you, business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feedback and other information requested by or provided to you.

We will keep your personal information in our records for as long as it is needed to fulfill these purposes, or as required or permitted by law, after which we will destroy, erase, de-identify and/or anonymize your personal information. We may use a de-identified and/or anonymized version of your personal information for any purpose.

Your Consent

We collect, use and disclose your personal information for purposes related to the products and services we offer, and with your consent, or as permitted or required by law. Your consent may be expressed in writing, or it may be given verbally, electronically, or through our, or your, authorized representative(s), such as your financial services advisor. Your consent may also be deemed, implied or inferred from certain actions. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law to do so.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

You may withhold or withdraw your consent for us to collect, use and share your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Disclosure of Your Personal Information

Generally, the disclosure of your personal information will be restricted to those who have a need to know the information.

We may disclose your information to third parties, including: third parties that provide services to us or on our behalf; third parties that assist Timbercreek in the provision of services to you; and third parties whose services we use to conduct our business.

For example, Timbercreek uses certain service providers to provide information technology and data processing services to us, and certain banks and financial advisors to assist with the preparation of tax returns, investment fund administration services and standard banking services from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada, the United States of America, Europe, the United Kingdom and other jurisdictions. In these circumstances, the governments, courts, law enforcement, national security, or regulatory agencies of such other jurisdictions may be able to obtain access to your personal information through the laws of the foreign country.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Timbercreek through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Your personal information may be disclosed:

  • to our employees, contractors, agents and representatives, who need the information in the performance of their duties for us;
  • to our affiliates, to resolve your concerns about any related products and services with us or to make you aware of other products or services that may be of interest to you;
  • as part of Timbercreek’s regular reporting activities to its affiliates;
  • to service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us;
  • where necessary to protect the safety of a person or group;
  • to comply with legal processes such as search warrants, subpoenas or court orders;
  • to protect the rights and property of Timbercreek;
  • any person or organization to whom you gave consent; and
  • anyone who is otherwise required or permitted by law to receive your personal

How Is Your Personal Information Protected?

Timbercreek endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Newsletters

If you have asked us to put you on an email mailing list, we may email you our newsletter. Each of our newsletter emails includes an unsubscribe link that you can use to remove yourself from such mailing lists.

How Do We Use Cookies?

When you visit the website, we place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs.

Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.

What About Links to Other Websites?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Timbercreek is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Regulatory Purposes

For legal and regulatory purposes, regulatory bodies such as FINTRAC or the Ontario Securities Commission, and credit reporting agencies (such as Equifax and Transunion) may require access to personal information of current and former clients, employees, agents, directors, officers, partners and others.

Such regulators may use the information for such purposes as:

  • surveillance of trading-related activity;
  • sales, financial compliance, trade desk review and other regulatory audits;
  • investigation of potential regulatory and statutory violations;
  • regulatory databases;
  • enforcement or disciplinary proceedings;
  • reporting to securities regulators; and
  • information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

Because Timbercreek is a regulated entity, we require your consent to the sharing of information with these bodies for these purposes. Without such consent, Timbercreek cannot provide financial services to you.

Accessing and Amending Your Information

We will take commercially reasonable efforts to ensure that any personal information we collect is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we rely on you to provide us with accurate information and to inform us of changes, such as changes in your contact information.

Under Canadian privacy law you may have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to applicable law.

Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Address:
Privacy Officer
Timbercreek Capital Inc.
25 Price Street
Toronto, Ontario, Canada M4W 1Z1
Email: privacyofficer@timbercreek.com
Phone: 1-866-975-8005

Revisions to This Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website https://timbercreek.com/privacy-policy/ and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on the date provided above.

Interpretation of This Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word “including” is used, it shall mean “including without limitation.”

This Privacy Policy has been developed to give effect to Canada’s federal and provincial privacy laws, as applicable. This Privacy Policy does not impose upon Timbercreek any obligations, or create or confer upon any individual any rights, outside of, or in addition to, those imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Timbercreek Capital Inc., including its affiliated entities Asset Management Inc. (collectively “Timbercreek“) is committed to maintaining the accuracy, confidentiality and security of your personal information. We have developed this document (the “Privacy Policy“) to describe our privacy policies and practices and how we collect, use and disclose the personal information of our clients and other individuals who visit our website. If you are unsure whether this Privacy Policy applies to you, please contact our Privacy Officer for more information.

Privacy Policy Effective for Canada

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

Timbercreek takes its commitment to the privacy of client information seriously. In doing so, Timbercreek follows these 10 principles:

  1. Accountability: We are responsible for personal information under our control. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
  2. Identifying purposes: The purposes, for which personal information is collected, will be identified by us, or through our, or your, authorized representatives before or at the time the personal information is collected.
  3. Consent: Your consent is required for the collection, use and disclosure of personal information, subject to certain exceptions. Such exceptions are set out in the law and include where legal, medical or security reasons make it impossible, or impractical, to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our, or your, authorized In certain circumstances, it may also be implied.
  4. Limiting collection: The collection of your personal information must be by fair and lawful means, and be limited to that which is necessary for the purposes identified.
  5. Limiting use, disclosure and retention: Your personal information may be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
  6. Accuracy: Any personal information that is collected, used or disclosed should be as accurate, complete and as up-to-date as is necessary for the purpose for which it is to be used. Accordingly, please keep us informed of any changes to your personal information.
  7. Safeguards: Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.
  8. Openness: This Privacy Policy provides information about our practices for managing your personal information.
  9. Individual access: Upon written request to our Privacy Officer, you will be informed of the existence, use and disclosure of your personal information and you will be given access to it, subject to certain exceptions, as permitted or required by You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate, in accordance with applicable laws.
  10. Inquiries and concerns: You may contact us if you have any inquiries or concerns about our privacy policies and practices.

The Information We Collect

Personal information is information about an identifiable individual (such as name, home address, personal phone number, personal email, and date of birth), other than business contact information (such as name, title, work address, work phone number, and work email) used or disclosed for the purpose of business communications. We may collect, use, and disclose personal information for the purposes set out in this Privacy Policy, other purposes to which you consent, and as otherwise permitted or required by law. In general, we will collect the required information directly from you, or from your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet, and through your business dealings with us. In some cases, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers we retain, financial institutions, your employer or credit reporting agencies.

In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). From time to time, we may use the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

What We Need to Know and Why

You can visit our website without telling us who you are or revealing any information about yourself, including your email address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes personal information such as your name, address, telephone number(s) or other identifying information, such as your Social Insurance Number (SIN) or date of birth. The information gathered may be financial, which would include such information as place of employment, annual income, assets and liabilities. It may be investment or advice related, requiring information on such things as your financial goals and retirement plans, and any other contact or other information that you choose to provide by:

  • using the “contact” portion of this website or a third-party website (e.g. recruiting services) used by Timbercreek;
  • applying for a position with Timbercreek through this website or a third-party website used by Timbercreek; or
  • by corresponding with a representative of Timbercreek, g., via email or telephone.

We collect information from you and about you with your consent, or as required or permitted by law. Generally, we collect, use and disclose your personal information to:

  • confirm your identity, and to protect both you and us against errors, fraud, theft, damage to goods and property, or other misrepresentations;
  • evaluate your financial needs and determine the suitability of our products and services for you;
  • determine your eligibility for products and services;
  • properly administer the products and services we provide;
  • comply with a variety of legal requirements, including any tax reporting obligations under the federal Income Tax Act; or
  • achieve any other purposes for which you consent, or any other purpose permitted or required by law.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.

Where you request information from us, we may use the contact information that you provide to send you information about offers on services that we provide to, or receive from, you, or that we believe may be of interest to you. We may also contact you to provide you with, or collect from you, business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feedback and other information requested by or provided to you.

We will keep your personal information in our records for as long as it is needed to fulfill these purposes, or as required or permitted by law, after which we will destroy, erase, de-identify and/or anonymize your personal information. We may use a de-identified and/or anonymized version of your personal information for any purpose.

Your Consent

We collect, use and disclose your personal information for purposes related to the products and services we offer, and with your consent, or as permitted or required by law. Your consent may be expressed in writing, or it may be given verbally, electronically, or through our, or your, authorized representative(s), such as your financial services advisor. Your consent may also be deemed, implied or inferred from certain actions. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law to do so.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

You may withhold or withdraw your consent for us to collect, use and share your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Disclosure of Your Personal Information

Generally, the disclosure of your personal information will be restricted to those who have a need to know the information.

We may disclose your information to third parties, including: third parties that provide services to us or on our behalf; third parties that assist Timbercreek in the provision of services to you; and third parties whose services we use to conduct our business.

For example, Timbercreek uses certain service providers to provide information technology and data processing services to us, and certain banks and financial advisors to assist with the preparation of tax returns, investment fund administration services and standard banking services from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in Canada, the United States of America, Europe, the United Kingdom and other jurisdictions. In these circumstances, the governments, courts, law enforcement, national security, or regulatory agencies of such other jurisdictions may be able to obtain access to your personal information through the laws of the foreign country.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Timbercreek through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Your personal information may be disclosed:

  • to our employees, contractors, agents and representatives, who need the information in the performance of their duties for us;
  • to our affiliates, to resolve your concerns about any related products and services with us or to make you aware of other products or services that may be of interest to you;
  • as part of Timbercreek’s regular reporting activities to its affiliates;
  • to service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us;
  • where necessary to protect the safety of a person or group;
  • to comply with legal processes such as search warrants, subpoenas or court orders;
  • to protect the rights and property of Timbercreek;
  • any person or organization to whom you gave consent; and
  • anyone who is otherwise required or permitted by law to receive your personal

How Is Your Personal Information Protected?

Timbercreek endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Newsletters

If you have asked us to put you on an email mailing list, we may email you our newsletter. Each of our newsletter emails includes an unsubscribe link that you can use to remove yourself from such mailing lists.

How Do We Use Cookies?

When you visit the website, we place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs.

Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.

What About Links to Other Websites?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Timbercreek is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Regulatory Purposes

For legal and regulatory purposes, regulatory bodies such as FINTRAC or the Ontario Securities Commission, and credit reporting agencies (such as Equifax and Transunion) may require access to personal information of current and former clients, employees, agents, directors, officers, partners and others.

Such regulators may use the information for such purposes as:

  • surveillance of trading-related activity;
  • sales, financial compliance, trade desk review and other regulatory audits;
  • investigation of potential regulatory and statutory violations;
  • regulatory databases;
  • enforcement or disciplinary proceedings;
  • reporting to securities regulators; and
  • information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

Because Timbercreek is a regulated entity, we require your consent to the sharing of information with these bodies for these purposes. Without such consent, Timbercreek cannot provide financial services to you.

Accessing and Amending Your Information

We will take commercially reasonable efforts to ensure that any personal information we collect is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we rely on you to provide us with accurate information and to inform us of changes, such as changes in your contact information.

Under Canadian privacy law you may have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law allows or requires us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to applicable law.

Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by email. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Address:

Privacy Officer
Timbercreek Capital Inc.
25 Price Street
Toronto, Ontario, Canada M4W 1Z1
Email: privacyofficer@timbercreek.com
Phone: 1-866-975-8005

Revisions to This Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website https://timbercreek.com/privacy-policy/ and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on the date provided above.

Interpretation of This Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word “including” is used, it shall mean “including without limitation.”

This Privacy Policy has been developed to give effect to Canada’s federal and provincial privacy laws, as applicable. This Privacy Policy does not impose upon Timbercreek any obligations, or create or confer upon any individual any rights, outside of, or in addition to, those imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.