Privacy Policy

Personal Information

“Personal Information” is defined as information that identifies an individual and includes, but is not limited to, their name, email, address, age, marital status, race/nationality, financial records, religion, or social insurance number.

Fund Investors are requested to notify Crescero as soon as possible of any changes, deletions, or corrections to their Personal Information so that Crescero may keep such information up-to-date.

Purposes of Collection, Use and Disclosure of Personal Information and Fund Investor Consent

Crescero collects and maintains Personal Information about individuals in connection with the offering and sale of interests in Funds, communications with Fund Investors, or otherwise as required by law.  Crescero collects and maintains Personal Information in order to:

Establish, service and administer investments in and by Funds (such as providing tax receipts, Fund financial statements, and other information that may be requested or needed to service these investments); 
Assess an investor’s eligibility in a Fund;
Manage and monitor our website; 
To communicate with prospective and existing Fund Investors in a variety of ways (for example, by email, telephone, or direct mail) about our products, services, or other information that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages; 
File with applicable Canadian regulatory authorities a report setting out a Fund Investor’s name, address, telephone number, email address and other information relating to an investment by an investor, the class and series of interests issued, the date of issuance, the purchase price of interests issued to an investor and other details of the distribution;
Protect us and our Funds/Fund Investors from error and fraud;
Comply with anti-money laundering/anti-terrorist financing and other regulatory requirements; and
Establish Crescero’s legal rights or defend against legal claims.

Personal Information collected from an individual includes, but is not limited to, name, address, date of birth, and social insurance number; we typically collect this information from the following sources:

Subscription agreements submitted by a Fund Investor;
Transactions with Crescero or any of its affiliates; 
Communications between Crescero and an individual;
Online activity information, such as browser type, Internet service provider (ISP), information about your device and operating system, referring/exit pages, pages viewed on and other information about how you use (or that you otherwise transmit to us) on our sites; and
Other information provided.

Personal Information shall not be used or disclosed for purposes other than those for which it was collected.  We may disclose Personal Information to third parties and to our affiliates, when necessary and without the consent of an individual, including:

financial service providers, such as banks and others used to finance or facilitate transactions by, or the operations of, an Crescero offered Fund;
other service providers to a Fund such as fund administrators, accounting, legal, or tax preparation services; and
regulatory, tax or other government authorities and agencies. We will only disclose Personal Information to a governmental entity or other regulatory organization when required to do so by such laws and regulations, or by court order.

The collection of individual information will be limited to that which is necessary for Crescero to provide services to an individual and for third-party service providers to be able to provide services to us, offered Funds. Before we may use Personal Information for a purpose not previously identified to an individual, the new purpose shall be identified and consent will be obtained from the individual before the information is used for the new purpose (or the client may opt-out), unless the use is otherwise required by law.

Video Surveillance

For safety and security reasons, Crescero may use video surveillance technologies at the Firm’s Chatham office to monitor the public areas around this property. Video images of individuals that access this property and/or vehicles and license plate numbers may be captured. We will post notices at the point of entry of any such areas where we may use this technology. If you do not wish to have your images captured by us, please do not enter those areas.

We may disclose video surveillance footage to law enforcement or other government agencies where we believe such disclosure is: (i) permitted or required by law; (ii) necessary to protect our properties, visitors, customers or employees; or (iii) reasonable in connection with a law enforcement investigation.

Security Safeguards

Crescero maintains physical, technological, and organizational controls consistent with regulatory standards to safeguard Personal Information in its possession.  Reasonable security safeguards have been implemented to help protect Personal Information from loss, misuse, unauthorized access or disclosure.  These measures include, but are not limited to:

Restricted physical and system access controls;
Safeguards to detect and prevent security system failures;
Use of secure user authentication protocols for access to records with Personal Information;
Use of reasonably up-to-date firewall protection and operating system security patches;
Use of reasonably up-to-date versions of system security agent software including malware protection and virus definitions;
Reviewing safeguarding controls of service providers who receive Personal Information as part of the provision of our services; and
Employee training on our privacy obligations.

Crescero remains responsible for Personal Information it has disclosed to third parties and endeavors to protect this information through contractual agreements. Crescero does not sell or lease Personal Information to third parties nor does it share Personal Information with third parties for their marketing purposes.

Notwithstanding the aforementioned controls, there remains a residual risk of a breach of security safeguards which could result in a real risk of significant harm.  See section “Breaches and Risk of Harm” below for Crescero’s reporting and notification procedures to deal with a privacy breach which results in a real risk of significant harm to an individual.

In the event of a sale, transfer, or reorganization of Crescero, we may disclose Personal Information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of Personal Information in a manner that is consistent with this privacy policy.

Personal Information will be retained for at least seven years following the end of the relationship (unless there are legal requirements that require its retention) after which all documentation will be destroyed in a manner commensurate with its sensitivity.

Privacy Governance Program

We have established the following governance program to ensure Personal Information is protected:

Policies and practices. A suite of internal policies and practices that define how Crescero handles Personal Information throughout the information’s lifecycle, including by: specifying the roles and responsibilities of our employees with respect to the management such information, providing a framework for retaining and destroying personal information in a secure and timely manner, setting out processes for dealing with complaints regarding the protection of personal information and responding to individuals’ request to exercise their rights under applicable privacy and data protection laws.
Employee training and confidentiality. We provide our employees with periodic training regarding the handling and protection of Personal Information, and employees are under an obligation of confidentiality with respect to such information.
Designating individuals responsible for privacy compliance. We have designated individuals within Crescero to oversee our compliance with applicable data protection laws and to exercise certain functions assigned to them by law. Their contact information can be found in the “Contact Us” section below.

Website

We may collect certain types of information electronically through an individual’s Crescero with our website using technologies (either our own, or third-party technologies) such as cookies and web beacons. We may collect your Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages and the pages you viewed on our site.

Cookies

For Crescero to better understand your needs and improve our website by offering a better and more personalised service, remembering your preferences, and generally improving your experience, we collect information such as the number of hits on our site, the pages most frequently accessed and information about access to our secure website. This information is collected by Google Analytics, from which we compile overall statistics in order to improve our site and the services we provide to our clients.

Cookies are small text files that are placed on your computer by websites that you visit. Cookies can be categorised in accordance as set out below:

Strictly necessary cookies – these cookies are essential in order to enable you to move around a website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
Performance cookies – these collect information about how visitors use a website, for example, by recording which pages users go to most often (usually on an anonymous basis).
Functionality cookies – these cookies allow a website to remember the choices a user makes, such as a user name or language preference.
Targeting or advertising cookies – these collect information about a user’s browsing habits and are generally placed by advertising networks with the website operator’s permission.

Most browsers are initially set to accept cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If you wish to withdraw your consent at any time, you must delete your cookies using your internet browser settings. The “options” or “preferences” options in your internet settings function within your browser should tell you how.

Please consult the following for information or useful advice on managing your cookie settings. For information on how to do this on the browser of your mobile phone please refer to your device manual.

Cookies used by Google Analytics uses are “_gid” and “_ga”:

_gid – distinguishes users for 24 hours
_ga – distinguishes users on a domain and lasts 2 years

The website only collects cookies for logged in users (website administrators or the domain owner).  If at a later date we find that we require the use of any additional plugins that do collect cookies, we will advise you and update this cookie policy accordingly.

Client Access to and Choice Regarding their Personal Information

Crescero's Chief Compliance Officer has been appointed Chief Privacy Officer ("CPO"). The CPO oversees privacy governance including the development of policies, adherence to procedures, training, and education, reporting to Crescero’s Board of Directors. Crescero’s Chief Privacy Officer may be contacted in writing if individuals wish to:

access their Personal Information;
correct their Personal Information;
withdraw consent to any use and disclosure of their Personal Information (however, this may limit the individual’s opportunity to access Crescero’s services or products);
obtain more information or have concerns; and
file a complaint relating to how Crescero has handled their Personal Information (if a Client is dissatisfied with the results of an investigation of a complaint, they may bring the complaint to the attention of the Office of the Privacy Commissioner of Canada (“OPC”)).

Costs associated with the provision of Personal Information further to a Client’s written request are borne by the individual.  Requested information will generally be provided within 30 days of the request being made.  Crescero’s Chief Privacy Officer may be contacted at:

Crescero Natural Capital Inc.
Chief Privacy Officer
7 Jahnke Street
Chatham, Ontario N7M 4T4
Canada

T: 519-352-8413
Email: compliance@crescero.com

If an individual is not satisfied with the results of an investigation or the corrective measures taken by the Firm, they may exercise the remedies available under law by contacting the OPC at:

Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3

An individual may change their communication preferences with Crescero (e.g. chose to not receive marketing information), changing their browser settings on their device, or restrict collection, use or disclosure of Personal Information with reasonable notice to Crescero in writing and subject to legal or contractual restrictions.

The disabling of browser setting may restrict the use some of the features of the firm’s websites, or the withdrawal of consent may affect Crescero’s ability to continue to provide an individual with the products and services that they have or would like to receive because the continued use and disclosure of Personal Information is a necessary part of making the product or service available. In some circumstances, legal requirements may prevent an individual from withdrawing consent, such as Crescero’s obligation to report taxable investment income to the local tax authority.

Breaches and Risk of Harm

Crescero is subject to reporting and notification obligations in the event a privacy breach occurs which results in a real risk of significant harm to an individual.  A privacy breach is the loss of, unauthorized access to, or disclosure of, Personal Information resulting from a breach of an organization's security safeguards. A real risk of significant harm includes but is not limited to damage to reputation or relationships, identity theft, humiliation, or financial loss.

In the event of a privacy breach, Crescero will investigate and assess the implications of the breach as soon as feasible. Where Crescero has determined the breach creates a real risk of significant harm to an individual, Crescero will investigate the matter, report to the OPC and notify affected individuals as soon as feasible, and take remedial measures as applicable.

Contact Us

If you have any questions or complaints about how we handle your Personal Information, please Crescero us as indicated below: