PRIVACY POLICY

Your Privacy at Kupfer Capital Corporation

At Kupfer Capital Corporation, we respect your privacy and are committed to keeping personal information about you strictly between us. For the security of all of our clients, we have adopted our own Privacy Principles observed by Kupfer Capital Corporation. The information is this notice answers common questions about the ways in which we collect, use and share your personal information. It explains your privacy choices and how you can access and change the personal information, which we have about you.

Privacy Principles

Kupfer Capital Corporation has adopted the following privacy principles:

• • We will only collect information that we believe to be relevant and required to understand our clients’ needs and to conduct our business.
  • We will use customer information to provide customers with better customer services and products.
  • We will share customer information with other related companies or agents, as permitted by law.
  • We will not disclose customer information to any external organization unless we have customer consent or are required by law.
  • We may be required, from time to time, to disclose customer information to Governmental or judicial bodies or agencies or regulators but we will only do so under proper authority.
  • We aim to keep customer information up-to-date.
  • We maintain strict security systems designed to prevent unauthorized access to customer information by anyone, including our staff.
  • All of our staff and all third parties with permitted access to customer information are specifically required to observe our confidentiality obligations.

Your Consent

We will not collect, use or disclose your personal information without your consent, except where required or permitted by law.
In order to provide you with products and services, it is necessary for us to be able to collect, use and disclose your personal information for certain clearly identified purposes. We obtain this consent beginning during the registration process. If you choose not to consent to these uses of your personal information, we will explain the consequences of this refusal to you.

Answering Your Questions About Privacy

What personal information do you need?

Personal Information” means any identifiable information about you. We are required by law to confirm your identity. We collect certain personal information from you including your name, address, signature, date of birth, identification numbers, and occupation or employment information.

If you have deposits towards real estate purchases that are interest bearing, Canada Revenue Agency requires us to keep a record of your social insurance number.

How is your personal information used?

We use your personal information to:

• • evaluate your application for products and services;
  • open, operate and collect on your account(s);
  • provide ongoing service to you as a customer;
  • to evaluate the current and future needs of our customers and to help better manage our business;
  • honour your privacy choices;
  • verify your identity;
  • meet legal and regulatory requirements;
  • conduct statistical and record keeping operations.

With your consent, we will share your personal information within Kupfer Capital Corporation so that we can determine what products or services may be of interest to you and offer these products and services to you. With your consent, we will also offer you the products or services of selected third parties. You may at any time withhold, withdraw or change your consent to the uses of your personal information, and this will have no effect on our relationship with you.

Where do you obtain personal information about me?

Most of the information comes directly from you when you apply or register with us. We may also need information from credit bureaus, income sources and personal references you have provided to us. Of course, we obtain consent from you before we contact anyone for information about you.

In what circumstances is personal information disclosed?

Generally, we do not disclose your personal information without your consent. More specifically, we ask for your written consent for the disclosure of information to credit reporting agencies or to other credit grantors.

There are however, some exceptions. For example, we sometimes require services from suppliers and agents, such as legal firms, market research and service companies. We choose our service providers and agents with care and we impose strict contractual obligations on them to protect your personal information to the standards of confidentiality and security, which we observe. We use service providers or agents located in Canada or in other countries and, as a result, personal information may be accessed under the laws of Canada or such other countries to which the information has been transferred. If you would like further information about the policies and practices of Kupfer Capital Corporation with respect to the use of service providers outside Canada or have any questions regarding collection, use or disclosure of your information by such service providers, please contact us. Our customer lists are for Kupfer Capital Corporation use only and we never sell or give lists to other companies.

Another exception is when Kupfer Capital Corporation is required by law to disclose your personal information. For example, if Kupfer Capital Corporation receives subpoenas, search warrants, court or government orders Kupfer Capital Corporation releases the information but only to the extent that is legally required. In addition, the law permits us to disclose personal information: in order to collect a debt owed to us; and to government authorities or investigative bodies for various law enforcement purposes like combating fraud or money laundering.

With the ongoing growth of Developments, some of our businesses may be bought or sold. In this event, personal information would be transferred in order that the purchaser could continue to provide ongoing service to the affected customers.

How long do you keep personal information?

We only keep your personal information on file for as long as we need it to provide you with service and to meet legal requirements. When we no longer need the information, it is either destroyed or made anonymous.

What safeguards do you have in place to keep personal information confidential?

We use a variety of security measures such as restricting employee access to files and data centres, using fireproof and locked file cabinets, and employing a variety of electronic security measures, such as passwords, personal identification numbers and data encryption techniques.

Only those employees who need personal information to provide service have access to it. It is a condition of employment that all Kupfer Capital Corporation employees conform to our Privacy Code and sign a written promise to observe the highest standards of confidentiality for each customer’s personal information.

Can I find out what information you have concerning me and who you have given it to?

At any time, you can find out what personal information we have, what it is being used for and to whom it has been disclosed. However, in some specific circumstances, disclosure of your personal information to you can or must by law be denied, for example when: the information is protected by solicitor/client privilege; disclosure of the information would also reveal personal information about another person; or, disclosure would reveal confidential commercial information. We do not keep records regarding the disclosure of personal information for routine purposes such as cheque printing, tax reporting to the government, updating credit information to credit bureaus or indicating to third parties when cheques are returned NSF. We will do our best to provide the required information to you within a reasonable time period after receiving your written request and will provide an explanation if we are unable to meet your request. Generally we will respond to inquiries free of charge and, in the event that the inquiry is sufficiently complex to warrant a charge, we will provide an estimate of the amount in advance.

If my personal information is inaccurate, can it be changed?

Yes, we will correct inaccurate or incomplete information within a reasonable time and will notify you when we have done so. There is no charge for correcting your information. In the unlikely event we have given incorrect information to others, we will ensure they are advised of the required corrections. You may access your Personal Information in our possession or make corrections to it by visiting a Kupfer Capital Corporation office. We will assist you to complete the necessary forms.

Recording of Telephone Calls

Telephone calls to and from Kupfer Capital Corporation may be recorded for quality assurance and as a record of the information exchanged.

What to do if you have a question, concern or complaint about privacy with Kupfer Capital Corporation

We are committed to setting the highest customer service standards in the financial services industry. We hope you will give us the opportunity to correct any situation that does not meet your expectations.
If you have a question, concern or complaint about the way in which personal information is collected, used or disclosed by Kupfer Capital Corporation, please contact the Privacy Officer of Kupfer Capital Corporation. Receipt of your complaint will be acknowledged in writing or by telephone. Upon completion of a detailed investigation, the Privacy Officer will provide a written response.
You may contact the Office of the Privacy Officer at the following:

Privacy Officer
Kupfer Capital Corporation
2 Bloor Street West
Toronto, ON M4W 3E2
Email:info@kupfercapital.com

Strictly between us

At Kupfer Capital Corporation, we respect your privacy and are committed to keeping personal information about you strictly between us.
If you have any concerns about Privacy we want to know about them. Write, call, or visit. Keep in touch and let us know what’s on your mind. We’re always ready to help.