Privacy Policy

Minett Capital Privacy Policy.


Minett Capital Inc., and its subsidiaries, affiliates and related entities, (“Minett”) is committed to preserving and safeguarding your right to privacy. As part of this commitment, we want you to be fully aware of what happens to your personal information, which we have in our possession. Accordingly, this Privacy Policy sets out the manner in which we will collect, use, disclose and otherwise manage your personal information, including in compliance with the Personal Information Protection and Electronic Documents Act (the “Act”).



The Act states that every organization must comply with the following obligations of privacy protection:

  1. Accountability;
  2. Identifying purposes;
  3. Consent;
  4. Limiting collection;
  5. Limiting use, disclosure and retention;
  6. Accuracy;
  7. Safeguards;
  8. Openness;
  9. Individual access; and
  10. Compliance.


Key terms

Personal Information means information about an identifiable individual, including but not limited to data such as race, ethnic origin, age, financial history and personal opinion. It does not include the name, title or business address or business telephone number of an employee of an organization.

Consent – Minett cannot collect, use or disclose personal information without the knowledge and consent, whether implicit or explicit, of an individual. Exceptions for the collection and use of personal information without consent are described in the Act.


Collection of personal information

We collect the personal information you provide us when you request information about Minett. The personal information we collect may include your name, address and telephone number and e-mail address; customer and investor relationship information, such as customer service requests and investor information requests; business relationship information, such as agreement terms and preferences; and business operations information, such as unit holder contact information in response to specific requests. Any information that is collected is treated as confidential and will be respected in accordance with this Privacy Policy.


We may also collect personal information to allow us to manage and develop our business and operations, including: informing you of, and supplying you with investor relations information other than that which you specifically requested; enabling Minett to comply with applicable law or regulatory requirements; and any other reasonable purpose to which you consent.


Personal information we receive from you may be collected by us either directly from you or may be obtained from one of our third party service providers who has collected the information from you on our behalf. These service providers may include providers of news wire services, transfer agents or financial institutions.


We also may automatically collect general anonymous information related to your use of our website, such as the date and time you visit the site, and the pages you visit on the website. In addition, we collect “cookie” information from your browser to identify your computer and provide us with a record of your visits to our website. The technology used to gather “cookie” information is provided by the Internet browser you use, and may be turned off by using your browser preference buttons. This statistical information helps us to understand how our websites are used (e.g., identifying which pages or sections are most popular and the peak activity times), which assists us in planning for future improvements to the website to better meet our clients’ needs.


Purposes of collecting personal information

  1. to inform you of, and supplying you with, investor relations information other than that which you specifically requested;
  2. to comply with your requests;
  3. to enable Minett to comply with applicable law or regulatory requirements; and,
  4. any other reasonable purpose to which you consent.


You may refuse or withdraw your consent to our use of your personal information as explained under “Consent” below. Before using your personal information for any purpose other than those listed in (i) to (iv) above, Minett will explain that purpose to you and seek your consent.


Disclosure of your personal information

All third parties will be asked to sign a Non-Disclosure Agreement, prior to their receipt of any personal information. The use, disclosure and retention of the personal information by the permitted third party is also governed by the Act and a statement of compliance with the Act will be required from such third parties prior to their receipt of the personal information.

In common with many organizations, we reduce costs by obtaining some routine services from third party service providers, and your information may be provided to them. These service providers must agree to only use the information disclosed to them for the specific purposes stated by us in the agreement and are prohibited from using it for any other purpose. Disclosure of personal information to these providers may be used for purposes described in this Privacy Policy and where:

  1. we are required to do so by legal or regulatory requirements;
  2. the information is publicly available or it is part of Minett’s regular reporting activities;
  3. it is necessary to protect the rights and property of Minett;
  4. emergencies occur or where the use is necessary to protect the safety of a person or group of persons;
  5. the information is public personal information;
  6. it is required by employees, contractors, consultants and other parties (including other organizations included in the term Minett), who require the information to assist us to establish, maintain and manage our relationship with you, including, for example, third parties that provide services to us or on our behalf or third parties that collaborate with Minett in the provision of services to you;
  7. it is required by another party, in the event of a change in ownership of or granting of security interests in all or part of Minett through, for example, some form of merger, purchase, sale, lease, amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them 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; or
  8. we have obtained your consent (see “Consent” below).


Our disclosure of your personal information to third parties will only be for the purposes set out in this Privacy Policy. Except as expressly set out in this Privacy Policy, we will not sell, transfer or otherwise disclose any of your personal information to any third party without your express consent.


Consent and opting-out

Our collection, use or disclosure of your personal information requires your consent. Depending on the nature and sensitivity of your personal information, your consent to the collection, use and disclosure of such information may be express and positive (which may be oral, in writing or electronic) or implied (such as by using our products or services or by not responding to our offer to remove your personal information from our marketing lists), in which case we assume that you consent. Consent may be given by your authorized representative. You may withdraw your consent at any time as long as you give reasonable notice of withdrawal.


Withdrawal or refusal of consent is subject to legal and contractual restrictions. Minett can collect, use or disclose your personal information for legal, security or certain processing reasons when authorized by law. For example, we must provide your personal information in response to a search warrant or other legally valid enquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law.


If you prefer to be removed from the investor relations mailing lists used to supply you with investor information, you have the opportunity to opt-out by contacting us in the manner set out below. You are free to opt-out from our investor relations lists at any time, allowing a reasonable time for withdrawal. By opting out you may limit our ability to offer you certain investor information, services or benefits.


Security of personal information

We will maintain your personal information in secure data storage to safeguard it from unauthorized access, use or disclosure. We will maintain the strict confidentiality of all personal information collected, and will only disclose such information to employees and service providers of Minett who require such information for the purposes set out above. We have entered into agreements with our service providers to safeguard the personal information in their possession. We will only keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. We will keep personal information that is in our possession or control accurate, complete and up to date as is necessary for the purposes for which it is used. The Act prevents the routine updating of personal information unless such updates are necessary for the purposes initially agreed to be the individual.


Third-party website links

Our websites may contain links to third-party websites. Any such, these websites are not under Minett’s control, and Minett does not assume any responsibility for the manner in which the operators of such third-party websites may treat any personal information you provide to them. We strongly encourage you to read the privacy statements of all such third-party websites as their policies may be materially different from this Privacy Policy.


Accessing your personal information

You have the right to reasonable access to your personal information in our possession or control and to request rectification of any personal information that may be obsolete, incomplete or incorrect. To assist your request, you can obtain the Access to Personal Information Request form from us by contacting us by email, or you can make the request by letter or telephone if you prefer. We may charge you an administration fee for providing access to your file in accordance with the nature of your request. Normally, we will respond to access or rectification requests within 30 days.