Privacy Policy

Spartan Fund Management Inc. (“Spartan”) is committed to maintaining the highest level of confidentiality regarding the sensitive personal information that our investors share with us, in accordance with applicable privacy laws. Commercial companies within Canada are governed by the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), and/or provincial privacy legislation in British Columbia, Alberta and/or Quebec. In general, the purpose of this privacy legislation is to regulate the private sector’s collection, use and disclosure of personal information.


In response to the requirements of this privacy legislation and to further reinforce our commitment to the safeguarding of your personal information, we have formally summarized our privacy practices in this privacy statement which briefly outlines how we manage the personal information of our clients.


Collection, use and disclosure for the Purposes. We collect and use your personal information (generally, your name, address and telephone number, birth date, social insurance number or driver’s license number, as well as your financial and investment information) for the purposes to which you consent, as identified at the point we collect your personal information, and as otherwise permitted or required by applicable law. These purposes generally are to properly identify you and to establish and administer your account (including without limitation to execute your transactions and to maintain, store, record and determine your account holdings and transaction records; to verify previously given information when necessary; to provide you with account statements, financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account); to satisfy legal, regulatory, custodian and tax reporting requirements; to the extent that you consent to same, to develop additional products and services, and to offer our additional products and services, or those of third parties, to you, in each case that we feel may be of interest to you; and as otherwise permitted or required by applicable law (the “Purposes”). We disclose your information to service providers which provide services to Spartan in connection with the Purposes. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential acquiror in connection with a transaction involving the sale of some or all of the business of Spartan or as otherwise permitted or required by law, in which case the use of your personal information by the new entity would continue to be limited by applicable law.


How we collect your Personal Information. We receive personal information typically at the time of account opening, either through the application process, by means of verbal consent, or in some form of disclosure document. This could be done electronically, via direct meetings and telephone conversations with you, or by an investor registering on Spartan’s website ( There may be occasions when personal information is collected from your advisors or dealers, credit bureaus or other financial institutions. In these instances we would ensure any consent required from you has been obtained before collecting, using and/or disclosing your personal information. We keep on file only information that is necessary.


Storage/processing outside Canada. You acknowledge and agree that from time to time your personal information may be stored or processed outside of Canada, and while in such jurisdiction(s) it may be subject to access by regulatory authorities pursuant to the laws of such jurisdiction(s).


Access to and Rectifying Your Personal Information. The file containing your personal information will be made available to the authorized employees, contractors or agents of Spartan who need to access the information in connection with the Purposes. The personal information will be held primarily in an electronic database. You have a right to access and rectify the information contained in the file held about you and in order to exercise this right, or if you have any questions, comments or concerns about this Privacy Statement please do not hesitate to contact the Privacy Officer at the address below:


Gary Ostoich, Privacy Officer
Spartan Fund Management Inc.
100 Wellington Street West
Suite 2101
Toronto, ON M5K 1J3