Last update: June 1, 2023

Terra Fund Management Ltd. (“Terra”) recognizes the importance of protecting the privacy and confidentiality of personal information in our possession and control. In accordance with federal legislation called Personal Information Protection & Electronic Documents Act (“PIPEDA”) this Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which Terra collects, uses, discloses and otherwise treats personal information through our website (“Terra Site”) available at www.terrafunds.ca, as well as through other interactions with our clients and prospective clients.

What is personal information?

The personal information collected is any information that identifies you as an individual or corporation resident in Canada.

Why do we collect personal information?

Terra collects information required to provide its services and meet income tax and regulatory requirements as required by law or Canadian securities regulatory bodies.

How do we collect personal information?

Terra through its affiliate, Linden Mills Investments Inc., collects personal information directly from you or through your registered advisor and dealer when you complete and submit a subscription agreement for the purchase of one of our funds. We record a client’s personal information electronically and/or in written form.

What personal information do we collect?

Collecting information that helps us understand your requirements, financial position, risk tolerance and other matters enables us to ensure that our investment recommendations are suitable. When you open an account or sign up for services, we collect personal information, often referred to as “Know Your Client” information which may include but is not limited to the following:

• Your name and date of birth
• Social insurance number (for tax reporting purposes)
• Address, phone and fax numbers, email address
• Nature of your employment or business
• Checking account information and optional beneficial information
• Investment knowledge, needs and objectives
• Risk tolerance
• Income, asset holdings and values
• Other information relevant to the services we provide

What other information do we collect?

We may also collect information when you visit the Terra Site to better understand website activity and to monitor and improve our website at www.terrafunds.ca. We collect information through a variety of methods, including the following:

A. Cookies

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. You can get more information about cookies at: http://www.allaboutcookies.org. This information is anonymous and is only used by Terra to measure and improve our website. You may set your browser to notify you when you receive a cookie, allowing you to decide whether or not to accept it. If you decide not to accept cookies from the Terra Site, you may not be able to access all the features offered by our website.

When sending e-mail we may use urls and tracking pixels urls to help us measure open rates for e-mails and link clicks. This tracking information is used internally only to help us provide relevant content and is never shared with any third parties.

B. Analytics

We use third party analytics tools, such as Google Analytics, to collect non-personal information using a tracking code when you use our website and/or services.

C. Online Advertising

We also use third party tools for online advertising to reach new potential clients and remarketing tools that allow us to target ads to specific groups of people who have previously interacted with our website. The third party tools may use cookies, tracer tags or web beacons to report certain information about the pages you visit on the Terra Site. Google allows individuals to opt out of it’s advertising cookies from its ad settings page. Google has additional information available about their Remarketing Privacy Guidelines, and Restrictions. You can learn more about the type of advertising at the Digital Advertising Alliance of Canada at www.youradchoices.ca/choices.

How is my personal information used?

The personal information we collect when you open an account is used for the following purposes:

• verifying your identity and other information you provided to us;
• help us determine if you qualify as an investor;
• help choose a suitable amount to invest;
• opening and servicing your account;
• meeting legal and regulatory requirements;
• sending statements and regular updates;
• sending tax information forms (T5013 forms);
• sending and receiving payments through your account;
• detecting and preventing fraud or other unauthorized activity;
• transferring your account to or from another institution; and
• as otherwise required and permitted by law.

Disclosure of Personal Information

We share only the information which is reasonably required in the normal course of business with third parties such as auditors, legal counsel, registrar and transfer agent, custodian, affiliates and agents to enable them to fulfill their obligations and assist us in providing the services you requested. We do not authorize our service providers to disclose your personal information for their own marketing or other purposes.

We or our third party service provider may disclose your personal information to securities regulators (in accordance with securities law) or law enforcement agencies in response to a request (subpoena or other legally valid inquiry or order) for a contravention of law or detecting, suppressing or preventing fraud. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required - otherwise we will seek your consent prior to disclosing any information. We may also provide your social insurance number to submit tax reports to Canada Revenue Agency. We shall not sell, distribute or lease your personal information to third parties unless we have your express written permission or are required by law to do so.

Links to third party websites

The Terra Site may contain links to other websites that we do not own or operate. Also, links to our website may be featured on third party websites on which we advertise. Except as provided herein, we will not provide any of your personal information to these third parties without your consent. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend you read carefully. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your personal information.

How do we store your information?

Terra may use third parties to store and process data. Terra will ensure that such third party service providers have the appropriate data and digital privacy policies and that data is stored and transmitted in encrypted format using technology such as SSL. Third party data storage and processing providers may be located in the United States or other jurisdiction and as a result personal information may be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.

Safeguards for protecting personal information

Terra maintains reasonable safeguards to protect personal information in our custody. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online or otherwise. We educate our employees about the importance of keeping a client’s personal information strictly private and confidential. We limit employee access to non-public personal information to those employees with a business need to know requirement for such information about you.

Third-party service providers, affiliates and agents will be required to adhere to strict confidentiality obligations and practices. Service providers have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.

Online access to your personal information is protected with a password you select. We strongly advise that you not disclose your password to anyone. We will never ask you for your password in any unsolicited communication including email messages, telephone calls or written communication.

We retain your personal information only as long as it is required for the reasons it was collected or as required by law.

You may update your personal information provided to us by logging into your online account, if any, or by sending a written request to:

Terra Fund Management Ltd.
101 - 51 Wolseley St. 
Toronto, ON M5T 1A4

If you have any questions, concerns or complaints about our privacy policy, please send your comments and your contact details to Tracey Pierson at tpierson@terrafunds.ca or by telephone at 416-203-2477 or toll-free at 1-888-449-4645.