Privacy Policy

At Triumph Asset Management Inc. (“Triumph”) we all recognize that personal information is private and confidential. Triumph’s Privacy Policy (“Privacy Policy”) governs Triumph’s collection, use and disclosure of personal information. It is the intention of Triumph, by way of this Privacy Policy, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Document Act (PIPEDA).

Triumph recognizes the following key principles of PIPEDA.

Accountability

Triumph acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all Triumph employees of the need to use the utmost discretion when dealing with client information. Triumph’s Privacy Officer has the responsibility to carefully analyze and alter collection procedures both on a preliminary and ongoing basis to assure maximum privacy protection.

Purpose

Triumph will only use client information for the purpose identified either before or at the time of collection. It is our policy that we will not sell your information.

Consent

Triumph will only use information for identified purposes and if the information is required for any new uses, Triumph will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by the client or a client-authorized representative.

Collection

Triumph will only collect information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation such as, the Money Laundering (Terrorist Financing) Act. Triumph’s employees will do their best to explain why collection of information is necessary in a clear and informative fashion.

Use, Disclosure and Retention

Triumph will only retain personal information as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individual's personal information is no longer required, Triumph will take the necessary measures to destroy, dispose of or erase the information in a manner that will ensure that information cannot be found or used by an unauthorized party.

Accuracy

Triumph strives to maintain accurate client information which not only help us provide better client client service but also minimizes the potential misuse of personal information.

Safeguards

Triumph understands the importance of protecting personal information and therefore, implements a number of safeguards against unauthorized access or improper disclosure. For example, Triumph’s computer network, employee computers, laptops, and phone message centres are all password protected. In addition, filing cabinet units and storage rooms containing personal information are locked and can only be accessed by authorized individuals. General entry to our office is secured and cannot be accessed by unauthorized personnel without permission.

Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continual maintenance and periodic overviews of our Privacy Policy and procedures. Triumph employees are subject to a strict code of conduct when it comes to personal information.

Directness

At Triumph we make our best efforts to inform our clients of our policies and procedures and to explain how we manage personal information. If you have additional questions or concerns, our Privacy Officer will do their best to assist you in understanding our policies and procedures.

Access

When requested and supported by sufficient identity information, Triumph will provide clients with their personal information as maintained in the client files. We recognize a clients right to their personal information, how their information is used and to the whom it is disclosed.

If an error or discrepancy is found in your personal information, we will act efficiently to correct the mistake in less than thirty days. An extension will only be applied if the request will unreasonably interfere with our business affairs.

Complaints and Recourse

Triumph’s Policy Officer will deal with any complaints or conflicts arising in regard to the collection, use and disclosure of personal information. In order to adequately address the complaint, all details will be recorded and a file will be created. All individuals involved will be notified of an enquiry into the complaint. Triumph’s Privacy Officer can provide clients with a more complete description of the recourse process. Individuals who are not satisfied with Triumph’s recourse can bring the complaint to the attention of the federal Privacy Commissioner.

The measures outlined in this Privacy Policy in order to abide by PIPEDA’s key principles are intended to provides clients with comfort that Triumph’s employees regard personal information with the utmost importance. The Privacy Policy is also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their information.

Website

Personal information collected by Triumph may be used to determine how many people the website and which sections of the website are visited most frequently. When you visit the website, move from page to page, or download content, the following information may be recorded: the address you are connecting from; which pages are visited; and what content is downloaded.

Certain Triumph employees will be provided with information about the website visitor in order to serve that visitor’s needs and provide the visitor with the information regarding specific products. Triumph employees are instructed to use strict standards of care in the handling of personal and confidential information.

Information obtained by registering on this website or attending a Triumph event will reside in an internal database at Triumph. If you wish to have your information removed from the Triumph database at any time, please click here to email your request or call Triumph’s Privacy Officer, Ornella Gubiani Parker at (416) 366-1947 for more information.

A complete version of PIPEDA can be found on the Department of Justice website.

Legal Information

Fund Performance and Offering Memorandum

Past performance does not guarantee future results. Net asset value and investment returns will fluctuate and there is no assurance that a fund can maintain a specific net asset value. Investors are cautioned that data based on less than three years’ experience may not be sufficient to establish a track record on which investment decisions can be based.

Units of Triumph Funds will be offered on a private placement basis (i.e. pursuant to exemptions from prospectus and registration requirements under applicable securities legislation) only to those persons where and to whom they may be lawfully sold and only by persons lawfully permitted to sell such units. This communication is not, and under no circumstances is to be construed as, a public offering to sell, or a solicitation of an offer to buy securities.

This site contains information about Triumph funds which is provided as a general source of information. Although every effort has been made to ensure that the material contained herein is accurate, Triumph does not guarantee its accuracy or completeness. As such, Triumph does not accept responsibility for any loss arising from the use or reliance on the information contained herein. An eligible investor should refer to the confidential offering memorandum, prospectus, or information statement, as the case may be, for a Triumph fund before deciding to purchase units of a Triumph fund. An eligible investor may obtain a copy of the offering memorandum, prospectus, or information statement by calling the Triumph office at (416) 366-1947.

Non-Canadian Investors

The information on this site is intended for Canadian residents. Triumph products are not offered in the United States and units of Triumph funds may not be purchased by any United States entity, either directly or indirectly. Units of Triumph funds will not be sold to any person residing outside Canada unless such sales are permitted under the laws of their jurisdiction. Investors should contact their financial advisors for more information.

Please click here for our Trade-Matching Statement.

© 2020 by Triumph Asset Management Inc.