1. 1. Any electronic mail you receive from an employee or representative of Cidel Bank and Trust Inc, (“Cidel”) or any subsidiaries, including any attachments thereto (“the email”), is subject to the Cidel e-mail disclaimer (“disclaimer”) as set out herein.
   2. The email may contain information which is confidential and private in nature. If you are not the stated addressee (or such person authorized representative) you must –

• • • notify the sender of this fact immediately by return e-mail, fax or telephone and delete the email from your system;
    • refrain from printing, copying, forwarding or otherwise disclosing any information contained in the email or any part thereof; and
    • refrain from reading, storing, using, selling or incorporating any information contained in the email into any database or mailing list for whatever reason, including for purposes of spamming or marketing.

Failure to do so may amount to the unlawful interception of a communication, the infringement of copyright and/or the infringement of the right to privacy.

1. 1. Neither Cidel, the sender of the email, or any other Cidel representative shall be liable for any loss, damage or expense of whatever nature (including without limitation that caused by the corruption or loss of data, damage to software programs and interruption of business operations) resulting directly or indirectly from the transmission of the email (including without limitation any malicious software code or viruses transmitted together with the email or any corruption to or loss of data contained in the email).
   2. The views and opinions expressed in the email do not necessarily reflect the views and opinions of Cidel. In particular, no Cidel representative or employee may send:

• • • unsolicited commercial messages (“spam”)
    • messages that infringe any third party’s copyright, trademarks or other rights and interests (“infringing content”) and
    • messages containing content that is offensive, derogatory, defamatory or otherwise unlawful (“offensive content”)

If the email constitutes spam, contains infringing content or offensive content, or was otherwise sent for purposes unrelated to the official business of Cidel, Cidel shall not be liable for any loss, damage or expense of whatever nature resulting therefrom.

1. Cidel reserves the right to read, monitor, access, block, delete, copy or otherwise intercept any email sent in reply to the email.
2. Where the time or date on which the email was transmitted is in issue, unless the content thereof expressly provides otherwise, Cidel will be deemed to have-
   • sent the email once reflected as “sent” on our mail servers; and
   • received an email once reflected as “received” on our mail servers
3. The disclaimer shall be governed by and interpreted in accordance with the laws and regulation of the country or territory that has the right to exercise jurisdiction over the matter. Jurisdiction of the applicable region shall supersede any terms contained in any email received by Cidel, insofar as these conflict with this disclaimer.

By accessing this Website, you acknowledge these terms of use and agree to be bound by them.  Cidel Bank & Trust Inc. (including its subsidiaries and affiliates, “Cidel”) reserves the right, in its sole discretion, to modify, alter or otherwise update these terms of use at any time and you agree to be bound by such modifications, alterations or upgrades.

Cidel is not responsible in any manner for direct, indirect, special or consequential damages, however caused, arising out of your use of this Website and/or any web browser, including any damages you may suffer if you transmit confidential or sensitive information to us or if we communicate such information to you at your request over the Internet. Links to other websites from this Website are for convenience only. No endorsement of any third party products, services or information is expressed or implied by any information, material or content referred to or included on, or linked from or to this Website.  This Website and the information is provided “as is”.  Cidel does not warrant the accuracy, adequacy, timeliness or completeness of this Website or Website information and disclaims liability for any errors or omissions.  No warranty or condition of any kind is given in the Website or Website information.  Cidel does not warrant that the Website will be available and meet your requirements, that access will be uninterrupted, that there will be no delays, difficulties in use, defects, incompatibility, failures, errors, omissions or loss of transmitted information.

Certain names, words, titles, phrases, logos, icons, graphics or designs, or other content on the Website are trademarks or trade names owned by Cidel or its subsidiaries.   Nothing on this Website shall be construed as conferring any license of any intellectual property rights, whether by estoppel, implication or otherwise.  Except when otherwise stipulated, the information otherwise may not be copied, displayed, distributed, downloaded, licensed, modified, published, reposted, reproduced, reused, sold, transmitted, used to create a derivative work or otherwise used for public or commercial purposes with the express written consent of Cidel or its subsidiaries.  Any unauthorized downloading, re-transmission, or other copying or modification of trademarks and/or the content of the Website may be a violation of federal or other law that may apply to trademarks and/or copyrights, and such actions could subject the copier to legal action.

In compliance with the Bank Act and the Trust and Loans Companies Act, the following offices have been designated by Cidel Bank & Trust Inc., Cidel Bank Canada, Cidel Asset Management Inc., Cidel Trust Company, and Cidel Pty Ltd. for the service of enforcement, including for Canada Revenue Agency and Family Maintenance and Support Orders.

Cidel (Pty) Ltd.
32 Impala Rd
Chislehurston
Sandton, 2196
South Africa

Cidel Bank & Trust Inc.
Cidel Place
Lower Collymore Rock
St. Michael
Barbados

Attention: Legal Department

Cidel Trust Company
Vintage Towers 1
Suite 403, 322-11th Avenue SW
Calgary, Alberta
T2R 0C5
Canada

Attention: Legal Department

Cidel Bank Canada
60 Bloor St. West 9th Floor
Toronto, ON M4W 3B8
Canada
Attention: Legal Department

Cidel Bank & Trust Inc. (“CBTI”) is a Foreign Currency Earning Bank that designs and implements customized financial solutions to help clients build, reserve and transfer wealth.  With a strategic network of operations in Canada and internationally, its broad range of investment and structuring capabilities provide clients with solutions that are global and innovative.  Most of these activities are carried out by CBTI’s subsidiaries, Cidel Trust Services Ltd (CTSL) and Cidel Financial Inc. (CFI), herein refer to ‘Cidel’.

CBTI is licensed and regulated by the Central Bank of Barbados and is subject to the Financial Institutions (Amendment) Act 2018-51.  The Board of Directors, Audit Committee, senior management and employees of Cidel are guided by internal policies as well as the Money Laundering and Financing of Terrorism (Prevention and Control) (Amendment) Act 2019, the Anti-Terrorism (Amendment) Act, 2019 and the Anti-Money Laundering (AML) / Combating Financing of Terrorism (CFT) Guidance Note issued by the Central Bank of Barbados in conjunction with the Anti-Money Laundering Authority, issued October 2006 and revised November 2021.

The Barbadian subsidiaries are subject to the same AML legislation and Guidelines as CBTI.  The asset management business is undertaken by CFI as a Securities Company and Investment Advisor.  It is licensed by the Financial Services Commission.  CTSL, the fiduciary arm of the business, is subject to the Corporate Trust and Services Providers Act and is regulated by the International Business Unit.

Cidel is required to take reasonable and appropriate measures to establish the identities of their clients (entity and individual) including all beneficial owners and to open accounts and conduct transactions only after identity is verified to our satisfaction.  These measures are also applicable to Cidel’s relations with custodians, correspondent banks, professional intermediaries, investment advisors and agents.

Money laundering and Financing of Terrorism and Proliferation are criminal offences in Barbados and in many other jurisdictions of which business is undertaken.  Cidel is committed to preventing the use of its business for such purposes, by establishing policies and procedures to ensure that:

• Business acceptance polices are in place for identification and approval of new business.
• A senior employee has been designated the Chief Compliance Officer and the Money Laundering Reporting Officer.

The various regulatory agencies issue guidelines periodically and Cidel will update its policies and procedures to ensure compliance with them by considering the nature and scale of its business, complexity, volume and size of activities and the degree of risk associated with each area of its operations.

An independent AML review is conducted every two years by an external party and the results are reported to the Board of Directors and the various regulatory agencies.  From time to time, CBTI and its subsidiaries are also subject to regulatory inspections which involve assessing their risk management and AML framework.

December 31, 2023

At Cidel Financial Inc., we are committed to maintaining the highest standards of transparency and trust with our valued clients.  As part of our ongoing commitment to clear communication, we provide online access to the important documents that govern our relationship with you.  Your Discretionary Management Agreement, or Non-Discretionary Management Agreement, is essential for understanding the terms and conditions under which we will manage your accounts.  Whether you are a new client to Cidel or revisiting your existing agreements, we encourage you to review these documents carefully.

Click here to download the Discretionary Management Agreement

Click here to download the Non-Discretionary Management Agreement

Click here to download the Conflicts of Interest Disclosure

Click here to download the Complaint and Dispute Resolution

Barbados signed the Multilateral Competent Authority Agreement (MCAA) on October 29, 2015 and joined over 100 jurisdictions participating in the Convention, who have agreed to embrace the Automatic Exchange of Information standard which sets out the due diligence and reporting rules to be applied to nancial institutions of participating jurisdictions. This OECD initiative encourages governments around the world to implement greater cross border tax compliance, transparency and cooperation, with the ultimate goal to reduce tax evasion through enhanced information reporting.

Click here to download Controlling Person Tax Residency

Click here to download Entity Self-Certication for FATCA and CRS

Click here to download Individual Self-Certication for FATCA and CRS

Click here to download the South Africa Mandate

This policy has been established by Cidel Bank Canada, Cidel Asset Management Inc. and Cidel Trust Company (collectively referred to as ‘Cidel’) in light of the obligations arising under the Accessibility for Ontarians with Disabilities Act, 2005 (the ‘Act’), and in consideration of the Integrated Accessibility Standards O.Reg 191/11 (the ‘Regulation’).

Cidel strives to meet the needs of persons with disabilities and has implemented standards to break down barriers and increase accessibility in areas of information and communication, employment, and customer service.

Cidel is committed to ensuring equal access and participation for people with disabilities, and to treating all people in a way that allows them to maintain their dignity and independence.

Cidel believes in integration and equal opportunity. We are committed to meeting the needs of people with disabilities by preventing and removing barriers to accessibility in a timely manner, and by satisfying the accessibility requirements under the Act and the Regulation.

Cidel’s Accessibility Plan sets out how we achieve accessibility by satisfying the requirements of the Regulation, and further provides strategic guidance on how we aim to improve accessibility and opportunities to Ontarians with disabilities. This plan is reviewed and updated at least once every 5 years, and a copy of the Accessibility Plan will be provided in an accessible format upon request. Please see the table below for the most recent Accessibility Plan.

Cidel ensures that training is provided to its directors, officers, employees and agents on the requirements under Ontario’s accessibility laws, and on the Ontario Human Rights Code, as it pertains to persons with disabilities. Training will be provided in a format that is suitable and appropriate to the duties of the recipients.

In accordance with the Regulation, Cidel will continue taking steps to ensure directors, officers, employees and agents are provided with appropriate training by:

• Adhering to the ongoing training requirements under the Act, Regulation, and the Ontario Human Rights Code, as it pertains to persons with disabilities;
• Ensuring training content is appropriate and relevant to address changes in the workplace;
• Providing training to new employees, and all employees whenever changes are made to the Accessibility Policy, as soon as practicable; and
• Maintaining a record of the training provided, including training dates, and the number of individuals in attendance.

Cidel’s training program is completed by all directors, officers, employees and agents on an annual basis and covers the following topics:

• The purpose and requirements of the Act and accompanying Regulations.
• How to interact and communicate with people with various types of disabilities.
• The purpose of assistive devices, and how to interact with people that use them.
• The purpose of service animals and how to interact with people that use them.
• The purpose of support persons, and how to interact with people who are accompanied by a support person.
• What to do if a person with a disability is having difficulty accessing Cidel’s services.

Cidel is committed to meeting the communication needs of people with disabilities, and shall consult with persons with disabilities to determine their information and communication needs.

In the event that information or a communication distributed by Cidel cannot be converted to an accessible format, it shall provide the person requesting the information or communication with an explanation as to why the information or communication cannot be converted, and a summary of relevant information or communication.

Feedback

Cidel will continue to ensure that its process for receiving and responding to feedback is accessible to persons with disabilities by providing, or arranging for the provision of, accessible formats and communication supports upon request. As a part of this process, we will identify existing feedback processes and review them for accessibility purposes. Wherever necessary, Cidel will take steps to remove barriers to accessibility, in a timely manner, once they are identified.

Accessible Format and Communication Supports

Upon request, Cidel will provide, or will arrange for the provision of accessible formats and communication supports which account of the person’s accessibility needs due to disability. Cidel will consult with the person making the request in determining the suitability of an accessible format or communication support.

Accessible Website and Web Content

Cidel ensures that its website, including all of its web content, conforms to the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, at Level AA, except where this is impracticable.

Cidel is committed to fair and accessible employment practices. The Ontario Employment Standards Act, 2000 builds upon the existing requirements under the Ontario Human Rights Code, 1990 in relation to accessibility at all stages of the employment cycle.

Recruitment

Cidel will continue taking steps to notify applicants, the public and its employees that accommodations will be made available upon request to persons with disabilities during the recruitment and assessment process, in relation to the materials or processes to be used, and when people are hired.

Where a request for accommodation is received, Cidel will consult with the person to provide, or arrange to provide, suitable accommodations in a manner that takes account of the person’s accessibility needs due to disability.

When an offer of employment is made, Cidel will notify the successful applicant of its policies for accommodating employees with disabilities.

Informing Employees of Supports

Cidel will continue to inform its employees of the policies, and any updates thereto, that are used to support employees with disabilities. This includes policies on the provision of job accommodations which account for an employee’s accessibility needs due to disability. This information will be provided to new employees as soon as practicable after commencing employment.

Accessible Formats and Communication Supports for Employees

Upon request by an employee with a disability, Cidel will provide, or arrange for the provision of, accessible formats and communication supports for information that is required to perform the employee’s job, and information that is generally available to other employees in the workplace. In determining the suitability of an accessible format or communication support, Cidel will consult with the employee making the request.

Workplace Emergency Response

Cidel will provide individualized workplace emergency response information to employees where it is required due to the employee’s disability. If an employee with an individualized workplace emergency response plan requires assistance, with the employee’s consent, Cidel will ensure that a designated person is available to assist the employee. Cidel will provide this information as soon as practicable after becoming aware of the need for accommodation.

Cidel will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed, and when Cidel reviews its general emergency response policies.

The Company will review the individualized workplace emergency response information when the employee moves to a different location in the organization, when the employee’s overall accommodations needs or plans are reviewed, and when The Company reviews its general emergency response policies.

Individual Accommodation Plans

Cidel will develop individual accommodation plans for employees with disabilities in accordance with its established process.  Where requested or required, an employee’s individual accommodation plan will include any information regarding the provision of accessible formats and communications supports, as well as any individualised workplace emergency response information.

Return to Work Process

Cidel will develop a process for an employee returning to work after being absent due to disability, and requires disability-related accommodations in order to return to work. This process involves documenting the steps Cidel will take to facilitate the employee’s return to work, and will include an individual accommodation plan for the employee.

Performance Management, Career Development and Advancement & Redeployment

Cidel will account for the accessibility needs and individual accommodation plans of employees with disabilities when conducting performance management processes, providing career development and advancement opportunities to employees, or when redeploying employees.

Cidel is committed to service excellence, and is mindful of the principles of independence, dignity, integration and equal opportunity when engaging with persons with disabilities. Cidel recognises that persons with disabilities may require the use of assistive devices, such as communication aids or personal mobility aids, and wherever possible Cidel will make accommodations to ensure that persons with disabilities can access our services and facilities.

Cidel welcomes clients with disabilities that are accompanied by support persons, or assisted by service animals in our offices.

Cidel will ensure that our employees are trained and familiar with various assistive devices or supports that may be used by clients with disabilities, in accordance with our internal policies and procedures. A copy of these documents will be made available upon request.

Notice of Temporary Disruptions

In the unlikely event that Cidel experiences a disruption in the provision of its services, we shall provide clients with a disability who use the service notice of the disruption, details of the cause, its anticipated duration and a description of alternative facilities or services that will be made available in the interim.

Feedback Process

Cidel is committed to delivering the highest level of service to all of our clients. As a result, feedback from clients regarding the delivery of service to persons with disabilities may be given in confidence by telephone, in person, in writing or alternative methods through the following:

Email:    hr@cidel.com

Mail:      Cidel Asset Management

60 Bloor Street West

Toronto

ON M4W 3B8

Telephone:  (416) 925 5504 (Please ask for Human Resources)

Part I – General

Part 2 – Information and Communications Standards

Part 3 – Employment Standards

Part 4 – Customer Service Standards

Each Cidel entity (“Cidel”) is committed to ensuring that its internal policies, practices, and systems are free of barriers, emphasize the value of diversity, and promote full participation to ensure dignity, respect, and equal access for all employees.

Through our processes and practices, we are working to eliminate barriers to employment for people who are usually underrepresented in Canada’s workforce – Aboriginal people, people with disabilities, racialized persons, and women.

Consistent with human rights legislation, employment equity recognizes the value and dignity of each individual and ensures everyone has genuine, open and unhindered access to employment opportunities, free from any barriers, systemic or otherwise.

Cidel’s established employment equity statement reflects this:

Cidel is committed to equity in its policies, practices, and programs, supports diversity in employment, learning and work environments, and ensures that applications from members of underrepresented groups are seriously considered under its employment equity policy. All qualified individuals who would contribute to the further diversification of Cidel are encouraged to apply.

Click here to download the External Privacy Policy

Click here to download Relationship Disclosure Information.

Click here to download the Trade Matching and Settlement Statement

Click here to download the CBC/CTC Complaint and Dispute Resolution.

For the CAM Complaint and Dispute Resolution please reference our Relationship Disclosure Information above.

Number of Complaints dealt with by the Complaints Officer – 0

Number of Complaints resolved by the Complaints Officer – 0

Average length of time (in days) taken by the Complaints Officer to deal with a complaint – 0

March 27, 2024

FORM CRS RELATIONSHIP SUMMARY FOR CIDEL ASSET MANAGEMENT INC.

Item I: INTRODUCTION

The name of our firm is Cidel Asset Management Inc. and we are registered as an investment adviser with the SEC. It is important for you to understand that investment advisory fees and brokerage fees are different from one another. You may wish to avail yourself of free and simple tools that are available to you for the purposes of researching our firm as well as other firms and financial professionals at Investor.gov/CRS, which also provides information about broker-dealers, investment advisers, and investing in general.

Is an Investment Advisory Account Right for You?

There are different ways you can get help with your investments. You should carefully consider which types of accounts and services are right for you. We are an investment adviser and provide investment advisory services rather than brokerage accounts and services. This document gives you a summary of the types of services we provide and how you pay. This document also provides specific questions you may want to ask us to understand our services in greater detail.

Item II: RELATIONSHIP AND SERVICES

What investment services and advice can you provide me?

We provide investment advice to our clients on either a discretionary and non-discretionary basis to managed accounts through the use of a range of in-house and third party portfolio managers that invest in both traditional and alternative assets If you select to open an account with us on a discretionary basis, we will be responsible for making all of the investment decisions for your account, in accordance with your stated investment objectives, without providing contemporaneous notification or consent to or from you. If you elect to open an account on a non-discretionary basis, we must receive your consent prior to making any transactions in your account. The nature and terms of your account will be agreed upon and memorialized in your investment advisory agreement (“IMA”) with us. Our advice may involve us providing you with asset allocation and the selection of investments. The advice we provide is guided by your stated investment objectives (i.e., maximum capital appreciation, growth, etc.). The process we use with respect to opening and maintaining your account starts with establishing and monitoring your appropriate asset allocation. Your risk tolerance and financial objectives will be considered in tailoring an asset allocation that is suitable to you. This allocation will primarily include equities, fixed income and cash equivalents, but may from time to time include other asset classes or products. Primary emphasis will be on large capitalization, publicly traded, domestic and international common stocks. We will review your account on at least a monthly basis to ensure it is being maintained in accordance with your stated investment objectives. There is currently no minimum amount required in order to open an account with us. Please see our ADV Part 2A (“Brochure”) that contains greater details about the firm’s services, personnel, risks and policies at: https://adviserinfo.sec.gov/firm/summary/172640

We believe it is important for you to understand your account, its terms and limitations and our mutual relationship thoroughly. It is in this connection that we should have a conversation where we, at minimum, help you to understand the answers to the following questions:

*Given my financial situation, should I choose an investment advisory service? Why or why not?

*How will you choose investments to recommend to me?

*What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?

Item III: FEES, COSTS, CONFLICTS AND STANDARD OF CONDUCT

What fees will I pay?

Your account will be charged a negotiable, asset-based management fee typically ranging from an annualized 0.10% to 1.75%. The management fee is agreed upon and memorialized in your IMA with us and is generally paid on a monthly or quarterly basis. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. The main conflict that exists between our interests and yours is that the greater the assets in your account, the greater the management fee we will collect; we, therefore, have an incentive to encourage or facilitate the increase of assets in your account.

*Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

*What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?

Standard of Conduct When we act as your investment adviser, we have to act in your best interest and not put our

interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means. For a more detailed list of risks and conflicts related to your account or your relationship with the firm, please see the firm’s Brochure that can be accessed using the link provided in Item II above.

*How might your conflicts of interest affect me, and how will you address them?

*How do your financial professionals make money?

We make money solely based on our collection of the management fee described in Item III above. The management fee we assess to your account is based on the amount of assets we advise on your behalf; the greater amount of assets, the greater the management fee we collect. While we will typically collect the management fee whether your account generates a positive or negative return, it is in our best interest for your account balance to increase.

Item IV: DISCIPLINARY HISTORY

Do you or your financial professionals have legal or disciplinary history?

No. However, we welcome you to visit Investor.gov/CRS for a free and simple search tool to research our firm and our financial professionals.

As a financial professional, do you have any disciplinary history? For what type of conduct? 

Item V: ADDITIONAL INFORMATION

Should you wish to obtain additional materials about us and/or the services we provide, please see our Brochure that can be accessed using the link provided in Item II above. If you wish to receive a copy of this Relationship Summary or other available, up-to-date information regarding our firm, please call us at + 416-925-4047 or email us at BTAMBLYN@CIDEL.COM.

Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?

Your primary contact person at the firm is the firm’s Chief Compliance Officer, Bryan Tamblyn. He can be reached at either the phone number or email address listed above in Item V.

This notice is provided with respect to the following investment funds managed by Cidel Asset Management:

• Cidel Absolute Return Master Fund (BVI) L.P.
• Cidel Alternative Income Master Fund (BVI) L.P.
• Cidel Credit Opportunities Master Fund (BVI) L.P.
• Cidel Enhanced Absolute Return Master Fund (BVI) L.P.
• Cidel Private Markets Master Fund (BVI) L.P.

Introduction 

The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Act (As Revised) (the “DPA”).

In this document, “we”, “us” and “our” refers to each Purchase Fund, the Manager, the General Partner and its or their affiliates and/or delegates.

Investor Data 

By virtue of making an investment in each Purchase Fund and your associated interactions with us (including any subscription (whether past, present of future), including the recording of electronic communications or phone calls where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPA (“Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.

In our use of Investor Data, each Purchase Fund will be characterised as a “data controller” for the purposes of the DPA. Each Purchase Fund’s affiliates and delegates may act as “data processors” for the purposes of the DPA.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

How We May Use Your Personal Data

Each Purchase Fund, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:

1. where this is necessary for the performance of our rights and obligations under the Subscription Agreement and/or the constitutional and operational documents of each Purchase Fund;
2. where this is necessary for compliance with a legal and regulatory obligation to which each Purchase Fund is subject (such as compliance with anti-money laundering and FATCA/CRS requirements); and/or
3. where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Additionally, NAV Consulting, Inc., doing business as NAV Fund Administration Group, and NAV Fund Services (Cayman) Ltd. (each and together, the “Administrator”), may use Investor Data, for example to provide its services to each Purchase Fund or to discharge the legal or regulatory requirements that apply directly to it or in respect of which each Purchase Fund relies upon the Administrator, but such use of Investor Data by the Administrator will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.

Further explanation regarding how the Administrator may handle Investor Data is set out in its privacy notice, which is available at https://www.navconsulting.net/Privacy

Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

Why We May Transfer Your Personal Data

In certain circumstances we and/or our authorised affiliates or delegates may be legally obliged to share Investor Data and other information with respect to your interest in each Purchase Fund with the relevant regulatory authorities such as the British Virgin Islands Financial Services Commission or the International Tax Authority.

These authorities, in turn, may exchange this information with foreign authorities, including foreign tax authorities.

We anticipate disclosing Investor Data to parties who provide services to each Purchase Fund and their respective affiliates (which may include certain entities located outside the British Virgin Islands or the European Economic Area). Such parties include the following who may either process personal data on our behalf or for their own lawful purposes in connection with services provided to each Purchase Fund.

1. the Administrator; and
2. the Manager.

The Data Protection Measures We Take

Any transfer of Investor Data by us or our duly authorised affiliates and/or delegates outside of the British Virgin Islands shall be in accordance with the requirements of the DPA.

We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Investor Data, and against loss, misuse, modification, unauthorised or accidental access or disclosure, alteration or destruction of Investor Data.

We shall notify you of any Investor Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.

Getting In Touch

Should you have any queries or wish to discuss your data protection rights with us, please contact Bryan Tamblyn, Chief Compliance Officer at Cidel Asset Management (email: btamblyn@cidel.com / phone: +1 (416) 925-4047).