Privacy Policy

Effective Date: February 9, 2025

Reviewed By: Chief Privacy Officer, Lankin Investments

Our Commitment to Privacy

Lankin Investments (“Lankin”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of our investors, prospective investors, employees, partners, and other individuals who engage with us. We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws.

 

This Privacy Policy outlines how we collect, use, disclose, and safeguard personal information in the context of delivering our investment services and managing our business operations in Canada.

What Is Personal Information?

Personal information” refers to details about an identifiable individual. It includes both factual and subjective data that may reveal an individual’s identity. Examples include:

 

  • Name, address, and contact details

  • Date of birth and government-issued ID

  • Employment and income details

  • Investment experience and objectives

  • Banking and financial information

  • Social Insurance Number (SIN) or Tax Identification Number (TIN)

  • Communications and correspondence records

 

This policy excludes business contact details used solely for professional communication.

Why We Collect Personal Information

We collect personal information to operate our business, fulfill legal obligations, and provide a high standard of
service to clients and employees. These purposes include:

 

For Investors and Clients:

  • Verifying identity and investor eligibility

  • Processing transactions and capital contributions

  • Communicating portfolio updates and distributions

  • Fulfilling KYC/AML and tax reporting obligations

  • Responding to inquiries and providing client support

  • Offering new investment opportunities (where consent is given)

 

For Employees and Employment Candidates:

  • Determining initial employment eligibility

  • Verifying references and qualifications

  • Administering compensation and benefits

  • Processing employment-related claims (e.g., WSIB, insurance)

  • Coordinating training and professional development

  • Managing performance evaluations and setting expectations

  • Supporting disciplinary processes or terminations

  • Maintaining emergency contact records

  • Meeting obligations under labour and securities legislation

  • Managing organizational charts and internal directories

  • Ensuring the integrity and security of company-held data

 

Failure to provide certain information may restrict our ability to deliver services or establish employment.

Types of Personal Information We Collect

Prospective Investors

When evaluating investment suitability, we may collect:

  • Full name and birth date

  • Residential address and contact information

  • Employment and financial background

  • Investment objectives and risk preferences

  • SIN or TIN (for tax reporting)

  • Identification for verification

  • Advisor or referral details (if applicable)

 

Investors

For investors with active positions, we maintain:

  • Investment documents and transaction records

  • Banking details for payments

  • Signed declarations and risk disclosures

  • Tax documents (T5, T5013, NR4, etc.)

  • Investor correspondence and updates to profiles

 

Employee Personal Information

We also collect personal information from employees and job applicants as part of our employment lifecycle.

This includes:

  • Contact information and emergency contact details

  • SIN and date of birth

  • Education, resume, and employment history

  • Banking details for payroll

  • Benefits, health, and disability data (where applicable)

  • Performance reviews and disciplinary records

  • Compliance, certifications, and training logs

  • Any other information necessary to fulfill employment or legal obligations

 

Sources of Information

We gather personal information from:

  • Direct submissions via forms, email, phone, or portal

  • Your financial or investment advisor

  • Verification documents you provide

  • Publicly available databases (e.g., corporate registries)

  • Third-party partners (e.g., custodians, auditors, CRM vendors)

 

All collection methods are consistent with Canadian privacy laws.

Cookies and Online Tracking

Our website and investor portals use cookies and other tracking tools to:

  • Store login credentials and session data

  • Monitor site activity and usage analytics

  • Enhance performance and personalization

  • Provide targeted content (with consent)

  • Ensure site security

 

Users can manage cookie preferences in their browser settings. Disabling cookies may limit access to certain
features.

Retention and Destruction of Personal Information

We retain personal information only as long as necessary to fulfill intended purposes or comply with legal and
regulatory requirements. For example:

  • Investor records are retained for at least 7 years post-investment

  • Tax and compliance documents follow CRA retention schedules

  • Unsuccessful investment inquiries are stored for up to 24 months

Information no longer needed is securely deleted, anonymized, or destroyed.

Disclosures and Consent

We may share your personal information with employees, contractors, consultants, or service providers who
require it for legitimate business purposes, including investment management, operations, and employment
administration.

 

Personal information may be disclosed or transferred during a business transaction such as a sale of assets,
merger, or joint venture. Any acquiring party will be required to adhere to this Privacy Policy unless you provide
alternative consent.

 

We may also disclose personal information to Canadian securities regulators (e.g., Ontario Securities Commission)
as part of regulatory filings such as exempt distribution reports. These filings may include your name, address,
security class, number of units, and invested capital.

 

In some cases, your personal information may be disclosed without consent:

  • Where required by law or a regulatory body

  • In response to court orders, subpoenas, or lawful investigations

  • To protect the rights or property of Lankin Investments

  • In emergencies where health or safety is at risk

  • If the information is publicly available

  • With your consent when legally required

 

We may also collect or disclose your personal information without notifying you when permitted under
applicable privacy laws.

 

Where consent is required, we assume—unless otherwise instructed—that you consent to the collection, use, and
disclosure of your personal information for the stated and reasonably implied purposes.

Breach of Security Safeguards

Despite best efforts, data breaches can occur. If your personal information is affected:

  • We will assess the breach and its potential impact

  • Notify you if the incident creates a real risk of significant harm

  • Report the breach to the Office of the Privacy Commissioner of Canada when required

  • Log and retain a record of the breach for a minimum of 24 months

  • Take remedial action to prevent recurrence

We are committed to transparency and prompt response.

Your Rights & Access to Personal Information

Under Canadian privacy laws, you have the right to:

  • Request access to personal data we hold about you

  • Request corrections to inaccurate or incomplete data

  • File a complaint if you believe your information has been mishandled

How to Submit a Request or Complaint

To request access, corrections, or raise a concern, contact:

 

Privacy Officer

Lankin Investments

6220 Hwy 7, Suite 500, Woodbridge, ON L4H 4G3

Email: inquiry@lankin.com

Phone: 905-452-1305

Website: www.lankin.com

 

We may request verification of identity to protect your privacy. Responses will be issued within 30 days
unless an extension is necessary, in which case we will inform you of the delay.

 

You may also contact:

 

Office of the Privacy Commissioner of Canada

30 Victoria Street

Gatineau, Quebec K1A 1H3

Website: www.priv.gc.ca

Phone: 1-800-282-1376