Privacy Policy

42KM Investment Partners Ltd. appreciates the opportunity to help you meet your financial needs. Earning and keeping your trust is at the very core of our business. We are committed to respecting and protecting the privacy and confidentiality of the Personal Information you have entrusted to us. It is important for you to understand what Personal Information we will collect, how we will use it, and who may see it. Our Privacy Policy outlines our commitment to you. The Chief Compliance Officer (“CCO”) is the officer responsible for effective implementation and enforcement of Privacy Laws at 42KM IP (“the Firm”).

PRINCIPLES

Accountability

The CCO is responsible for ensuring daily compliance with the Privacy Policy. The CCO also ensures that any third parties who may provide services to The Firm, and, as a result, have access to personal information, are under an obligation to ensure compliance with this policy, especially with reference to safeguarding information and ensuring investors may have access to such information upon request.

Identifying Purposes

The purpose of collecting information regarding an individual will be identified and disclosed to the Client at or before the time that the information is collected. The Firm will only collect information necessary to fulfill the prior identified purpose. If information that was previously collected is to be used for a new use/purpose, the respective Client must consent to the new use/purpose, unless otherwise mandated by law. The Firm presently collects personal Client information for KYC, Suitability and AML documentation purposes.

Consent

An individual’s knowledge and consent is required prior to the collection of personal information. Such knowledge and consent is also required whenever personal information is to be used or disclosed for a different purpose from what was previously consented to by a Client. When obtaining consent from a Client, their reasonable expectations will always be considered and respected.

The Firm also assumes that individuals who invest in securities consent to the reasonable collection, use and disclosure of their personal information for those purposes. The Firm will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given (i.e. whether implied or formal consent is required). Clients are deemed to have provided consent when they personally, or through an authorized agent, volunteer to provide information.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

Limiting Collection and Retention

Personal information is retained to fulfill the intended purpose or in accordance with applicable laws or corporate policies. Notwithstanding this principle, all personal information will be retained for time periods set out under AML regulation, applicable securities regulation and other applicable legislation.

Accuracy

We are committed to maintaining the accuracy of your Personal Information and ensuring that it is complete and up-to-date. If you discover inaccuracies in our records, or your Personal Information changes, please notify us so that we can make the necessary changes. Failure to notify us of changes to your Personal Information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Information that we may have released to them.

Safeguards

We use physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control. The security safeguards protect such information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

Third party service providers who have access to personal information will be required to confirm that they have adequate safeguards to ensure the privacy of such information.

Openness and Access

We are committed to transparency with respect to the collection, use, management, and disclosure of personal information.

Clients have the right to request access to information about the existence, use and dissemination of their personal information. They also have the right to request access to specific information about the Firm’s privacy policies including:

• the name or title and the address, of the person who is accountable for the compliance with Privacy Laws and to whom complaints or inquiries can be forwarded;
• the means of gaining access to personal information held by the organization;
• a description of the type of personal information held by the organization, including a general account of its use;
• Additional information that explains The Firm’s policies, standards and/or codes.

Challenging Compliance

A Client may challenge the accuracy and completeness of the information collected and have it amended as appropriate. We ask you to please submit the request in writing.