Burgundy Asset Management Ltd. is committed to protecting our Clients'
privacy and the confidentiality of their personal information in our possession.
Here are the ways we fulfill these commitments.
1. We only ask Clients for necessary personal information.
All of our forms are designed to obtain only information needed for contractual,
regulatory and income tax reporting requirements. In addition we use the personal
information you provide to us to thoroughly understand your investment goals and
objectives. This helps us to determine the appropriate investments for you.
For example, our Client Profile form requests:
Social Insurance Number (SIN)
Asset holdings and values
Investment knowledge and objectives
Dependent and beneficiary names and contact information
For registered retirement accounts, we ask only for information to register the accounts
with the government. To help us keep our records accurate and complete, we ask Clients to
notify us of any personal information changes or corrections.
2. We safeguard and limit access to Clients' personal information.
We keep Client information in a computer system, which can only be accessed by authorized
employees using secure passwords. We have installed anti-hacking hardware to prevent
unauthorized access to the computer system. For disaster recovery purposes, we maintain a
duplicate computer system in an offsite location. This system has the same privacy and
security measures as are in our main offices. We may also keep paper copies of Client information
in filing cabinets in our office. When we need to store information offsite, the storage
firm is under contract to adhere to our privacy and security measures.
3. Outside Service Suppliers
We may use service providers to perform specialized services on our behalf including but not
limited to, issuing cheques, preparing income tax slips, processing transactions or other
data processing. Our service providers may at times be responsible for handling personal information,
however, they are provided only the information necessary to perform the required services.
In addition, we require them to protect the information in a manner that is consistent with our
privacy policies and security practices.
4. We prevent unauthorized disclosure of Clients' personal information
All Burgundy and Beaujolais personnel are trained to keep Client information private and
confidential. We require all of our staff to sign our Code of Conduct, which contractually
obliges them to respect and protect Client information even if they are no longer in our employment.
We prohibit disclosure of any Client's personal information to a third-party without the Client's
explicit consent. We shred paper documents containing Client information before discarding such documents.
When electronically stored personal information is no longer required for contractual or regulatory
purposes, we delete the information from our computer systems.
5. Use of information collected via the Internet
If you use the internet to communicate with us or you access our website, certain information about
your computer may automatically be generated, collected and logged by web servers. This information
may include the Internet Protocol (IP) Address assigned to your computer by your Internet Service
Provider (ISP), the type of browser you are using, the general location of your computer, and web
pages visited. We may use this information to monitor website usage, resolve technical issues,
improve functionality and evaluate website popularity.
6. We have a Privacy Officer
Our Privacy Officer is responsible for monitoring the fulfillment of our privacy commitments and for
in our possession or that require further information should send a written request to
7. We are required to make regulatory filings, but only with your consent
We are required to provide certain contact information of non-prospectus fund investors to the
Ontario Securities Commission ("OSC") under the authority granted in securities legislation.
This information is collected only for the purposes of administration and enforcement of the
securities legislation. If you are an investor in a Burgundy non-prospectus fund and you object
to Burgundy's filing of your information, you may contact our Privacy Officer. If you have any
questions about the collection and use of this information, you may contact the OSC at the
Administrative Assistant to the Director of Corporate Finance
Ontario Securities Commission
Suite 1903, Box 55, 20 Queen Street West
Toronto, ON M5H 3S8
Telephone: (416) 593-8086