Harmonic Fund Services Canada Inc (“Harmonic”) Privacy Policy


The privacy of employees, independent contractors, clients and the investors in the funds for which Harmonic acts as administrator (each a “Discloser”) is very important to Harmonic, and personal information will only be collected, maintained and disclosed by Harmonic in accordance with this policy and applicable legislation.

Harmonic may collect, maintain and disclose personal information in the following circumstances:

  • To assess an individual’s eligibility for employment or engagement as an independent contractor with Harmonic;
  • In connection with an offer of employment or engagement;
  • To assess eligibility for employment or engagement;
  • For any purposes required during employment or engagement;
  • To meet legal or regulatory requirements;
  • To establish an individual’s identity;
  • To protect Harmonic from error or fraud; and
  • To enable Harmonic to carry out its duties to its client in the ordinary course of business

A Discloser’s personal information may be collected from the following sources:

  • Curriculum Vitae and covering letter;
  • References supplied by referees;
  • Meetings and telephone conversations with Discloser;
  • Any other documents provided by Discloser to Harmonic (e.g. subscription agreement of a fund).

Unless otherwise advised, by providing Harmonic with personal information, Discloser is deemed to have consented to the collection, use and disclosure of the personal information.

During the course of employment, engagement, or business with Harmonic, personal information may be disclosed to third parties, when necessary, and to Harmonic’s affiliates, including but not limited to:

  • Financial service providers, such as banks and others used to finance or facilitate transactions by or operations of a fund;
  • Other service providers to a fund, such as accounting, legal or tax preparation services;
  • Such verification and search application as Harmonic utilises from time to time in order to conduct so-called “Watch List” checks; and
  • Taxation and regulatory authorities and agencies.

Harmonic shall only make such disclosure to third parties and affiliates on the understanding the recipient will only use that personal information for the purposes required, and as permitted by applicable law and regulation.

Harmonic seeks to carefully safeguard personal information and, to that end, restricts access to personal information to those employees, independent contractors, affiliates and other persons who require access for a legitimate business purpose. Each such recipient is responsible for ensuring the confidentiality of all personal information they may access.

Personal information is maintained on Harmonic’s networks or on the networks accessible at TD Canada Trust Tower, 161 Bay Street, Suite 2110, Toronto ON M5J 2S1, Canada. Personal information may also be stored on a secure off-site storage facility. Personal information may be may accessed to verify its accuracy, to withdraw consent to any of the foregoing collections, uses and/or disclosures being made of the personal information. Personal information may be updated by contacting Harmonic at the following number: (416) 507-4700 or the Human Resources Manager on (345) 949-0090. Please note that in certain circumstances, an individual’s ability to be employed or engaged by Harmonic may be impacted should consent to the collection, use and disclosure of personal information as outlined above be withdrawn.

LAST REVISED: 22 August, 2017