Idealist Capital Inc. (collectively, “Idealist Capital”, the “Firm”, “we”, “our” or “us”) is committed to maintaining the accuracy, confidentiality and security of the personal information that it collects. The purpose of this privacy policy (the “Policy”) is to explain how and for what purposes we collect, use, share or otherwise process your personal information and how we safeguard the confidentiality of your personal information, whenever you interact with Idealist Capital.

1. Scope

This Policy applies to all of Idealist Capital’s operations. It applies, for instance, if you are a client that invests in an Idealist Capital managed fund (a “Fund”) or if you visit our website (including our client portal), or if you apply for a career opportunity with Idealist Capital.

In this Policy, we describe our policies and practices with respect to the collection, use and disclosure of personal information and the measures taken to ensure its continued protection. In some cases, at the time of collection of your personal information, we may provide you with additional information regarding the processing of your personal information. We may also, in certain circumstances, obtain your specific consent to the use or sharing of your personal information, including where required by law.

2. What is “personal information”?

For the purposes of this Policy, personal information means any information about an identifiable individual, other than the person’s business title or business contact information. 

3. Personal Information Collected

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. 

Depending on your interaction with us, we may collect personal identifiers, commercial information, professional or employment–related information and Internet or other electronic network activity. We may also need to collect certain information about our clients to conduct money laundering, sanctions, financial crimes and fraud prevention checks.

4. Collection of Personal Information

We may collect personal information directly from you or from your representatives, such as when:

• you invest in one of our Funds; 
• you provide identification documentation in response to “Know Your Clients” checking requests;
• you apply for a career opportunity with us;
• you contact us with an inquiry.

In certain circumstances, we may collect personal information from third parties, such as a consultant or a referral agent with whom we work with. 

Idealist Capital may also collect certain types of information electronically through your contact with our websites using technologies (either our own or third party technologies) such as cookies and web beacons. We may collect your Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages and the pages you viewed on our site.

5. Use and Disclosure of Personal Information

Idealist Capital does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by applicable law.

The Firm may, from time to time, disclose your personal information to third parties, such as agents, contractors, consultants, financial institutions, the Fund’s administrator and other service providers that perform specialized services on our behalf. When the Firm uses such external parties, it uses contractual or other measures to ensure that these parties agree to protect personal information in the same manner as the Firm.

6. Protection of Personal Information

The Firm maintains physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information. These safeguards are designed to prevent the personal information from loss and unauthorized access, copying, use, modification and disclosure.

If the Firm uses a third-party service provider to process or store personal information, it will only disclose the personal information necessary for the service provider to perform its services.  Contracts with such third-party service providers will require that they keep personal information confidential, protect it by appropriate security safeguards, and use and/or disclose the information solely for the purpose of carrying out the contracted services.

7. Retention of Personal Information 

The Firm retains personal information only for so long as it is useful or may be required by law or reasonable business needs.  Except where required or authorized at law, when personal information is no longer required for the purposes for which it has been collected, such personal information will be made anonymous or securely destroyed. 

8. Updating the Personal Information

The Firm ensures that personal information is as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.

To help us keep our records accurate and complete, we ask clients to consent to the use of their personal information in our form of subscription agreement. Clients are also asked to notify us of any personal information changes, deletions or corrections. 

9. Access to Personal Information

Subject to certain exceptions prescribed by law, individuals may be given reasonable access to their personal information and are entitled to request that we delete their personal information, or challenge the accuracy and completeness of their information and, if shown to be inaccurate, to have it amended as appropriate.

10. Inquiries or Concerns

If you have any questions about this Policy or have any concerns about how the Firm collects, uses or discloses your personal information, please contact us by email at raenden@idealist.capital.com. 

11. Revisions to this Policy 

The Firm may make changes to this Policy from time to time including for the purpose of reflecting changes in its legal or regulatory obligations. If the Firm changes this Policy, an updated version of the policy will be made available.  

This Policy was last updated on March 23, 2022.