This Privacy Policy describes the policies and procedures followed by Turtle Creek Asset Management Inc. (together, “TCAM”, “we”, “our” or “us”) regarding the collection, use and disclosure of your personal information when you visit our website or otherwise interact with TCAM. Please note that when using the website, this Privacy Policy should be read in conjunction with our Terms of Use and is incorporated into our Terms of Use.

The privacy of our investors is very important to us. Set forth below are our policies with respect to personal information of subscribers in our funds, investors and former investors that we collect, use and disclose.

Definition of Personal information. When used in this Privacy Policy, personal information means any information about an identifiable individual. This may include, for example, your name, contact information, email-address, information relating to your account with us, including your identity and the services you use and subscribe to, as well as credit and banking information, billing records and any complaints documented in a file. It may also include other types of more technical information (such as information collected from visitors to the website) but only when this information can identify you as an individual. Personal information that is aggregated and or anonymized and cannot be associated with an identifiable individual is not considered to be personal information.

Collection of Personal Information. We collect your personal information to enable us to provide you with services in connection with your investment in our funds, in order to give you the best possible service, allow us to establish your identity, protect us from error and fraud, assess your eligibility in our products, to comply with the law and to meet legal and regulatory requirements, for any other purpose to which you may consent in the future or for the purposes listed in section “Use of your Personal Information” below. When you visit the website, receive services from us or otherwise interact with TCAM or in connection with the offering and sale of units of our funds, we may collect and process the following data about you:

• Information that you give to us – you may give us personal information including your name, company name, contact details including address(es), telephone number(s) and email address. If you are an investor, we may also collect your passport information, social insurance or security number and assets, account balances and transaction history and investment experience and wire transfer instructions. You are not under any obligation to provide any of this information. However, if you withhold requested information, we may not be able to provide certain services to you.
• Information that we collect about you – we may automatically collect basic technical information from all visitors to the website through our automatic data collection tools, which may include cookies and other commonly used technologies (see section on Cookies below). These tools collect certain standard information that your browser sends to the website such as your browser type and language, access times, and the address of the site from which you came to the website. They may also collect your Internet Protocol (“IP”) address, or click stream data within our website (i.e. the actions taken in connection with the website). This information helps us improve the functionality of the website.
• Information may also be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails with us). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used only for legal, compliance or security purposes

Use of your Personal Information. We may use the personal information you give us to carry out the following purposes:

• To contact you and to respond to your requests, enquiries and other communications 
• To deliver services to you
• For employment recruitment purposes
• For business administration, including statistical analysis
• To personalize your visit to the website and to assist you while you use the website
• In connection with corporate sales or other restructuring events
• For fraud prevention and detection and to comply with applicable laws, regulations or codes of practice including complying with any obligations that derive from anti-money laundering and counter-terrorism legislation

Sharing your Personal Information. We may use selected third parties to provide us with services or technical support for the website and our systems who may have access to your personal information. If you are an investor, we may also disclose certain personal information to our affiliates and service providers, such as fund administrators (including, but not limited to, SGGG Fund Services Limited and its affiliates), custodians, financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of a fund, broker-dealers, accountants, auditors and lawyers, as necessary to effect and administer our funds and enforce our rights and obligations. All service providers are permitted to use data only for the purpose of performing services on our behalf. Similarly, we may share your personal information as required by law to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial, regulatory and taxation authorities. Investors should be aware that our funds are required to periodically file a report with certain regulatory and taxation authorities. Regulatory authorities, including the Ontario Securities Commission (the “Regulators”), require that our funds file a report setting out who bought units of a fund including each subscriber’s name, address and telephone number, the number and type of securities purchased, the date of issuance and the purchase price of the securities issued to the investor.  Such information is collected indirectly by the applicable Regulators under the authority granted to it in securities legislation for the purposes of the administration and enforcement of such securities legislation.  More information is found in our Relationship Disclosure Information document.

International Transfer. Our computer systems are currently based in Canada, which means that information we collect will be processed by us in Canada, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. If you use or visit our website from outside Canada, you consent to the collection and/or processing in Canada of information we collect from you. In some cases, personal information that we manage may be transferred, processed and stored outside your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable there. You hereby consent to the transfer of your personal information to recipients as described in this Privacy Policy which are located outside of your country of residence.

Consent. Unless you otherwise advise, by providing us with your personal information you have consented to our collection, use and disclosure of your information as provided herein. You have a right to object to processing of your personal information where that processing is carried out for our legitimate interest and/or this processing is not core to the services or products provided. You may withdraw your consent at any time by contacting TCAM at the following number: (416) 363-7400.  The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal, and it will not preclude the future processing of personal information if within our legitimate interest. Please note that your ability to participate or invest in a fund may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information. Security. Your personal information is maintained on our networks or on the networks of our service providers accessible at Scotia Plaza, 40 King Street West, Suite 5100, Toronto Ontario M5H 3Y2. Your information may also be stored on a secure off-site storage facility. . TCAM maintains physical, electronic and procedural safeguards reasonably designed to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.  TCAM can make no guarantee that these procedures will prevent all unauthorized access, and as a result, personal information submitted through or contained on the website or on our systems may be vulnerable to unauthorized disclosure to unknown third parties.

Data Quality and Access. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us in this regard by promptly notifying us if there are any changes to your personal information. You may access your personal information to verify its accuracy and update your information by contacting TCAM at the following number: (416) 363-7400.

Retention. TCAM may retain your personal information as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements. The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Children’s Privacy.  No part of our website is targeted to attract anyone under 18.

Cookies. The website may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of the website. Cookies may also help us diagnose problems with our server and the website. If you do not want us to use cookies when you use the Website, you can adjust your internet browser settings not to accept cookies. Your web browser’s help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org.  The website will also explain how you can delete cookies which are already stored on your device.

Revisions to this Privacy Policy. We may revise or supplement this Privacy Policy from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify you by posting a notice on our website, prior to the change becoming effective and obtain your consent when required by law. We encourage you to refer to this Policy on an ongoing basis so you understand our current privacy practices.

Contact Us. If you have any questions or comments about our Privacy Policy, please contact our Chief Privacy Officer, Meaghan Einav, at (416) 363-7400.