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Legal and Regulatory

 

Disclaimer

All the information on StarBridge Capital Ltd.’s (“StarBridge”) website is published in good faith and for general information purposes only. The information on the StarBridge website is not an offer to sell and is not intended as an invitation to make an investment in any fund or in any company as a direct transaction. StarBridge does not make any warranties about the completeness, reliability and accuracy of the information on its website. Any action you take based on the information on the StarBridge website, is strictly at your own risk. StarBridge will not be liable for any losses and/or damages in connection with the use of our website.

 

From the StarBridge website, you may visit other websites by following hyperlinks to such external sites. While StarBridge strives to provide only quality links to useful and ethical websites, we have no control over the content and nature of these sites. Any links to other websites do not imply a recommendation for all the content found on these sites. Site owners and content may change without notice and may occur before we remove links that may no longer be relevant. Also, when you leave the StarBridge website, other sites may have different privacy policies and terms that are beyond our control. Please check the Privacy Policies of these sites and their “Terms of Service” before engaging in any business or uploading any information.

 

Consent

By using the StarBridge website, you hereby consent to our Disclaimer and agree to its terms.

 

Update

Should we update, amend or make any changes to this website, those changes will be posted here.

 

Privacy Policy

StarBridge’s policies on privacy are guided and governed by the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”).  StarBridge also has manager and corporate clients outside Canada and we will adhere to the applicable privacy legislation impacting those clients.  StarBridge values the privacy of both our investor clients and manager / corporate clients and we are committed to protecting the privacy and confidentiality of all information belonging to our clients in our possession.

 

This Privacy Policy is intended to provide you with an outline of how StarBridge fulfills our privacy commitment to all our clients, with a key focus on investor clients:

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  • Collecting Information: StarBridge collects personal information to enable us to provide our investor clients with services in connection with their investment, to meet legal and securities regulatory requirements and for any other purpose to which they may consent in the future. This Privacy Policy governs the collection of personal information such as an investor’s name, address, phone number, email address, and tax identification numbers.  We collect personal information from the following sources:

    • Subscription agreements or other forms and documents investors complete;

    • Transactions with us and our managers / corporations and their related service providers; and

    • Meetings, telephone conversations and electronic communications.

 

  • Why We Need Your Information: StarBridge collects and maintains its investor clients’ personal information to provide you with the best possible service and allow us to establish your identity, protect StarBridge from error and fraud, comply with applicable laws, assess your eligibility to invest in any manager funds and/or in a direct investment in a company, and if required, to determine the suitability of an investment by you in a manager’s fund or in a direct investment. It is our policy that we will never sell your information.

 

  • Disclosing Information: StarBridge may disclose its investor clients’ personal information to third parties, when necessary, and to its affiliates in connection with the services provided related to their subscriptions, including:

    • Financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, StarBridge managers’ funds or companies if a direct investment;

    • Other service providers, such as accounting, legal or tax preparation services; and

    • Taxation and security regulatory authorities and agencies.

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Disclosure of investor clients’ personal information to third parties may also occur where we have your consent to do so, or where we are required or permitted to do so by law, including to taxation authorities and securities regulatory authorities. It is our policy that we will never sell your information.

 

  • Protecting Information: StarBridge seeks to carefully safeguard the private information of both its investor clients and manager clients and restricts access to personal information concerning clients, only to those employees and other persons who need to know the information to enable StarBridge to provide services. StarBridge employees and/or consultants are subject to a code of conduct concerning the confidentiality of all personal information they may access and are responsible for ensuring the confidentiality of all personal information they may access. Investor clients’ personal information is maintained on StarBridge’s networks (and/or on the networks of our managers / corporations’ service providers) and is accessible at 300 Front Street West, Suite 208, Toronto, Ontario, M5V 0E9, Canada.  Personal information may also be stored on a secure off-site storage network or facility. We only collect investors clients’ personal information that is necessary. We will retain personal information as long as needed, to satisfy the purposes identified when the information was collected or as long as regulations demand.  When we deem that we no longer need your information, we will delete electronic records and destroy physical record.

 

  • Providing Access: Upon request, we may provide investor clients with access to your personal information as required by law. You may access your personal information to verify its accuracy.  We will take all reasonable steps to ensure that your personal information is accurate and current.  Having accurate information about you will enable us to provide the best possible service.  We expect you will provide us with updated information whenever you move or have any other material changes to your information.

 

  • Our Website: If you access our website, certain information about your computer such as the address you are connecting from, may automatically be generated, collected, and logged by web servers. We may use “cookies” on this site. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

 

  • Your Right to Withdraw Consent: By working with StarBridge, investor clients provide your consent for us to collect, use and disclose your personal information in the ways and purposes stated in this Privacy Policy, as required by securities regulators.  If at anytime you wish to withdraw your consent, please contact StarBridge Capital at 416-277-4940 or email confidentiality@StarBridgeCapital.com. Please note that your ability to receive our services may be impacted if you withdraw your consent to the collection use and disclosure of your personal information as outlined in this Privacy Policy.

 

Contacting Securities Commissions in Canada

Investor clients who are resident in Ontario (and in other Canadian provinces) should be aware that StarBridge’s fund managers and/or the corporations it works with, as issuers of securities, may be required to file with the Ontario Securities Commission (“OSC”) (other provincial securities commissions) a report setting out their name and address, the Class and Series of Units issued, the date of issuance and the purchase price of Units issued to each subscriber.  Such information is collected indirectly by the OSC (or other securities commissions) pursuant to the authority granted to it (them) under securities legislation, for the purpose of the administration and enforcement of the securities legislation of Ontario (in other provinces).  By submitting a Subscription Agreement (or similar document), a subscriber for Units authorizes such indirect collection of the information by the OSC (respective securities commission). 

 

The following official can answer questions about the OSC’s indirect collection of investor clients’ information:

 

Ontario Securities Commission (“OSC”)

Attention: Inquiries Officer
20 Queen Street West, 22nd Floor
Toronto, Ontario, M5H 3S8

Canada


Telephone:                 416-593-8314
Toll Free (Canada):     1-877-785-1555
Facsimile:                    416-593-8122
Email:                           exemptmarketfilings@osc.gov.on.ca

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For all other jurisdictions in Canada, please contact us at confidentiality@StarBridgeCapital.com for details.

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