Privacy Policy

The privacy of our investors is essential to us. This Privacy Policy sets out the information practices for Dili Capital Corp., including what types of personal and business information is collected, how the information is used, and with whom the information is shared. We are committed to protecting your privacy and maintaining the confidentiality of your data.

This Privacy Policy may be updated from time to time without notice. This Privacy Policy was last modified on December 28, 2013.

Dili Capital Corp. complies with the requirements of Part 1 and Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and all applicable provincial personal information laws. Below is an overview of the privacy principles set out in Schedule 1 of PIPEDA.

​Definitions you need to know
We, our and we mean, as applicable, any Dili Capital Corp member. 

DiliCapital means, collectively, Dili Capital Corp. and all of its affiliates and subsidiaries and any program or joint venture any of these parties participates in.

Service means any financial product or service offered by us.

You and your means each person, whether an individual, corporation, or trust, who has made an application to us for or signed an application in respect of any Service offered by us, including any co-applicants, guarantors, or personal or corporate representatives such as directors.

SROs refer to self-regulatory organizations, including the Investment Industry Regulatory Organization of Canada (IIROC), the Mutual Fund Dealers Association of Canada, the exchanges and other regulated marketplaces, and the Canadian Investor Protection Fund.

What personal information do we collect?
The term “personal information” refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number (“SIN”), birth date, assets and income information, employment history, and credit history. We will be collecting personal information from you that includes the following:

  • Your full name, address, occupation, and date of birth, which is required by law;
  • Identification, such as a valid driver’s license or passport;
  • Your social insurance number for income tax reporting purposes, as required by law;
  • Your financial information including, annual income, assets and liabilities, and banking information;
  • Your employment history and credit history;
  • Information about third parties such as your spouse if you are applying for certain Services, where this information is required by law.

For legal entities such as businesses, partnerships, trusts, estates, or investment clubs, we may collect the information referred to above from each authorized person, partner, trustee, executor, and club member, as appropriate.

How do we collect your information?

We collect your personal or business information directly from you or through your financial advisor and dealer to provide you with Services, meet legal and regulatory requirements, and any other purposes to which you consent. Your information may be collected from a variety of sources, including:

Subscription forms, applications, questionnaires, or other forms that you submit to us or agreements and contracts that you enter into with us;

  • Your transactions with us;
  • Meetings and telephone conversations with you;
  • E-mail communications with us; and
  • Our websites.

We may monitor or record any telephone call we have with you. The content of the call may also be retained. We may inform you before proceeding with the call of this possibility. This is to establish a record of the information you provide, ensure that your instructions are followed correctly, and ensure customer service levels are maintained.

How do we use your information?
We collect and use your personal or business information to give you the best possible service and for the purposes set out in your agreement(s) with us, such as:

  • To establish your identity and verify the accuracy of your information;
  • To confirm your corporate status;
  • To understand your needs;
  • To determine the suitability of our Services for you;
  • To determine your eligibility for our Services;
  • To set up, administer, and offer Services that meet your needs, including fulfilling any reporting or audit requirements;
  • To provide you with ongoing service, including executing your transactions;
  • To provide you and your financial advisor and dealer with confirmations, tax receipts, proxy mailings, financial statements, and other reports;
  • To meet our legal and regulatory requirements;
  • To manage and assess our risks; and
  • To protect us from error and to prevent or detect fraud or criminal activity.

We collect, use and disclose your SIN, social security number, or other government-issued personal or business identification number for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.

How do we obtain your consent?
DiliCapital will not, as a condition of the supply of Services, require you to consent to the collection, use, or disclosure of your personal information beyond that which is necessary to fulfill these purposes.

Who do we share your information with?
We may share your​
personal or business information within the DiliCapital for the purposes set out above. We do not provide directly all the services related to your relationship with us. As such, we may transfer your personal information, when necessary, to our third-party service providers and our agents in connection with the Services, however; however, please note that these third-party service providers and agents will not share this information with others. Such information is only used for the purposes identified above. We may use third-party service providers or agents such as:

  • Your financial advisor or dealer;
  • Other financial service providers such as investment dealers, custodians, prime brokers, banks, and others used to finance or facilitate transactions or operations on your behalf;
  • Registrar and transfer agents, portfolio managers, brokerage firms, and similar service providers; and
  • Other service providers such as accounting, legal, or tax preparation services.

Our service providers and agents process or handle your information on our behalf and assist us with various services such as printing, imaging, document storage, shredding, mail distribution, and marketing. Some of these third parties may be located outside of Canada. As a result, your information may be accessible to regulatory authorities by the laws of these jurisdictions. When data is provided to our service providers and our agents, we will require them to protect the information in a manner consistent with DiliCapital privacy policies and practices.

We may also be required by law to disclose information to government regulatory authorities. For example, we may be required to report your income to taxation authorities. We may also be required to disclose your personal and business information to SROs. SROs collect, maintain, use and disclose such information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases, and enforcement proceedings. SROs may, in turn, disclose such information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.

We do not sell, lease, barter, or otherwise deal with your personal information with third parties. DiliCapital may be involved in the sale, transfer, or reorganization of some or all of its business at some time in the future. As part of that sale, transfer, or reorganization, we may disclose your personal and business information to the acquiring organization; however, we will require the acquiring organization to agree to protect the privacy of your personal and business information in a manner that is consistent with this Privacy Policy.

How do we use your information for marketing purposes?
We may share​
your personal or business information within the DiliCapital for marketing products and services that we believe may be of interest to you. This would only be done with your consent. We may ask you for your contact information, such as your telephone number, residential address, e-mail, or other electronic address, and keep and use this information as well as disclose it to other members of the DiliCapital so that we or any of these companies may contact you directly through these channels for marketing including telemarketing. Your consent to this is not a condition of doing business with us, and you may withdraw it at any time (see below).

​How do you withdraw your consent?
Subject to legal, regulatory and, contractual requirements, you may refuse to consent to our collection, use, or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use, or disclosure of your data at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact our ability to provide you or continue to provide you with some Services or information that may be of value to you. We will inform you of the implications of your withdrawal of consent for the continued promise of service to you. We will act on your instructions as quickly as possible, but there may be specific uses of your information that we may not be able to stop immediately.

You can tell us at any time to stop using information about you to promote our Services or the products and services of third parties we select or to stop sharing your information with other members of the DiliCapital. Suppose you wish to withdraw consent as outlined in this Privacy Policy. In that case, you may do so at any time by contacting us by mail at Dili Capital Corp.., Suite 203, 1370 Don Mills Road, Toronto, Ontario M3B 3N7Attention: Chief Compliance Office or by e-mail at

How do we safeguard personal information? 
We carefully safeguard your personal information​
and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. Our employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of our employees must sign a code of conduct, which contains policies on the protection of personal information.

How do you update your information?
As we make decisions based on our information, we encourage you to help us keep our information accurate and complete. Contact us at any time in writing at Dili Capital Corp., Suite 203, 1370 Don Mills Road, Toronto, Ontario M3B 3N7Attention: Chief Compliance Office or by e-mail at if you wish to update the information we have about you.

How can you access your information?
You may request access to the personal information​
we hold about you at any time to review its content and accuracy and to have it amended as appropriate. To request access to such information, please contact us in writing Dili Capital Corp.., Suite 203, 1370 Don Mills Road, Toronto, Ontario M3B 3N7Attention: Chief Compliance Office or by e-mail at

We will respond to your written access request promptly. We may be unable to provide you with access to all or some of the information we hold about you. We will provide you with an explanation if we are unable to fulfill your access request.

​Whom do you contact if you have any questions or concerns?
If you have any questions about our privacy policies and practices and how they relate to you, please get in touch with our Chief Privacy Officer by telephone at 1-416-548-7876, by e-mail
at, or by mail to Dili Capital Corp., Suite 300, 1370 Don Mills Road, Toronto, Ontario M3B 3N7Attention: Chief Compliance Officer.

If you are still not satisfied, you can contact The Office of the Privacy Commissioner of Canada. Complaints to the Office of the Privacy Commissioner must be submitted in writing to 112 Kent Street Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3 Attention: The Privacy Commissioner of Canada.

​Other information
We may amend this Privacy Policy from time to time to consider changes in legislation or other issues that may arise. We will post the revised Privacy Policy on our public websites, including We may also send it to you by mail.


The Personal Information Protection and Electronic Documents Act (the “Act”) regulates the way private sector organizations collect, use and disclose personal information.  It does not apply to either corporate or not-for-profit organizations.

Its main objective is to ensure personal information collected from clients is used for the stated purpose and to safeguard such information.

​“Personal Information” is defined as information about an “identifiable individual”.  This includes such things as age, weight, height, medical records, income, education, home address and phone number.  It does not cover general contact information such as name, title, business address, business phone number, etc.

Information that Palette has collected for completion of the Know Your Client questionnaire is subject to the requirements of the Act.

​Palette and Capitaleta recognizes the importance of privacy and recognizes the sensitivity of personal information received by it in the conduct of its business.  This policy has been prepared with this objective in mind.

​The need for Personal Information

We have collected Personal Information to meet certain regulatory requirements and to help us comply with securities and federal anti-money laundering regulation.  This information will necessarily include personal information about our clients and, in certain cases, about individuals other than you. (e.g. information on person with trading authority.)

​Collection, Use and Disclosure of Personal Information

Where practical, Palette will try to collect personal information directly from the person to whom the information pertains.  However, where appropriate, we may collect personal information from publicly available sources.  We will collect only the personal information necessary for the purposes stated in the section titled, “The Need for Personal Information.”

The Act provides that an individual is deemed to consent to the collection, use or disclosure of personal information for a specific purpose, if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.

​By transacting through Palette, we consider that you have consented to our collection, use or disclosure of personal information as necessary to properly represent you in these financial and investment matters.

Where necessary to fulfill our regulatory obligations, we may collect personal information about individuals other than you as a client in accordance with the provisions of PIPEDA.

​When we collect personal information about individuals directly from them, except in situations when their consent to the collection is deemed, we will tell them the purpose for which the information is collected.

Obtaining consent from the individual is a key element of the Act.  However, this obligation is not absolute.  The Act also permits us to collect, use or disclose personal information about an individual in some circumstances, without the individual’s consent.  Such circumstances include (but are not limited) to where:

  • The collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
  • Collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
  • The personal information is available to the public from a prescribed source; or
  • The collection, use, or disclosure is required or authorized by a Federal or Provincial statute or regulation.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete.  The Act also allows us, for legal or business purposes, to retain personal information for as long as is reasonable, but also imposes obligations upon us to ensure that procedures are in place to destroy the personal information when it is no longer required.

Security of Personal Information
We recognize​ our professional and legal obligations to protect the confidential information of our clients.  We also recognize our legal obligations to protect the personal information we have gathered about our clients, and about other individuals during the course of our business.

​Palette has implemented policies and procedures to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

Requests for Access to Personal Information
Pursuant to the​ Act, an individual may submit a written request to us to provide them with:

  • A record of the personal information of the individual under our custody or control;
  • Information about the purposes for which their personal information under our custody or control has been and is being used by us; and
  • The names of persons to whom and the circumstances in which their personal information has been and is being disclosed by us.

We will respond to requests in the time allowed under the Act, and will make a reasonable effort to assist applicants, and to respond as accurately and completely as reasonably possible. Requests may be subject to certain fees and disbursements in accordance with the provisions of the Act.

​An individual’s ability to access his or her personal information under our control is not absolute.  The Act provides that we must not disclose personal information where:

  • the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
  • the disclosure would reveal personal information about another individual and consent is not obtained; or
  • the disclosure would reveal the identity of an individual who has, in confidence, provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity.

The Act further provides that we may choose not to disclose personal information where:

  • the personal information is protected by any legal privilege;
  • the disclosure of the information would reveal confidential commercial information, and it is not unreasonable to withhold that information;
  • the personal information was collected by us for an investigation or legal proceeding;
  • the disclosure of the personal information might result in similar information no longer being provided to us, when it is reasonable that it would be provided;
  • the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under an agreement, under an enactment, or by a court; or
  • the personal information relates to or may be used in the exercise of prosecutorial discretion.

The above examples are not exhaustive, and you are encouraged to examine the provisions of the Act for a complete list.

Requests for Correction of Personal Information. An individual may also submit a written request to us to correct errors or omissions in the personal information of the individual that is in our custody or control. When provided with a written request, Palette will:

  • Correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or
  • Decide not to correct the personal information, but annotate the personal information that a correction was requested, but not made.

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our President at:

Mr. Andrew Cook
​Palette Investment Management Inc.
19 Glen Castle Street
Toronto, Ontario M4R 1Z5

E-mail communications may be sent to If you are dissatisfied with our handling of your personal information, we invite you to contact  Andrew Cook in writing, setting out the reasons for your concern.  If you remain dissatisfied after Andrew Cook has reviewed and responded to your concern, you may wish to contact the Office of the Information and Privacy Commissioner.

​We also encourage you to obtain a complete copy of the Act to further determine the rights and obligations contained within that legislation, and to obtain independent legal advice if considered necessary.  The contact information for the Office of the Privacy Commissioner and a copy of the Act can be obtained from the following link:

​I/We also acknowledge receipt of the Palette Investment Management Inc. Relationship Disclosure Document and by signing below, I/We indicate that I/We have read and understand all the information and conditions contained therein.