PRIVACY POLICY STATEMENT
108 Equity Inc. (together with its affiliates, “108 Equity”) and each Investment Company or other pooled investment entity managed by 108 (each, a “Fund”) complies with
the requirements of the Personal Information Protection and Electronic Documents Act (Canada) and all applicable provincial personal information laws.
108 and the Funds recognize the importance of protecting their clients’ privacy. Accordingly, 108 and the Funds take precautions to maintain the privacy of personal
information concerning each Fund’s current and prospective individual investors. These precautions include the adoption of certain procedures designed to maintain
and secure such investors’ nonpublic personal information from inappropriate disclosure to third parties.
108 and the Funds collect nonpublic personal information about investors from the following sources:
• information contained in the investor’s subscription agreements and related documents, including an investor’s name, address, income, social
insurance or social security number, citizenship, employment and occupational data, residency, company affiliations or other personal identification numbers
and information required to establish that an investor is an “accredited investor” or the equivalent under laws of jurisdictions outside of Canada, and certain other
financial information;
• meetings and telephone conversations with investors;
• information about an investor’s transactions with 108, the Funds or others; and
• information 108 or the Funds may receive from a consumer reporting agency.
Neither 108 nor any of the Funds disclose any nonpublic personal information about prospective, existing or former investors to anyone, except as permitted by law and
regulation, as authorized by the relevant investor in writing or in accordance with this Privacy Policy.
The personal information collected from investors will be used solely for the purposes of:
• providing services to investors in a Fund, including executing transactions and providing confirmations, tax information and financial statements in connection with an investor’s investment;
• satisfying 108’s and the Funds’ obligations under applicable legal and regulatory requirements and under the limited partnership agreements governing the
business and affairs of the Funds and any related side letters or other agreements, including any obligations to ensure that each investor’s investment in a Fund is suitable for such investor and that each investor is a person to whom such Fund is permitted to sell interests of the Fund; and
• for any other purpose to which an investor may consent in the future.
108 and the Funds respect the privacy of their clients. 108 and the Funds restrict access to nonpublic personal information about investors to those employees and agents of 108 and the Funds who need to know that information in order to provide services to investors, 108 or any of the Funds. Each employee and agent of 108 and the Funds will be made aware of the importance of maintaining investors’ personal information and will be responsible for ensuring the confidentiality of all personal information they may access.
108 or the Funds may also disclose investors’ personal information to their affiliates and to service providers (including 108’s and the Funds’ auditors or legal advisors) and financial institutions that provide services to 108 or any of the Funds or in order to satisfy their obligations under applicable laws. 108 and the Funds will require such third party service providers and financial institutions to protect the confidentiality of investors’ nonpublic personal information and to use such information only for purposes for which it is disclosed to them.
108 or the Funds may disclose certain nonpublic personal information about current or former investors in a Fund received from investors, such as an investor’s name, contact information and financial profile, to companies that perform marketing services on 108’s or a Fund’s behalf or to other financial institutions, such as placement agents, in connection with offerings of interests of new and existing Funds.
108 or the Funds may disclose certain nonpublic personal information about current investors in a Fund received from investors, such as an investor’s name and the
respective commitment of such investor, to current and/or prospective investors in one or more Funds.
108 and the Funds maintain physical, electronic, and procedural safeguards that comply with federal standards to safeguard investors’ nonpublic personal information and which Ironbridge and the Funds believe are adequate to prevent unauthorized disclosure of such information.
Unless you otherwise advise, by providing 108 or any Fund with your personal information, you have consented to our collection, use and disclosure of your information as provided in this Privacy Policy. Please note that our ability to manage your investment in a Fund may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information as outlined herein.
108 reserves the right to change this Privacy Policy at any time and 108 will make any such revised Privacy Policy available to you.
If you have any questions concerning any personal information pertaining to you held by 108 and/or the Funds or this Privacy Policy, please contact the President of 108 Equity Inc., at 528 Waterloo Street, Suite 2000 London, ON N6B 2P9.