Protecting personal information and privacy is very important to us. We are committed to ensuring that your information is treated with the utmost confidentiality and in accordance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) as well as all applicable provincial privacy legislation.

Pender is governed by the Manager’s Privacy Policy. The complete Privacy Policy is available here:

The policy comprehensively covers the following key areas:

  1. The Ten Principles of PIPEDA

We have outlined the ten key principles that form the basis of our Privacy Policy.

  1. Purposes of Collecting Personal Information

Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

  1. Consent

We will obtain client consent to collect, use or disclose personal information (except where we are allowed to do so without consent).

  1. Limiting Collection

The personal information collected will be limited to the purposes set out in this Privacy Policy, Pender contracts, and/or other documentation.

  1. Limiting Use, Disclosure and Retention

Personal information will be used for only those purposes to which the individual has consented, with a few exceptions as permitted under PIPEDA. We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection. We will retain client, customer, member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

  1. Accuracy

We will make reasonable efforts to ensure that client personal information is accurate and complete. Clients may request correction to their personal information.

  1. Safeguards

We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

  1. Openness

Pender will endeavour to make its privacy policies and procedures known to the individual via this Privacy Policy as well as the firm’s Privacy Statement (see Schedule 3 of the full Privacy Policy document).

  1. Individual Access

Clients have a right to access their personal information, subject to limited exceptions.

  1. Complaints, Recourse

If an individual has a concern about Pender Growth Fund) personal information handling practices, a complaint, in writing, may be directed to the Manager’s Chief Privacy Officer.