MCELVAINE INVESTMENT MANAGEMENT LTD.
PRIVACY POLICY
July 27, 2021
Protecting your privacy is very important to us at McElvaine Investment Management Ltd. We want to
tell you how and why we collect, use and disclose the personal information you may provide to us in the
course of investing in the McElvaine Value Fund, the Osler Fund or other investment funds that we manage
(each, a “Fund”).
Your Consent
By applying to invest in a Fund, you are indicating your consent to our collection, use and disclosure of
your personal information in the manner described below. If you do not agree with our collection, use and
disclosure of your personal information in this manner, please contact us immediately at (250) 708-8345.
Our Collection of Your Personal Information
In order to invest in a Fund, we may ask you to voluntarily provide certain personal information, such as
your personal contact information, employment information, financial and banking information, and
information regarding your investment knowledge, objectives and strategies. We request this information
to comply with applicable securities and other laws.
Our Use of Your Personal Information
We may use your personal information to contact and correspond with you, to respond to your
communications, to provide services to you, and as otherwise permitted by law.
Our Disclosure of Your Personal Information
We may disclose your personal information in the following limited circumstances:
(a) Disclosure to Agents and Service Providers - We may provide your personal information to our
agents and service providers, such as the trustee and auditors of a Fund, but only where it is
necessary to do so in connection with your investment in the Fund.
(b) Disclosure Required by Law, etc. - We may disclose your personal information (i) to a government
institution, such as a securities regulator, that has asserted its lawful authority to obtain the
information, (ii) where we have reasonable grounds to believe the information could be useful in
the investigation of unlawful activity, (iii) to comply with a subpoena or warrant or an order made
by a court, person or body with jurisdiction to compel the production of information, (iv) to comply
with court rules regarding the production of records and information, (v) to our legal counsel, or
(vi) as otherwise required by law.
Security and Access to Your Personal Information
We take the security of your personal information very seriously, and employ appropriate security
safeguards. At any time, you may request access to your personal information and information about our
privacy practices by contacting us at (250) 708-8345. Subject to certain limited exceptions prescribed by
law, you will be given reasonable access to your personal information within a reasonable time, and will
be entitled to challenge the accuracy and completeness of the information and to have it amended as
appropriate.
Your Comments
We welcome your comments and questions about our privacy practices. At any time, you may contact us
at (250) 708-8345.