Blue Couch Privacy Policy

Blue Couch Fund Administration (collectively “Blue Couch”, “we”, “us”) is committed to maintaining the accuracy, security and privacy of the Personal Information submitted to us by our clients and others with whom we do business (hereinafter collectively referred to as “you”), in accordance with applicable legislation. This Privacy Policy is a statement of the principles and guidelines we apply with respect to your Personal Information.



You may refuse or withdraw your consent at any time by contacting the Blue Couch Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide, or continue to provide, our services to you. We will rely, unless you specifically advise us to the contrary in writing at the time, upon your personal representation that you have all necessary authority and/or have obtained all necessary consents to enable us to collect, use and disclose any Personal Information of another individual which you may provide to us, for all purposes permitted by this Privacy Policy.

What Personal Information does Blue Couch collect?

Applicable privacy legislation defines “personal information” very broadly. Generally speaking, it will be information which:

Is about an identifiable individual; or

Allows an individual to be identified; and

In either case, is not information which is already “public” according to exceptions set forth in the applicable legislation.

In this policy, our use of the term “Personal Information” means information which is defined as being personal information under the applicable privacy legislation, and which is not exempted under such legislation.

Generally speaking Personal Information does not include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or e-mail address. Certain information, such as your name, home address and telephone number, may be exempted under applicable legislation. In addition to this information, we may also collect your personal email address, income and employment information, asset, liability and net worth information, and other information which is necessary for us to gather in connection with an application, pre-approval, or request for information concerning mortgages, loans or other products or services purchased or applied for through Blue Couch (including Personal Information about family members, beneficiaries, directors, officers, employees, potential guarantors and other relevant parties).

Why does Blue Couch collect your Personal Information?

We have a professional obligation to maintain the confidential information we receive from you, and nothing in this Privacy Policy is intended to limit our common law obligations to you.


The privacy of our investors is very important to us. Set forth below are Blue Couch’s policies with respect to Personal Information of investors and former investors of Blue Couch that we collect, use and disclose. In connection with the investment, we collect and maintain Personal Information about our investors. We collect investors’ Personal Information to enable us to provide them with services in connection with an investment in Vector Financial, to meet contractual legal, regulatory and income tax requirements and for any other purpose to which investors may consent in the future. Investors’ Personal Information is collected from the following sources:

KYC Information or other forms that they submit to us;

Their transactions with us and our affiliates; and

Meetings and telephone conversations with them.

Unless an investor otherwise advises, by providing us with their Personal Information they have consented to our collection, use and disclosure of their information as provided herein. We collect and maintain their Personal Information in order to conduct a suitability assessment, provide services to investors in connection with their investments, comply with legal and regulatory requirements (such as establishing the identity of the investor), provide them the best possible service and protect us and investors from error and fraud, and for any other purpose related to the products and services of Foremost or its affiliates to which investors may consent.

We may disclose investors’ Personal Information to third parties, when necessary, and to our affiliates in connection with the services we provide related to their investment with Vector Financial, including:

Financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of Blue Couch;

Other service providers to Blue Couch, such as technology, administration, printing, marketing, accounting, legal, or tax preparation services; and

Taxation and regulatory authorities and agencies.

We require that our third-party service providers have similar privacy policies, or agree to acknowledge and abide by ours.

We seek to carefully safeguard investors’ Personal Information and, to that end, restrict access to Personal Information about them to those employees and other persons who need to know the information to enable us to provide services to them. Each employee of Blue Couch is responsible for ensuring the confidentiality of all personal information they may access.

Investor residents in Ontario should be aware that Blue Couch is required to file with the Ontario Securities Commission (“OSC”) a report setting out the investor’s name and address, the date of issuance and the purchase price of the security issued to the investor. Such information is collected indirectly by the OSC under the authority granted to them in provincial securities legislation, for the purposes of the administration and enforcement of the securities legislation.

By submitting a participation request, the investor authorizes such indirect collection of the information by the OSC. The following official can answer questions about the OSC’s indirect collection of the information:

Administrative Support Clerk

Ontario Securities Commission (“OSC”)

Suite 1903, Box 55, 20 Queen Street West

Toronto, Ontario M5H 3S8

Telephone: (416) 593-3684

Facsimile: (416) 593-8122


Where do we maintain your Personal Information?

Investors’ Personal Information is maintained on our networks, or on the networks of our service providers, and are accessible at Blue Couch. Personal information may also be stored on a secure offsite storage facility. Investors may access their personal information to verify its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting Blue Couch by phone at 416-XXX-XXXX by contacting our Blue Couch Privacy Officer. Please note that an investor’s ability to participate in the investment may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above.

How do we protect your Personal Information?

To help protect the confidentiality of your Personal Information, we endeavor to operate secure data networks protected by industry standard firewall and password protection systems.

Changes to the Privacy Policy

Blue Couch reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our website ( and make such revised policy and changes available upon request to our Privacy Officer.