Privacy Policy

Last updated: June 2025

Our Commitment to Your Privacy

Summerhill Capital Management Inc. is committed to protecting the privacy and confidentiality of your personal information. We collect, use, and disclose your personal information responsibly and only as permitted or required by law.

What is Personal Information?

Personal information means any information about an identifiable individual, including but not limited to your name, address, date of birth, contact details, Social Insurance Number, financial and employment information, and account activity.

How We Collect Personal Information

We collect personal information directly from you or through your authorized representatives (such as your trusted persons/power of attorney), as well as from forms, applications, and other documents you provide to us. We may also generate information about you in the course of managing your accounts or providing services. In some cases, we may collect information from third parties as permitted by law.

How We Use Your Personal Information

We use your personal information to:

Establish and manage your account(s)
Provide investment management and related services
Communicate with you about your account(s) and our products and services
Meet legal, regulatory, and tax requirements
Detect and prevent fraud and other unauthorized or illegal activities
Improve our products and services

We do not sell or lease your personal information.

Consent

By providing us with your personal information, you consent to our collection, use, and disclosure of that information as described in this Policy and as otherwise permitted or required by law. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. However, withdrawing consent may affect our ability to provide you with certain products or services.

Disclosure of Personal Information

We may disclose your personal information:

To service providers and third parties who assist us in providing services to you (subject to confidentiality agreements)
As required or permitted by law or regulatory authorities
To credit bureaus, government agencies, or law enforcement as necessary
In connection with a business transaction, such as a merger or sale of assets.

Some of these parties may be located outside of Canada, and your information may be transferred, processed, or stored in other jurisdictions. We ensure that appropriate safeguards are in place to protect your information in such cases.

Protecting Your Information

We maintain physical, electronic, and procedural safeguards appropriate to the sensitivity of your personal information to protect it from loss, theft, unauthorized access, disclosure, copying, use, or modification.

Retention of Personal Information

We retain your personal information only as long as necessary to fulfill the purposes for which it was collected or as required by law.

Accessing and Correcting Your Information

You have the right to request access to the personal information we hold about you and to request corrections if you believe it is inaccurate or incomplete. To make such a request, please contact our Privacy Officer (see below).

Your Rights (Including Quebec Residents)

Depending on your province of residence, you may have additional rights, such as data portability, the right to withdraw consent, and the right to request deletion of your personal information. Quebec residents may also request information about the transfer of their personal information outside Quebec.

Changes to This Policy

We may update this Privacy Policy from time to time. The most current version will always be available on our website, with the effective date noted at the top of the Policy.

If you have questions about this Policy, wish to access or correct your personal information, or have a privacy-related complaint, please contact our Compliance/Privacy Officer:

Privacy Officer: Mary Throop
Summerhill Capital Management Inc.
401 Bay Street, Suite 1600 Toronto ON M5H 2Y4
compliance@sumcap.com
416-628-7282

This Policy is intended to comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec’s Act Respecting the Protection of Personal Information in the Private Sector, and other applicable privacy laws.