MIM I, LLC (Canada)

MIM I, LLC (Canada)

This Privacy Notice (the “Privacy Notice”) sets out the privacy practices for MIM I, LLC (the “Company,” “we,” “us,” “our”) with respect to how the Company collects personal information of its clients, prospective clients and other individuals (“you,” “your”). It also describes how the Company uses, maintains, retains, transfers and discloses your personal information. This Privacy Notice applies to information collected from you by the Company via institutional investors and other places and/or sources where, or means by which, we may collect personal information. This Privacy Notice also sets out how you can access certain information that the Company may collect about you and explains the choices you have regarding any collection, use, maintenance, retention, transfer and disclosure of such information, and how you may access or correct that information. In this Privacy Notice “personal information” means any information about an identifiable individual or information that allows an individual to be identified, as defined from time to time in applicable privacy legislation. “Affiliates” means companies related by common ownership or control. “Nonaffiliates” means companies not related by common ownership or control.

 

Who we are  
Who is providing this notice? MIM I LLC, a limited liability company incorporated in Pennsylvania, (1717 Arch Street 15th Floor Philadelphia, Pennsylvania, 19103 USA) (“MIM I”)

OUR COLLECTION PRACTICES:

Why?

We collect Personal Information about you to:

  • Know you. Personal information will help us serve you as our customer, to understand and meet your financial needs, understand your investment objectives and to improve our products and services.
  • Comply with Laws. In addition, we collect certain details required by governments and regulators in Canada and other countries where we and our affiliates operate, including information that helps protect MIM I and its affiliates, the financial system and our customers from financial crime.

The Personal Information we collect about you will allow us:

  • To provide our products or services;To administer your account (including administering billing activities and providing record of your transactions); 
  • To contact you and to respond to any communications from you;
  • To develop and manage our business and operations;
  • To audit compliance with our policies and contractual obligations;
  • As permitted by, and to comply with, any legal or regulatory requirements or provisions;
  •  For any other purpose to which you have given your consent.

What?

Types of Personal Information we collect
How we use it
  • Financial information and Credit history
  • Name of all Directors (or equivalent) and Beneficial Owners
  • To determine the financial condition of the client
  •  To determine the identity of the entity engaging in the relationship and the representative authorized to act on its behalf 
  • To comply with anti-money laundering laws and applicable sanctions screening programs

How?

Your Consent:

By submitting personal information to us you agree that we may collect, use, maintain, retain, transfer and disclose such personal information in accordance with this Privacy Notice and as permitted or required by applicable laws.
Subject to legal and contractual requirements, you may refuse or withdraw your consent at any time by contacting the Company at the address provided below. If you refuse or withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with certain services, products or information.
We may collect personal information from you indirectly when you have given other organizations, including our affiliates, permission to share it, for example when you buy a product or service from them. We may also collect Personal Information through third parties you have authorized to provide to us. The information we receive from other organization/entities depends on your consent options as given to them.
If you provide us with personal information of another individual, you represent to us that you have that individual’s consent to allow us to collect, use, maintain, retain, transfer and disclose that personal information in accordance with this Privacy Notice.

You are responsible for ensuring the accuracy of the personal information that you submit to us. In certain situations, we may use, maintain, retain, transfer or disclose personal information without your knowledge or consent (as permitted or required by law). These circumstances may be:

  • Where your personal information is publicly available.
  • To investigate a breach of an agreement or a contravention of law.
  • In the event of a corporate change in control of the Company resulting from, for example, a merger, a reorganization, a sale of assets or bankruptcy.
  • To comply with a subpoena, warrant, court order or as required or otherwise permitted by law; and
  • When information is being collected for the detection and prevention of fraud or for law enforcement.

How long do we retain your personal information?

We determine our retention periods based on criteria such as: (a.) the ongoing nature and/or the duration of our relationship with you, (b.) to meet legal requirements to which we are subject, including required regulatory retention periods (c.) whether retention is advisable to comply with applicable statutes of limitation, regulatory investigations and defense to legal claims. The applicable retention period determines how long the information may be kept before being securely disposed of. Certain information may be deleted upon client request following the required retention period and barring any regulatory investigations and defense to legal claims.

 

Disclosure of your personal Information

Except as provided for in this Privacy Notice, we will not sell, rent, lease, commercially exploit or otherwise disclose your personal information or data to third parties unless: (a) we are required to do so by law or to cooperate with legal investigations; (b) it is required to protect the legal interests of the Company; or (c) you provide consent to such disclosure.

 

Reasons we can share your personal information
Does MIM I share?
For our everyday business purposes – Such as to process your transactions, maintain your account(s), respond to court orders and legal investigations,
Yes
For our marketing purposes – To offer our products and services to you No
For joint marketing with other financial companies No
For our affiliates’ everyday business purposes Information about your transactions and experiences No
For our affiliates’ everyday business purposes  No
For nonaffiliates to market to you No

 

 

Accountability
How does MIM I safeguard your personal information? We limit access to the personal information we have about you to MIM I and its associates’ employees only as it is necessary for them to perform their jobs, provide our services to you and respond to your inquiries. To protect your personal information we maintain, physical, electronic and organizational safeguards in accordance with applicable laws and industry standards, which we review and adapt for adequacy as technologies evolve and as new risks emerge.
Transfer of your information Your personal information may be used, stored, processed, disclosed, retained and transferred through countries other than your home country, in which cases the personal information is bound by the laws of these countries. By requesting our services you consent to such use, storage, processing, disclosure, retention and transfer
Your choices - Access to, and Correction of, Your Personal Information If you do not want your personal information collected, used, maintained, transferred, disclosed or retained by us as provided in this Privacy Notice, you should refrain from: (a) registering for any specific tool or application that collects personal information; (b) purchasing any product or service from us; and (c) filling out any forms or questionnaires. You may request a copy of the personal information which you have provided to us by advising our Company at the address provided below. If you have any questions or enquiries relating to our privacy practices or procedures, or if you believe that the personal information that the Company holds about you is not accurate, complete or up to date, you may write to the Company at the address provided below.If you are able to establish that the information is not accurate, complete or up to date, we will take reasonable steps to correct the information so that it Page 5 of 5 is accurate, complete and up-to-date.
Questions?

Questions or concerns regarding MIM I personal information governance and protection practices as described in this Privacy Notice should be addressed to:

Nicolas Ferrer
Investments Compliance | MetLife
One MetLife Way, Whippany, NJ 07981 United States of America
Nicolas.Ferrer@metlife.com

If you choose to contact MIM I via email, please mark the subject heading of your email “MIM I Privacy Inquiry"

UPDATES TO THIS NOTICE:
We may modify this notice from time to time and will post the most current version online. Please visit this page for updates and changes.