At Grandeur Peak Global Advisors, LLC (“Grandeur Peak,” “we,” “us,” “our”), we understand that our relationship with you, and with all shareholders in the Grandeur Peak Funds, is one of trust. As such, we strive to protect the information we collect about you and your accounts. This Privacy Policy describes how Grandeur Peak collects, uses, and shares Personal Information (as defined below).
This Privacy Policy applies to use of this website, https://grandeurpeakglobal.com (the “Website”). By using the Website, you accept and consent to the terms of this Privacy Policy. There are also privacy policies that apply specifically to the Grandeur Peak Funds which are included in the fund prospectus. You can obtain a copy of the prospectus by clicking on this link or by calling 1-855-377-7325.
This Website may include links to third-party sites or information that we think may be of interest to you. When you click these links and leave the Website, our Website’s Terms of Use and Privacy Policy no longer apply. You are responsible for complying with the third-party site’s terms of use and understanding its privacy policy, both of which you should review carefully.
What is Personal Information and how do we collect it?
“Personal Information” includes any information that we collect that, alone or in combination with other information, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual. It generally means the same as the terms “personally identifiable information,” or “personal data,” or “nonpublic personal information” as defined under applicable data protection laws.
Most of the Personal Information we collect comes directly from you. The ways we gather it may include:
Account applications and online access. From information you provide when you open an account, enter information in an online account application, or access your account through a link on the Website.
Transactions. Through current and historical records of your accounts and transactions with Grandeur Peak or the Grandeur Peak Funds, and related account statements.
Third-Parties. From third-parties who you have authorized to share personal information with us and from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
Website. By information collected from “cookies” are used on this Website. For example, we may identify the web pages your browser requests or visits. For more information, please read the “Cookies” and “Third-party analytics” sections below.
What kind of Personal Information do we collect?
Personal Information we collect may include:
- Identifiers and certain protected information, like your name and address, email address, telephone number, signature, driver’s license number, Social Security or taxpayer identification number, and date of birth;
- Information about protected characteristics regarding your citizenship, race or ethnic origin, marital status, or sex/gender information;
- Financial information like assets, income, account balances, financial account credentials, investment activity, and accounts at other institutions;
- Employment-related information, including information about your job and title;
- Education information, including level of education attained, where you attained your education, and what years you were there;
- Commercial information, such as services purchased, obtained, or considered or other purchasing or consuming histories or tendencies;
- Audio or visual information, such as recordings of telephone calls or visual calls to Grandeur Peak;
- Internet or other similar network activity, including usage information regarding the pages you view, links you click or hover over, selections you make on the Website, features you use, preferences you set, other actions that you perform on our websites, the internet protocol (“IP”) address of the device you are using to access the services, computer browser type, device manufacturer, operating system, domain name, average time spent on certain website pages; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; your general geographic location (e.g., your city, state, or zip code); and the website visited before our Website;
- Inferences drawn from other personal information, including information we collect and use about your use of this Website.
Some of the information above, such as Social Security numbers and driver’s license numbers, is considered “sensitive personal information” under applicable law.
We may combine the Personal Information collected on this Website with Personal Information collected from or about you in other contexts. This may include Personal Information collected through publicly available sources or online, such as through our email exchanges with you, or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined Personal Information in accordance with this policy.
If you do not wish to provide Personal Information to Grandeur Peak, we may be unable to provide certain products or services to you.
How do we treat your Personal Information?
We strive to treat Personal Information that we collect or that you disclose to us with the utmost care and respect for your privacy. Our use of any Personal Information is motivated by our desire to serve you better.
- We will not disclose your Personal Information to anyone unless it is necessary to provide you with our services, at your direction, required by law, or for another purpose described in this Privacy Policy.
- We do not allow individuals or companies that provide services to Grandeur Peak to use your personal information for their own marketing purposes.
- We maintain contracts with individuals or companies providing services to Grandeur Peak’s shareholders that require them to protect the confidentiality of your Personal Information.
- We afford the same protection of Personal Information to prospective and former shareholders that we do to current shareholders.
- We consider all of the information we have about you to be confidential, including whether you are a Grandeur Peak shareholder (unless you tell us otherwise).
- We restrict access to your Personal Information to employees who service your accounts.
- We maintain physical, electronic and procedural safeguards designed to maintain the confidentiality of your information.
- In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Grandeur Peak. For example, if you ask to transfer assets from another financial institution to Grandeur Peak, we will need to provide certain information about you to that company to complete the transaction.
How do we use your Personal Information?
We and third-parties working on our behalf may use the information we collect about you for various purposes, including:
- To respond to your requests or to communicate with you;
- To provide you with information or services you requested;
- To personalize your experience on this Website or with our products or services;
- To monitor and ensure compliance with the Website’s Terms of Use;
- To send email communications or information about our products or services that may be of interest to you;
- To analyze usage trends;
- To improve and enhance the functionality of this Website or our products and services;
- For recruitment and employment-related purposes (including conducting background checks and employment eligibility verification, for interview purposes, payroll administration and employee timekeeping, benefit administration);
- For other legitimate business purposes; and
- For other purposes, with your consent.
In certain circumstances, we may aggregate and/or de-identify information collected for additional purposes.
We may disclose Personal Information about our current and former shareholders to third-parties for the following purposes:
- To service your account and process your transactions. We may share your Personal Information with non-affiliated companies or individuals that we contract with in order to provide services. These may include payment processing; printing and mail services; providing products or services to you on our behalf; creating or maintaining our networks, systems, and databases; analytics; providing support; marketing our products and services; or responding to inquiries.
- To respond to your requests. For example, you may direct us to send your statements and confirmations to a third-party.
- To comply with laws or regulations. We may be legally required to disclose or report Personal Information, for example, to respond to a subpoena, court order or regulatory demand made by proper authorities.
- To the extent permitted by law. For example, the law permits us to respond to a request for information from a consumer reporting agency.
- To enable business transactions. In the event of a merger, sale of the business, bankruptcy proceeding, or similar transaction, we may exchange your Personal Information with the other entity involved in the transaction.
- To protect our interests, rights, safety, or property or those of others.
- Any other sharing or disclosure with your consent.
What other terms apply to Personal Information or this Privacy Policy?
Privacy Policy Changes
In its sole discretion, Grandeur Peak may change its Privacy Policy from time to time and at any time by posting the revised version of the Privacy Policy on the Website and updating the last modified date. We encourages visitors to the Website to frequently check this page for any changes to the Privacy Policy. Your continued use of this Website after any change in this Privacy Policy will constitute your acceptance of any such changes.
Transfer of Personal Information
The Personal Information we collect about you may be transferred to or stored by Grandeur Peak or our service providers in the United States or elsewhere, as permitted by law. If you reside outside the United States and use our website or otherwise provide information to us, you acknowledge that your information will be transferred to and processed in the United States and in accordance with the laws of the United States, which may not provide the same levels of privacy protection as the laws in your jurisdiction.
Online Privacy Protections
Our Website and the websites of third-party service providers who provide services relating to and in support of the Grandeur Peak Funds and other accounts advised by Grandeur Peak use secure forms of online communication, which may include data encryption, transmission encryption, user names and passwords, and back-end fraud and account monitoring. However, no security system is entirely secure. As a result, while we will certainly strive to protect your Personal Information, we cannot guarantee or warrant the security of any information you transmit.
Information About Children
We do not knowingly collect Personal Information from children under the age of 16. If we discover that we have inadvertently collected any information from a child under the age of 16, we will promptly delete it. If you are a parent or guardian and believe your child provided us with their Personal Information without your consent, please contact us.
Marketing Communications
We may send you marketing correspondence about our services, which may be sent by email. To unsubscribe from these communications, please follow the unsubscribe instructions contained in the emails or contact us using the contact information below.
Cookies
We may use a variety of online technologies, such as cookies, web beacons, and similar mechanisms, to collect information that helps us understand how our website are used. A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. We or third-parties may use such information for certain purposes, including to support functions on the website, to enhance your experience with the website, or to analyze and compile the usage of the Website and communications from us. Users of the Website who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using the Website, with the drawback that certain features of the Website may not function properly without the aid of cookies.
If you are a shareholder in the Grandeur Peak Funds or other account advised by Grandeur Peak who has registered for secure online access to your Grandeur Peak account, we may combine information about your usage of our Website during a secure (logged-on) session in your account with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to the Website, even if you do not log on, and link information about that visit to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Website, as well as to identify ways that we can better serve you and services that may be of interest to you.
Some web browsers have “do not track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Our Website does not track your browser’s “do not track” settings.
Third-party analytics
We may partner with third-parties to manage or operate the Website, which may include collecting such information as discussed above to engage in analysis, auditing, research, and reporting. These third-parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our Website. In particular, the Website may use third-party analytics services to help collect and analyze certain information for the purposes discussed above.
Your Rights Under California Law
California residents have certain privacy rights under the California Consumer Privacy Act (“CCPA”). The CCPA also provides certain exemptions that may apply to the Personal Information we collect from or about you. For example, personal information subject to the protections of the Gramm-Leach-Bliley Act of 1999 or the California Financial Information Privacy Act may be exempt from the requirements of the CCPA. To the extent that your Personal Information does not fall under an enumerated exemption, California residents have the following rights:
- The Right to Know: You have the right to request that we disclose to you details about the personal information we collect, use, disclose, or sell. This includes the specific pieces of personal information we have collected from or about you.
- The Right to Request Deletion: You have the right to request that we delete any of your personal information under our control.
- The Right to Correct: You have the right to request that we correct any inaccurate information that we maintain about you.
- The Right to Limit the Use and Disclosure of Sensitive Personal Information: As described above, some of the information we collect may be considered sensitive personal information. You have the right to request that we limit the use and disclosure of your sensitive personal information to that use which is necessary to provide you with Services you have requested and for certain other limited purposes as provided for under the CCPA.
- The Right to Non-Discrimination: If you choose to exercise any of these rights, you will not receive any discriminatory treatment from us.
Verification. In order to protect the integrity of our products and services, as well as your Personal Information, we may need to verify your identity before processing any requests. We will not fulfill any request regarding Personal Information unless we have sufficient information to reasonably verify you are the individual about whom we collected the Personal Information.
Authorized Agent. Under California law, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. Please note, any authorized agent must have written permission from you to make such a request, and will be subject to identity verification.
Sale or Sharing of Personal Information. Grandeur Peak does not “sell” or “share” Personal Information, as those terms are defined in CCPA. Grandeur Peak has not sold or shared Personal Information in the prior 12 months.
Other California Privacy Rights. Under California’s “Shine the Light” law (California Civil Code Section 1798.83), California residents are entitled to request and obtain from Grandeur Peak once per calendar year information about when we share your Personal Information with third-parties for those third-parties’ own direct marketing purposes. We do not share Personal Information with third-parties for their direct marketing purposes; however, to request more information, please email us at the address indicated below, and note “California Shine the Light” in the subject line.
To exercise your rights under the CCPA with respect to the Website and this Privacy Policy, please send a detailed request to:
OR
Grandeur Peak Global Advisors
Attn: Client Team
136 South Main Street, Suite 720
Salt Lake City, Utah 84101
What can you do to safeguard your Personal Information?
For your protection, you should not provide your account information, user name, or password to anyone. If you become aware of any suspicious activity relating to your account, it is your responsibility to contact us immediately.
How can you contact us regarding this Privacy Policy?
If you have any questions relating to this privacy policy or concerns about the way in which we have handled your Personal Information, please send us a detailed message to:
OR
Grandeur Peak Global Advisors
Attn: Client Team
136 South Main Street, Suite 720
Salt Lake City, Utah 84101
We will strive to respond promptly and work to resolve your concerns.
