Protecting our clients’ privacy is a priority for YL Capital Ltd. (“YLC”). These Privacy Principles are adhered to by YLC to ensure that the information you submit to us will be treated with the utmost confidentiality. YL Capital Ltd. is responsible for Personal Information in its custody and control and has designated a Privacy Officer who is accountable for ensuring our compliance with applicable privacy legislation, including British Columbia's Personal Information Protection Act ("PIPA") and, where applicable, the federal Personal Information Protection and Electronic Documents Act ("PIPEDA").
Your personal privacy is important to us, and as part of our commitment to safeguarding information about you that you have entrusted to us, we share the following details with you so that you understand how your Personal Information is collected, used, and disclosed. Furthermore, we believe in transparency and accountability, and we encourage you to review our Policy regularly to stay informed about any updates or changes.
Depending on the nature of the business relationship, we collect certain information from you to meet our business, legal, and regulatory requirements. In all cases, we collect only the personal financial information necessary to provide personalized investment services and for other purposes that a reasonable person would consider appropriate in the circumstances
The types of Personal Information we collect may include:
- Identification and contact information: such as name, residential address, email, phone number, date of birth, government-issued identification numbers, citizenship and residency status.
- Know-your-client and suitability information: such as occupation, employer, financial situation, investment objectives, risk tolerance, investment experience and time horizon.
- Account and transaction information: such as account numbers, holdings, transaction history, subscription and redemption details, and bank account information for payments.
- Regulatory and compliance information: including information required to comply with anti-money-laundering and anti-terrorist financing obligations, sanctions screening, politically exposed person status, and source of funds or wealth verification.
- Online and technical information: such as login credentials for online portals, IP addresses, and device information.
We may collect Personal Information directly from you or from third parties such as your dealer, custodian, fund administrator or other financial institutions, where permitted by law.
We collect and use Personal Information to:
- Establish, administer and service investment management, advisory and exempt market distribution relationships.
- Determine investment suitability and provide discretionary and non discretionary portfolio management services.
- Operate and administer investment funds for which we act as investment fund manager.
- Process subscriptions, redemptions, transfers, distributions and other fund or account transactions.
- Comply with our obligations as an investment fund manager, portfolio manager and exempt market dealer under securities, anti-money-laundering and tax laws and regulatory requirements (including those of the British Columbia Securities Commission and other members of the Canadian Securities Administrators).
- Manage risk, including credit, operational, legal and reputational risk.
- Communicate with you about your accounts, holdings, transactions, statements and other service-related matters.
- Respond to your inquiries, requests and complaints.
- Conduct business development and marketing activities (subject to applicable consent requirements and your marketing preferences).
- Maintain and improve our systems, technology and security.
- Any other purpose for which we have obtained your consent or that is otherwise permitted or required by law.
Information will be retained for specific timeframes as required by law and as long as necessary to fulfill the purposes identified in this Policy. Information may be disclosed as required by law. Information is also shared with third-party service providers that have been engaged by YLC. Confidentiality agreements are in place with the service providers.
YLC treats all personal information in a confidential manner, in accordance with British Columbia's Personal Information Protection Act ("PIPA") and, where applicable, the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), which governs the collection, use, and disclosure of personal information. Personal information will not be used or disclosed for purposes other than those for which it was collected unless you provide express consent or if required or permitted by law.
We obtain your consent to the collection, use, and disclosure of your Personal Information through the act of providing us with the information. Implied consent may also be obtained through actions such as using our services or inactions such as failing to opt out when given the opportunity. If you decline to provide your Personal Information, you may be ineligible to access or receive certain products and services.
In some situations, PIPA and other applicable laws allow us to collect, use or disclose Personal Information without your consent, for example, where we are investigating a breach of an agreement or a contravention of the law, to respond to regulatory or law-enforcement requests, to collect a debt, or in the context of certain business transactions.
You may withdraw your consent to our collection, use or disclosure of your Personal Information, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer. Withdrawal of consent may affect our ability to provide you with certain products or services.
Your Personal Information may be shared with our third-party service providers to manage products and services on our behalf relating to the operation of your Account. Service providers may include custodians, brokers, portfolio trading and execution platforms, fund administrators, transfer agents, record-keepers, pricing and valuation vendors, client reporting providers and other dealers or advisers involved in your account or investment.
Our service providers are given only the information necessary to perform the required services and are subject to regulatory requirements in their country of jurisdiction, imposing data security obligations on the ways in which they process personal information.
Some of our service providers, including our cloud storage provider and other technology providers, may be located outside British Columbia and Canada, including in the United States and other countries where the provider or its sub-processors operate data centres. As a result, your Personal Information may be stored, processed or accessed in those jurisdictions and may be subject to the laws of those jurisdictions and accessible to courts, law enforcement and national security authorities in those jurisdictions. We take reasonable steps to ensure that service providers who handle Personal Information on our behalf protect it with safeguards comparable to those we use and use it only for the purposes for which it is provided.
Your Personal Information may be disclosed in response to a regulatory inquiry, audit or investigation, or a legally valid request, which may include lawful inquiries from authorities, inside or outside your home jurisdiction. We may disclose Personal Information to securities and other regulators, exchanges, self-regulatory organizations and government authorities in Canada and in other relevant jurisdictions, as required or permitted by applicable law, in connection with our registration as investment fund manager, portfolio manager and exempt market dealer and the products and services we provide.
We may also share your name, contact information, and holdings with issuers of securities that you hold in your Account and other individuals/companies as required by securities law, for the purpose of sending you financial reports, tax documents, and other relevant materials.
Furthermore, we may disclose Personal Information in limited circumstances where we believe, in good faith, that the disclosure is required, authorized under the law, or advisable to protect our interests or the rights, property or safety of you or others.
We maintain reasonable security procedures and standards to prevent unauthorized access to confidential information. We provide training to our employees about the importance of confidentiality and privacy. Personal Information in our possession is kept in our office, on encrypted cloud-based storage and other secure systems.
We employ administrative, technical and physical safeguards that are appropriate to the sensitivity of the Personal Information, including access controls, encryption and secure storage, and require employees and service providers who have access to Personal Information to keep it confidential and to use it only for authorized purposes.
In the event of a data breach involving your Personal Information, we will notify affected individuals as required by law. Notifications will include the nature of the breach, the potential impact, and steps being taken to address the situation. Where required, we will also notify the appropriate privacy regulator, such as the Office of the Information and Privacy Commissioner for British Columbia.
Personal information will be as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. If you discover any inaccuracies in the Personal Information we have on record, please let us know, and we will make the necessary corrections.
Upon your request, you will be informed of the existence, use and disclosure of your personal information and shall be given access to that information. We will provide you with general access to your Personal Information as required by law. To request access, please submit your inquiry in writing.
If you believe that your request for access to Personal Information has been unjustly denied, or if you have concerns about the accuracy or completeness of your records, you may escalate your concern by contacting our Privacy Officer at compliance@ylcapital.ca. The Privacy Officer will review your concern and provide a written response within 30 days.
If you remain dissatisfied after we have responded, you may contact the Office of the Information and Privacy Commissioner for British Columbia to file a complaint:
Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038 Stn Prov Govt
Victoria, B.C. V8W 9A4
Phone: 250-387-5629
Toll-free: 1-800-663-7867
Website: www.oipc.bc.ca
If your complaint relates to Personal Information that is subject to the federal Personal Information Protection and Electronic Documents Act (PIPEDA), you may also have the right to contact the Office of the Privacy Commissioner of Canada.
Contact Information
Should you have any questions or concerns regarding your privacy or the information outlined in
this policy, please reach out to our Privacy Officer at:
YL Capital Ltd.
Attn: Privacy Officer
Suite 1500 – 701 West Georgia Street
Vancouver, BC,
V7Y 1G5
Email: compliance@ylcapital.ca
This Privacy Policy is effective as of January 22, 2026.
