Heirloom Investing – Privacy Policy

This privacy policy was last updated on September 2019.

The terms “Heirloom”, “we” and “us” refer to Heirloom Holdings, its subsidiaries and its affiliates as applicable. Heirloom is committed to protecting the privacy rights of investors, prospective investors and those who visit our website. We will take every step to maintain the confidentiality of your personal information. This Privacy Policy governs Heirloom’s collection, use and/or disclosure of individuals’ personal information. Personal information means any information about an identifiable individual.


Heirloom is required to collect and use personal information from customers and prospective customers in order to provide information about its products and services. We will not disclose your personal information to any third party without your consent or unless we are required or permitted to do so by law. Heirloom will not use personal information for any other purpose other than identified in this Privacy Policy or as otherwise identified at or before the time of collection.

Collection and Use

Website Visitors:
Heirloom does not collect any private information on visitors to its website. During your visit to Heirloom’s website, no IP addresses are stored, or cookies used to identify or record your session activities.

Newsletter subscribers:
Upon a User’s request, Heirloom will ask for, and store, individuals’ name and email address solely for the purpose of distributing newsletters and other information relevant to the requesting User. Personal data will not be subjected to automated decision-making or profiling and will only be used for the purpose intended and disclosed.

Potential and existing investors:
Information obtained from potential and existing investors will not be facilitated through our website but will be gathered directly from the Party involved. The information gathered will be subject to the terms of this Privacy Policy.


Heirloom is accountable for all personal information under its care and control. Heirloom’s Chief Compliance Officer is designated as the person responsible for the Privacy Policy and for the personal information received by Heirloom. The Privacy Officer can be reached by e-mail at [email protected]. Any questions relating to Heirloom’s handling of personal information should be directed to our Chief Compliance Officer.

Limits for Collecting, Using, Disclosing and Retaining Personal Information

Heirloom, unless required or permitted by law, does not collect, use or disclose personal information, except when it has obtained consent. In all cases, Heirloom limits the amount and type of information collected to that which is necessary to meet the purposes described above. Heirloom undertakes to keep all personal information it collects strictly confidential. All information that does not have a specific purpose or that no longer fulfills its intended purpose will be destroyed in a secure fashion. Heirloom will only retain personal information for the duration of its intended use or as otherwise required by law.

Third Parties and Service Providers

With your consent, we may obtain personal information about you from third parties. This information helps us to assess your eligibility for certain products and services. We may also disclose your personal information to service providers. However, we will ensure that service providers have similar safeguards and a similar privacy policy or that they agree to abide by ours. We are also obliged by law to provide your information to regulatory bodies within the investment industry, to government agencies or law enforcement agencies with a legal right to collect such information, or when we are in receipt of a valid court order or search warrant.


In providing personal information to Heirloom, you agree and consent that Heirloom may collect, use and disclose your personal information as outlined in this Privacy Policy or otherwise identified at or before the time of collection. If you do not agree, you should not provide any personal information to Heirloom. This, however, may render Heirloom unable to provide certain services to you. If you have asked us to provide you with information about our services or if you are receiving information about our products and no longer wish to, you may ask that we cease doing so at any time. If Heirloom requires personal information for a new purpose, it will seek consent for such new use. You may withdraw your consent at any time.

Safeguarding Personal Information

Heirloom respects the privacy of its customers and potential customers and will protect that privacy as vigorously as possible. Heirloom stores personal information in electronic and physical files that are secure and to which access is restricted. We also provide training to our employees so that they will understand the need for confidentiality when dealing with your information.

While Heirloom’s website may provide links to other websites, please be aware that Heirloom has no knowledge or control over your personal information on those websites and assumes no responsibility with respect to those websites. Please ensure that you review the privacy policies of the websites to which you link or that you view.

Accuracy of Personal Information

Heirloom makes every effort to keep personal information accurate, complete, and current. Heirloom will update any changes to personal information when received with the onus being on you to provide us with such updated information. If Heirloom holds personal information about an individual which can be established by the individual to be inaccurate, Heirloom will take reasonable steps to correct it.

Access to Personal Information

All individuals have access to their personal information when requested. Heirloom will respond to written requests within 30 days of receiving notice. We will keep records of inquiries and/or objections and will document their resolution. Heirloom will conduct all investigations in a timely, fair and impartial manner and we will address and respond to any concern you may have about our handling of your information.

Existence of Individual Rights

In addition to having access to their personal information, and the right to rectify personal data held where it is incorrect or incomplete, individuals also have the right to restrict or suspend processing of personal data. When necessary, individuals also have the right to complain to a supervisory authority.

Date: 09.2019