Privacy Policy & Cookies Notice
Last Updated: August 17, 2026
At mref.ca (operated by MREF, "we," "us," or "our"), we respect your privacy and are committed to protecting the personal information you share with us. As a registered Exempt Market Dealer (EMD) regulated by the Ontario Securities Commission (OSC), MREF is bound by the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as regulatory recordkeeping standards established under Ontario securities legislation.
1. Scope of This Policy
This Privacy Policy applies to all personal information collected, used, or disclosed through:
- Browsing or accessing the mref.ca website.
- Registering an account or accessing our online investor portal and data rooms.
- Submitting Know Your Client (KYC) documentation or subscribing to private placement offerings through MREF.
2. Information We Collect
A. Information Required for EMD Onboarding, KYC & AML Compliance
Under OSC rules, NI 31-103, and Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA), MREF is legally mandated to collect:
- Identification Data: Full legal name, date of birth, residential address, government-issued photo ID (e.g., driver's license, passport), and Social Insurance Number (SIN, collected for tax reporting and regulatory compliance).
- Financial & Investment Data: Annual net income, liquid assets, total net worth, investment objectives, time horizon, risk tolerance, employment status, source of funds, and statutory qualification status (e.g., Accredited or Eligible Investor documentation under NI 45-106).
B. Technical, Portal & Cookie Data
When you visit mref.ca or access the investor portal, we collect:
- Device & Usage Data: IP address, browser type, operating system, referrer URL, pages viewed, and access timestamps.
- Cookies & Tracking: Essential cookies (required for portal login, session security, and data room protection) and analytics cookies to evaluate site usage.
3. How We Use Your Personal Information
MREF collects and uses your personal information solely for legitimate operational, contractual, and statutory purposes, including:
- Verifying your identity in compliance with FINTRAC Anti-Money Laundering (AML) standards.
- Enabling MREF's registered Dealing Representatives (DRs) to conduct mandatory investor suitability assessments prior to processing investments.
- Providing secure access to confidential offering materials, Offering Memoranda, and electronic data rooms.
- Facilitating the execution of subscription agreements and payment processing.
- Fulfilling statutory filings with the Ontario Securities Commission (OSC) and Canada Revenue Agency (CRA).
- Communicating important updates, transactional notices, and portal alerts.
4. Third-Party Service Providers & Disclosures
MREF does not sell, lease, or trade your personal information. To facilitate your investments on mref.ca, we share relevant information with vetted third-party service providers bound by strict confidentiality and encryption standards:
Identity Verification
Purpose
Electronic KYC / AML background checks and identity validation.
Information Shared
Name, address, date of birth, photo ID documentation.
E-Signature Platforms
Purpose
Facilitating legally binding electronic execution of subscription agreements.
Information Shared
Name, email address, IP address, completed subscription contracts.
Payment Processors & Escrow
Purpose
Processing investment wire transfers, EFTs, and escrow account handling.
Information Shared
Banking details, transaction amounts, payment execution status.
Issuers & Deal Sponsors
Purpose
Finalizing unit/share issuances for private offerings you subscribe to.
Information Shared
Subscriber legal name, contact details, subscription amount, investor status.
Securities Regulators & Authorities
Purpose
Mandated statutory compliance and regulatory reporting (OSC, FINTRAC, CRA).
Information Shared
Transaction details, trade reports, audit trails as required by law.
5. CASL & Electronic Communications
In compliance with Canada’s Anti-Spam Legislation (CASL):
- Transactional & Regulatory Notices: By creating an account, you consent to receive non-promotional communications reasonably related to your account, security alerts, regulatory notices, and trade confirmations.
- Marketing Communications: MREF will only send you promotional newsletters, market insights, or new deal announcements if you explicitly opt-in. You may withdraw consent at any time.
6. Data Security & Storage
- Encryption & Controls: All traffic on mref.ca is encrypted using HTTPS / TLS protocols. Personal and financial records are encrypted both in transit and at rest.
- Canadian Data Residency: Where feasible, your data is hosted on secure servers located within Canada.
7. Record Retention
Under Ontario securities law (NI 31-103), EMDs are required to maintain complete client, KYC, suitability, and trade records for a minimum of seven (7) years following the closure of an account or transaction.
8. Your Rights & Privacy Officer Contact
For all privacy inquiries or data access requests, please contact MREF's designated Privacy Officer:
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