1. TIFL’s Accountability
TIFL is accountable for all personal information in its possession or control, including any personal information transferred to third parties for processing. TIFL has established policies and procedures to comply with this Privacy Code, and has designated one or more persons accountable for compliance.
2. Identifying the Purposes of Collecting Personal Information
TIFL will inform individuals of the purpose for which personal information will be used before or when they consent to its collection.
3. Obtaining Consent
TIFL will obtain consent before or when it collects, uses or discloses personal information about an individual.
An individual can provide consent to the collection, use and disclosure of personal information about them expressly, implicitly, or through an authorized representative. An individual can withdraw consent at any time, with certain exceptions.
TIFL will collect, use or disclose personal information without an individual’s consent only in limited circumstances as permitted by law.
4. Limits for Collecting Personal Information
TIFL limits the amount and type of personal information it collects. TIFL will collect personal information only for the identified purposes or as otherwise permitted by law.
5. Limits for Using, Disclosing and Keeping Personal Information
TIFL will use or disclose personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason.
Under certain circumstances, TIFL may have a legal duty or right to disclose personal information without consent.
TIFL will keep personal information only as long as necessary for the identified purposes.
6. Keeping Personal Information Accurate
TIFL will keep the personal information in its possession or control accurate, complete, current and relevant, based on the most recent information available to TIFL.
Individuals may challenge the accuracy and completeness of personal information about them and have it amended as appropriate.
7. Safeguarding Personal Information
TIFL protects personal information with safeguards appropriate to the sensitivity of the information.
8. Making Information about Policies and Procedures Available
TIFL will be open about the procedures used to manage personal information. Individuals will have access to information about these procedures through this Privacy Code, by contacting our Investment Fund Associates or by contacting the Privacy Office. The information will be available in a format that is easy to understand.
9. Providing Access to Personal Information
When an individual requests it, when possible, TIFL will advise the individual what personal information TIFL has in its possession or control about the individual, what it is being used for, and to whom it has been disclosed.
When an individual requests it, TIFL will give an individual access to personal information about them which is in the possession or control of TIFL. In certain situations, however, TIFL may not be able to give individuals access to all of their personal information.
10. Handling Complaints and Questions
Individuals may challenge TIFL’s compliance with this Privacy Code. Complaints and inquiries should be directed to our Investment Fund Associates or sent to the Privacy Office.