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Stonebrooke Asset Management Ltd. Privacy Policy

This Privacy Policy sets out Stonebrooke Asset Management Ltd.’s standards for collecting, using, disclosing and storing your personal information. The Privacy Policy also explains how we safeguard your personal information and your right to access that information.

Stonebrooke Asset Management Ltd. (SAM) understands your privacy is important and is committed to maintaining your confidentiality. This notice will help you understand what types of non-public personal information - information about you that is not publicly available – we may collect, how we use it and how we protect your privacy.

We recognize that you expect your personal information to be handled in a professional, confidential manner and we have adopted the following policies to safeguard your privacy and to explain the circumstances, under which we may collect, maintain and use any non-public personally identifiable information that you may provide us.

We collect information about you to help us serve your financial needs, provide client support, offer new products or services, and fulfill legal regulatory requirements. The type of information we collect may include:

  • Personal Information: Information we receive from you on applications or other forms (e.g., your name, address, social insurance number, lifestyle or health information, financial situation, etc.). Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.
  • Transactional Information: Information about your transactions with us or others (e.g., your account balance, payment history, and transaction amounts).
  • Credit Report: Information that we receive from a consumer reporting agency (e.g., your creditworthiness and/or credit history) as applicable.

We do not share non-public personal information about you with unaffiliated third parties with whomwe have no contractual business relationship for their independent use unless (1) you give us permission, (2) it is necessary to complete a transaction on your behalf, (3) it is necessary to protectagainst fraud, comply with a subpoena or other court order, or is otherwise required or permitted by law.

We do not sell information about you to outside unaffiliated companies. Further, we restrict access to your personal and account information to those employees and affiliated third parties who need to know that information to provide products or services to you and maintain strict physical, electronic, and procedural safeguards to guard your non-public personal information.

If you decide to close your accounts(s) or become an inactive client, we will adhere to the privacy policies and practices described in this notice.

We reserve the right to change these privacy policies at any time. You will receive appropriate notice of changes to our Privacy Policy. You may opt-out of the disclosure of non-public personal information to a non-affiliated third party by giving us notice in writing or email.

Purpose of Information Collection

Collecting information about you is necessary in order for us to provide you with high quality services. The nature and sensitivity of the information we collect about you varies according to the services we provide you and to legal requirements imposed on us (such as your social insurance number, where investment income is generated by a chosen product, etc.).

The purposes for which we collect personal information about you are identified at or before the time of collection. For example, information may be collected while submitting an application, opening an account, or sub-mitting a claim.

Purposes for collecting information generally include providing products or services requested, confirming your identity, protecting against fraud, or dealing with matters concerning the relationship between us.

Any questions and concerns you may have regarding the purposes for collecting information may be directed to us at the address provided below.

Consent

When we collect personal information from you, we obtain your consent to use the information for the purposes collected. We will obtain your consent for any additional use or collection, or if the purpose of using the information is changed.

We generally seek your express written consent in order to collect, use or disclose personal information. Where appropriate, for less sensitive information, we may accept your verbal consent. Occasionally, we may imply consent where we can infer consent from your action or inaction.

Consent must be given by you or your authorized representative such as a legal guardian or a person having power of attorney.

You may withdraw your consent at any time, subject to legal or contractual restrictions (for example,your right to withdraw consent is necessarily limited where we need information to extend a loan against the value of a policy issued by us). We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or process a request. If you choose not to consent, we will record the decision in our file.

In limited circumstances, we have the right (or obligation) to collect, use or disclose personal information without your knowledge and consent. This occurs when legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for theinvestigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking consent might defeat the purpose of the information collection. Similarly, seeking consent may be impossible or inappropriate when you are a minor, seriously ill or otherwise incapacitated.

Limits to the Collection, User and Disclosure

We limit the collection of your personal information to what we need in relation to the purposes identified to you.

We collect the information directly from you unless you allow us to collect information from a third party or in accordance with the law.

We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use your personal information for other purposes without your consent, except as required by law.

We cannot disclose your personal information to anyone except with your consent or as required by law.

Your personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties.

You have the right to know, on request, to whom the information was disclosed. Only in rare instances are we prevented by law from making such disclosure. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.

We will occasionally share your personal information with service providers or agents to ensure the proper administration of products, or to provide you with the services you require. These service providers or agents must agree to comply with privacy legislation before receiving any personal information. In certain circumstances, we may use service providers outside Canada, including the United States. We are responsible for the service provider’s compliance with our Privacy Policy and will ensure that the level of protection of personal information is comparable to that provided by us. Any questions concerning the collection, transfer or use of personal information outside Canada can be forwarded to the Privacy Officer at the address provided below.

Retention

We only retain your personal information for as long as needed for the purpose it was collected. We must destroy this information in accordance with the law and our file retention guidelines. When we destroy your personal information, we make sure that confidentiality is secured and that no unauthorized person can access the information during the destruction process.

Accuracy

We make every possible effort to ensure that your personal information is as accurate and complete as necessary for the purposes it is collected, used, or disclosed.

Accountability

We are responsible for your personal information in our possession or control, including information that may be transferred by us to third parties for processing. We require such third parties to keep personal information under strict standards of privacy and protection. We adhere to legislated and self-imposed rules, aimed to safeguard your privacy. The rules are established by this Privacy Policy, the Code of Business Conduct (applicable to directors, officers and employees), Market Conduct Standards (applicable to agents and brokers) as well as insurance industry guidelines and applicable law.

Our staff is trained on these processes and procedures and is provided with information about privacy laws.

Safeguards

We have implemented and continue to implement rigorous safeguards so that your personal information remains strictly confidential and is protected against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Protection methods include organizational measures such as requiring security clearances and limiting access to a “need-to-know’’ basis, physical measures (e.g. off-site backups and archiving), and technological measures such as the use of password and encryption (e.g. the use of routinely changing passwords, firewalls and segmented operator access).

Request for Access to Information and Amendments

You have the right to be informed whether we hold personal information about you and to see that information. You also have the right to enquire as to how we collected your information, how we used it and to whom it may have been disclosed.

This information will be provided to you within a reasonable time from the date we receive your written request. We may charge a reasonable fee for processing your request.

In certain limited and specific circumstances, we may refuse to provide to you the requested information. Exceptions to your access right can include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, information that has been obtained in the course of an investigation of a potential breach of contract or fraud, and information that is subject to solicitor-client or litigation privilege.

You may challenge the accuracy and completeness of your personal information. We will respond to an amendment request within a reasonable time.

Any request for access to information or request for amendment must be sent to the following address:

Stonebrooke Asset Management Ltd. 

 344 Lakeshore Rd East, Suite B, Oakville, Ontario L6J 1J6

Attn: Chief Compliance Officer

Email: ComplianceSAM@StonebrookePWM.ca


You can also contact the Office of the Privacy Commissioner of Canada for assistance between the hours of 9 am and 5 pm, at:

Toll-free: 1-800-282-1376

Phone: (613) 995-8210

Fax: (613) 947-6850

112 Kent Street Place de Ville Tower B, 3rd Floor Ottawa, Ontario K1A 1H3

or on the Web at: http://www.privcom.gc.ca/

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