We recognize that all personal information is private and confidential. We are committed to ensuring and protecting the privacy and confidentiality of our clients’ personal information. This privacy policy describes how we collect, hold, use and whenever necessary, disclose your personal information, and outlines how we comply with applicable privacy legislation.

What is personal information?

Personal (or client) information refers to information that identifies you. It may include information such as your name, age, date of birth, marital status, citizenship, social insurance number, occupation, employment information, financial information, credit history, home address, personal e-mail address and home telephone number.

How do we collect personal information?

We collect personal information about you: (i) from subscription or application forms and other information provided by you or your advisor in writing, by telephone, in person, electronically or by other means; (ii) from your activity on the web site and transactional activity in your accounts, including account balances, investments, withdrawals and fees/commissions; (iii) through your advisor, if you have one, and (iv) from other interactions with us, such as discussions with our staff.

How do we use your personal information?

We may use your personal information to:

  • identify you;
  • ensure our records are accurate;
  • establish and administer your account(s);
  • execute your transactions;
  • maintain, store, record and determine your account holdings and transaction records;
  • verify previously given information;
  • provide you and your representatives with account statements, tax receipts, financial statements, proxy mailings, transaction confirmations and any other information that may be requested or needed to service your account;
  • provide you with quality customer service and support;
  • protect our interests, including recovering any debts you may owe us; and
  • meet legal and regulatory requirements.

To whom do we disclose your personal information?

Your personal information will only be used for stated purposes to assist us in providing you with the best possible service. We may also provide your personal information to other third parties. This is done only to meet your service requirements.

Third parties that may be provided with your personal information include:

  • Third-party service providers;
  • Your financial or legal representatives;
  • Other financial institutions, securities dealers and mutual fund companies;
  • First Asset affiliates;
  • Canadian, provincial and municipal governments, government agencies and regulators (for example Canada Revenue Agency or the Ontario Securities Commission) as required by law or legal process; and
  • Authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorized to act.

We do not sell your personal information to third parties.

Obtaining Your Consent

Before or at the time you open an account with us, you will be required to provide certain personal information to establish the account. The information may be collected via our application form, in which case you will formally indicate your consent for us to collect and use the personal information when you sign the application. The information may also be provided to us by your financial advisor, in which case, by virtue of account opening, your consent is implicitly provided to us to collect and use the information. In this case, at the time of initial collection of your personal information by your financial advisor, you will have provided consent to your advisor to disclose your personal information for the purposes of effecting investment transactions, including the opening of accounts with us.

Withdrawing your consent

Subject to certain restrictions and reasonable notice, you may withdraw your consent for the collection and use of your personal information at any time by forwarding a written request to our Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.

In some circumstances, legal requirements may prevent you from withholding consent. In addition, your decision to withhold consent may also limit the products and services that we may provide to you and may require you to close your accounts with us.

How can you access your personal information?

Subject to certain restrictions, you have the right to verify the accuracy and completeness of your personal information. Upon request, we will provide you with access to your personal information we have on record at the time of the request. Please note that we may not be able to provide you with this information in certain circumstances, for example, where such information: contains references to other persons; contains proprietary information confidential to us or your financial advisor; has been destroyed or is too costly to retrieve; is subject to legal or some other form of privilege; or cannot be disclosed for legal reasons or relates to an investigation.

Any request to access or update information may be made by forwarding a written request to our Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.

Where is your personal information kept?

Your personal information may be kept in electronic or paper format in our offices, in secure off-site storage facilities, or in the offices of our service providers.

How do we protect your personal information?

We will maintain the security and confidentiality of personal information. We maintain appropriate technological, procedural and organizational safeguards to protect your personal information against unauthorized access, theft or misuse.

How long do we keep your information?

We only keep your information as long as it is necessary to do so. The length of time we keep your information will depend upon the product or service and the nature of the information and will be only as long as it is legally necessary for us to retain sufficient information to respond to any inquiries that may arise later.

Questions, concerns or complaints?

If you have any questions, concerns or complaints regarding matters of privacy please contact our Privacy Officer (Z. Edward Akkawi).

Phone: (877) 642-1289 or 416-642-1289

We reserve the right to change or remove this Privacy Policy at our discretion. If we decide to change it, we will post those changes here. We encourage you to visit this area frequently to stay informed. If you access our website after we have posted changes to this policy, you are agreeing to accept the changes.

Updated August 2012