Privacy Policy
Alitis Investment Counsel Inc.
Privacy Information Statement
Your Privacy Is Important!
Mission Statement
Your privacy is important. At Alitis(i), we are committed to protecting your privacy in order to ensure that the confidentiality, security and accuracy of your personal information are maintained at all times. Personal information is information that identifies you as an individual. Personal information could include your name, address, social insurance number, date of birth, citizenship and country of residence, banking information, identification documents, marital status, dependents, occupation, income and net worth. In order to protect your privacy, Alitis has developed policies and procedures(ii) based upon the following ten privacy principles:
1. Accountability
Alitis is responsible for all of the personal information of its clients that it collects or that is under its control. Alitis has appointed a Privacy Officer who is accountable for Alitis’ compliance with its stated privacy principles. The Privacy Officer may be contacted at the address set out at the end of this Privacy Information Statement.
1.1 Employees And Agents
All employees of Alitis are bound contractually or under the policies and procedures of Alitis to maintain the confidentiality of your personal information. In the event that your adviser is an agent of Alitis, your adviser is bound contractually or under the policies and procedures of Alitis to maintain the confidentiality of your personal information and to ensure that his/her employees or, in some cases, the employees of a corporation in which your adviser is the principal shareholder, maintain the confidentiality of your personal information.
1.2 Third Party Suppliers
All of Alitis’ third party service providers are bound contractually or by other appropriate means to maintain the confidentiality of your personal information and to not use your personal information for purposes that are not related to the service or product that they have been contracted to provide. In the event that your adviser is an agent of Alitis, your adviser is bound contractually or under the policies and procedures of Alitis to ensure that his/her third party service providers or, in some cases, the third party service providers of a corporation in which your adviser is the principal shareholder, maintain the confidentiality of your personal information and to not use your personal information for purposes that are not related to the service or product that they have been contracted to provide.
2. Identifying Purposes
Alitis shall identify the purposes for which the personal information of its clients is collected before or at the time the information is collected.
2.1 General Purposes
Alitis collects your personal information for the purpose of establishing and servicing your account(s) and to fulfill our legal, regulatory and self- regulatory obligations in Canada and in some cases, abroad. In addition, Alitis may from time to time, with your consent, provide you with information which may be of interest to you or information relating to products and services that are available through other Alitis companies or may share your personal information with other Alitis companies so that they can provide you with such information directly. Alitis will not sell your personal information to anyone.
2.2 Specific Purposes
2.2.1 Social Insurance Number
Alitis is required by law to keep a record of your social insurance number if you have an account that earns income or if you are opening a registered account. In addition, Alitis reserves the right to review your credit history and may, with your consent, use your social insurance number to obtain more accurate credit information.
2.2.2 Date of Birth
Your age is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through Alitis. Your adviser is required by law to consider, among other things, your age before making investment recommendations. In addition, Alitis is required to record your date of birth in order to comply with money laundering legislation.
2.2.3 Citizenship and Country of Residence
Alitis requires your citizenship and country of residence in order to fulfill its regulatory obligations. For example, depending on your country of residence, Alitis may not be permitted by law to open and service your account.
2.2.4 Banking Information
Alitis is required by law to record your banking information for purposes relating to the prevention of money laundering.
2.2.5 Identification
Alitis is required by law to verify your identify for purposes relating to the prevention of money laundering. In addition, in the event that you want to avoid adverse tax treatment under U.S. tax laws with respect to income earned from U.S. securities, you may be required to provide a copy of your identification or in the alternative, to complete certain U.S. tax forms.
2.2.6 Marital Status and Dependents
Your marital status and number of dependents is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through Alitis. Your advisor is required by law to consider, among other things, your marital status and number of dependents before making investment recommendations.
2.2.7 Occupation
Information relating to your occupation is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investment products and services that are available through Alitis. Your adviser is required by law to consider, among other things, information relating to your occupation before making investment recommendations.
2.2.8 Income and Net Worth
Information relating to your income and net worth is an important factor in determining your investment objectives, risk tolerance and overall suitability for the different investments products and services that are available through Alitis. Your adviser is required by law to consider, among other things, information relating to your income and net worth before making investment recommendations. In certain instances, Alitis is required by law to determine your creditworthiness and your income and net worth are among the factors that we use to make this determination.
3. Consent
Alitis shall only collect, use or disclose client information with the knowledge and consent of its client except where inappropriate or as otherwise required or permitted by law.
3.1 Consent
By completing our account forms, you are consenting to the collection and use of your personal information for the purposes set out in this Privacy Information Statement and to the disclosure of your personal information to the persons identified in this Privacy Information Statement for the purposes identified.
3.2 Collection
The majority of your personal information is collected directly from you at the time your account is opened at Alitis. In the event that your credit history is obtained, Alitis may collect personal information directly from a credit reporting agency.
3.3 Disclosure
Your personal information is made available to the employees, agents and third party service providers of Alitis and in some cases, to credit reporting agencies and to government, regulatory or self regulatory authorities as required by any domestic or foreign law or as required under the rules and regulations of any self-regulatory authority of which Alitis is a member. In the event that Alitis buys or sells any part of its business in the future, your personal information may be one of the assets that is transferred and may be disclosed to the vendor or purchaser, as the case may be, prior to the completion of such a transaction for purposes relating to the evaluation of such a transaction. In addition, with your consent, your personal information may be disclosed to other Alitis companies for the purposes of providing you with information relating to products and services that may be of interest to you. Your adviser may be an employee or agent of Alitis. In the event that your adviser is an agent of Alitis, your personal information may be made available to the employees and third party service providers of your adviser or, in some cases, to the employees and third party service providers of a corporation in which your adviser is the principal shareholder.
3.4 Non-Alitis Related Business
Your adviser has been engaged by the applicable Alitis company for the purpose of advising others in the products and/or services that are available at Alitis (“Alitis Related Business”). Your adviser may from time to time offer you products and services relating to non-Alitis Related Business. Your adviser is required to obtain your consent before using any of your personal information that was collected for purposes relating to Alitis Related Business, as the case may be, for non-Alitis Related Business.
3.5 Withdrawing Your Consent
You have the right to withdraw your consent to the use of your personal information that is not required for the purpose of establishing and servicing your account(s) and to fulfill our legal, regulatory and self-regulatory obligations in Canada and in some cases, abroad, or as otherwise permitted by law. If you DO NOT want Alitis to provide you with information relating to products and services that are available through other Alitis companies or other information which may be of interest to you or may share your personal information with other Alitis companies so that they can provide you with such information directly, please notify Alitis of your decision in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. Please be sure to include your name and all of your account numbers in your request. Requests to withdraw consent will only be accepted if received directly from you; requests to withdraw consent received from, received via, or directed by other persons, companies, or organizations WILL NOT be accepted. In the event that your adviser provides you with information which may be of interest to you or information relating to products and services available through other Alitis companies and you DO NOT want to receive such information, please notify your adviser of your decision. Please be advised that the withdrawal of your consent is NOT a condition of doing business with Alitis and you are free to withdraw your consent at any time. In addition, please be advised that Alitis will NOT sell your personal information to anyone and your adviser is prohibited from selling your personal information to anyone.
3.6 Consent Not Required
In certain circumstances, your personal information is made available without your consent when required by a court of law or by a regulatory or self-regulatory organization or to our legal advisers in order to protect the interests of Alitis. Regulatory authorities include, without limitation, provincial securities commissions, Canada Revenue Agency (“CRA”), provincial insurance regulators and provincial mortgage regulators. Self-regulatory authorities include, without limitation, the Investment Industry Regulatory Organization of Canada (“IIROC”) and the Mutual Fund Dealers Association of Canada (“MFDA”).
4. Limiting Collection
Alitis shall only collect the personal information of its clients that is necessary for the purposes that have been previously identified to the client.
4.1 New Products And Services
In the event that you would like to open additional accounts or obtain other investment products or services that are available through Alitis from time to time, Alitis may require personal information that was not previously collected. For example, Alitis does not require information regarding your designated beneficiaries when opening a regular cash account but will require such information if you decide to open a registered savings account.
5. Limiting Use, Disclosure, Retention
Alitis shall only use or disclose the personal information of its clients for the purposes for which it was collected unless the client has otherwise consented or as required or permitted by law and such client information shall only be retained for as long as necessary to fulfill the purposes for which it was collected or as otherwise required or permitted by law.
5.1 Further Consent May Be Required
In the event that Alitis would like to use your personal information in a manner that has not been previously identified, Alitis will notify you in advance and obtain your consent unless otherwise required or permitted by law.
5.2 Retention And Destruction
Your personal information is retained throughout the period of time in which you are a client of Alitis and for a reasonable period of time thereafter as required or otherwise permitted by law or as required to protect our legal interests. Your personal information is destroyed in a safe and secure manner once it is no longer needed.
6. Accuracy
Alitis is committed to keeping the personal information of its clients accurate, complete and up to date at all times.
6.1 Updating Your Information
In order to maintain the accuracy and completeness of your personal information, your adviser may require you to update your account documentation from time to time. If your personal information changes, please notify your adviser so that Alitis has accurate, complete and up to date information.
7. Safeguards
Alitis is committed to protecting the personal information of its clients and has implemented the necessary security safeguards that are appropriate to protect the sensitivity of such information.
7.1 Security
The majority of your personal information is contained on your account documentation. Alitis stores the bulk of your original account documentation offsite in a secure location. Account documentation that is maintained at Alitis’ head office is safeguarded by using a number of protective methods such as using locked, fire-resistant filing cabinets and restricting access to certain designated areas where your account documentation is stored. Your adviser is also bound under the policies and procedures of Alitis to use similar protective methods to safeguard your account documentation and any other personal information that is maintained in his/her branch.
7.2 Technology
Alitis has implemented industry standard methods of protecting your personal information that is available electronically or online from unauthorized access, disclosure, copying, use or modification. This includes the use of firewalls, encrypted passwords, anti-virus software, intrusion detection systems and other appropriate means to protect your personal information. Your adviser is also bound under the policies and procedures of Alitis to use appropriate protective methods in maintaining the security of your personal information that is in an electronic format. Alitis may from time to time use cookies on its website to improve functionality and in some cases, to provide clients with customized access to our website. Cookies are not used to collect personal information that may reside on your personal computer and are not used to track the websites that you visited before or after you leave the Alitis site.
8. Openness
Alitis is committed to providing its clients with information relating to the policies and procedures that apply to their personal information.
8.1 Additional Information
You can obtain more information about our privacy policies and procedures by contacting your adviser or the Privacy Officer in writing at the address noted at the end of this Privacy Information Statement. This Privacy Information Statement and any amendments made thereto are available on our website at: www.alitisinvestmentcounsel.com or by contacting your adviser directly for a copy.
9. Access
Alitis is committed to providing its clients with information relating to the existence, use and disclosure of their personal information and clients shall be given access to such information where appropriate.
9.1 Contact Us
You can request access to your personal information by contacting your adviser directly or the Privacy Officer in writing at the address indicated at the end of this Privacy Information Statement. A request to access your personal information will only be accepted if received directly from you; requests received from, received via, or directed by other persons, companies, or organizations WILL NOT be accepted. If you would like to update or amend any inaccuracies in your personal information, please contact your adviser directly. In certain instances, your adviser may not have access to all of your personal information where such information has been created for regulatory, self-regulatory, investigatory or any other purpose necessary to protect the legal interests of Alitis. In such instances, Alitis may not be able to provide you with access to all of your personal information. Alitis may charge a minimal fee to process requests for personal information. An estimate of the fee will be provided to you before any work is undertaken. As well, a deposit may be required from you before any work is undertaken. Personal information collected by a request to access will only be delivered to you; your personal information WILL NOT be delivered to other persons, companies, or organizations.
10. Responding To Inquiries And Complaints
Alitis is committed to providing its clients with access to an effective, fair and responsive inquiry and dispute resolution process.
10.1 Inquiries
Your adviser should be able to answer most of your questions regarding Alitis’ privacy policies and procedures. In the event that you require further information, please direct your inquiry in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. In most instances, the Privacy Officer will investigate and reply to inquiries within 30 days. If the Privacy Officer is unable to respond to your inquiry within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response.
10.2 Complaints
All privacy complaints must be directed in writing to the attention of the Privacy Officer at the address noted at the end of this Privacy Information Statement. In most instances, the Privacy Officer will investigate and reply to complaints within 30 days. If the Privacy Officer is unable to respond to your complaint within 30 days, you will be notified in advance of the end of such 30 day period of when you should expect to receive a response.
10.3 Contact Details
The Privacy Officer can be reached in writing at the following address:
Alitis Investment Counsel Inc.
101 – 909 Island Highway
Campbell River, B.C., V9W 2C2
Attention: Privacy Officer
Please be advised that all inquiries and complaints must be IN WRITING to the attention of the Privacy Officer. Telephone calls, faxes, and emails WILL NOT be accepted. Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint. Inquiries and complaints will only be accepted if received directly from you; inquiries and complaints received from, received via, or directed by other persons, companies, or organizations WILL NOT be accepted.
Footnotes:
(i) All references to the term “Alitis” collectively refers to Alitis Investment Counsel Inc. and Alitis Insurance Services Ltd.
(ii) The information proved herein regarding the policies and procedures of Alitis may not in all cases be equally applicable to all Alitis companies (as such term is defined herein).
Updated September 21, 2010
