The privacy of our investors is very important to us. This Privacy Policy sets out the information practices for SRHI Inc. group members, including what types of personal and business information is collected, how the information is used, and with whom the information is shared. We are committed to protecting your privacy and maintaining the confidentiality of your information.
Definitions you need to know.
"We, our and us" mean, as applicable, SRHI Inc.
"Service" means any brokerage or financial product or service offered by us.
"You and your" means each person, whether an individual, corporation or trust, who has made application to us for or signed an application in respect of any Service offered by us, including any co-applicants, guarantors or personal or corporate representatives such as directors.
"SROs" refers to self-regulatory organizations, including the Investment Industry Regulatory Organization of Canada (IIROC), the Mutual Fund Dealers Association of Canada, the exchanges and other regulated marketplaces and the Canadian Investor Protection Fund.
"Data Protection Legislation" means all applicable data protection and data privacy legislation including, where relevant, the General Data Protection Regulation EU 2016/679, the UK Data Protection Act 1998 and all equivalent, associated and similar legislation which applies to us from time to time.
What personal information do we collect?
The term personal information refers to any information about you (or other identifiable people) including information that may specifically identify you or them. We will be collecting personal information from you that includes the following:
For legal entities such as businesses, partnerships, trusts, estates or investment clubs, we may collect the information referred to above from each authorized person, partner, trustee, executor and club member, as appropriate.
How do we collect your information?
We collect your personal or business information directly from you or through your financial advisor or dealer in order to provide you with Services and perform contracts with you, to meet legal and regulatory requirements and to comply with our legal obligations, for the purpose of our own legitimate business interests (where these are not overridden by your rights and freedoms) such as to keep in contact with you, and for any other purposes to which you consent. Your information may be collected from a variety of sources, including:
We may also monitor or record any telephone call we have with you. The content of the call may also be retained (and these recordings will be stored for a fixed period of time in accordance with our own internal policies and Data Protection Legislation). We may inform you prior to proceeding with the call of this possibility. This is to establish a record of the information you provide, to ensure that your instructions are followed properly and to ensure customer service levels are maintained.
How do we use your information?
We collect and use your personal or business information in order to give you the best possible service and for the purposes set out in your agreement(s) with us, such as:
We collect, use and disclose your social or national insurance number, social security number or other government-issued personal or business identification number for ID verification purposes and for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.
We will store your personal information for no longer than it is needed and our retention of the information will be in accordance with our internal policies and the Data Protection Legislation.
How do we obtain your consent (where needed)?
Where we need your consent in order to process your personal information in a certain way, we will rely on your actions as indications of your consent to our collection, use and disclosure of your personal information. For example, by signing an application form, voluntarily providing your information to us directly or through your financial advisor or dealer and continuing to do business with us, you are consenting to the collection, use and disclosure of your personal information for the purposes identified in this Privacy Policy. SRHI will not, as a condition of the supply of Services, require you to consent to the collection, use or disclosure of your personal information beyond that which is required to fulfill these purposes.
Who do we share your information with?
We do not provide directly all the services related to your relationship with us. We may use third party service providers or agents such as:
Our service providers and our agents process or handle your information on our behalf and assist us with various services such as printing, imaging, document storage and shredding, mail distribution and marketing. Some of these third parties may be located outside of Canada. As a result, your information may be accessible to regulatory authorities in accordance with the laws of these jurisdictions. When information is provided to our service providers and to our agents, we will require them to protect the information in a manner that is consistent with SRHI privacy policies and practices and which accords with the Data Protection Legislation (which may involve the use of contracts containing the EC approved "model clauses" contract for data transfers). You are entitled to request a copy of the relevant provisions of these contracts by contacting us at the email address below.
We may also be required by law to disclose information to government regulatory authorities. For example, we may be required to report your income to taxation authorities. We may also be required to disclose your personal and business information to SROs. SROs collect, maintain and use such information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings. SROs may, in turn, disclose such information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.
SRHI may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, we may disclose your personal and business information to the acquiring organization.
How do we use your information for marketing purposes?
We may share your personal or business information within the SRHI for the purpose of marketing products and services that we believe may be of interest to you. This would only be done with your consent. We may ask you for your contact information, such as your telephone number, residential address, e-mail or other electronic address, and keep and use this information.
How do you withdraw your consent?
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact on our ability to provide you or continue to provide you with some Services or information that may be of value to you. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.
Who do you contact if you have any questions or concerns?
If you have any questions about our privacy policies and practices and how they relate to you, please contact our Chief Privacy Officer by telephone at 855.943.8099, by e-mail at ________or by mail to the address below
If you are still not satisfied, you can contact The Office of the Privacy Commissioner of Canada. Complaints to the Office of the Privacy Commissioner must be submitted in writing to 112 Kent Street, Ottawa, Ontario K1A 1H3 Attention: The Privacy Commissioner of Canada. There are other privacy regulators who may also be able to assist you.
If you have any questions regarding this Policy, please contact us at:
Royal Bank Plaza, South Tower
200 Bay Street
Suite 2600
Toronto, Ontario M5J 2J
Canada
Last updated as of 6/23/2020.
