Dundee Securities Ltd. and its divisions, Dundee Goodman Private Wealth and Dundee Capital Markets (including the foreign affiliates below, “Dundee”) are committed to providing investors with the highest standard of service. As part of our commitment, we strive to protect your privacy and the confidentiality of personal information that you provide to us.
Personal information refers to information that identifies you. It may include information such as your age, gender, family and marital status, income, assets, liabilities, employment history, social insurance number, investment objectives, financial plans, source of funds, payment records, other financial-related information, credit history, credit rating, identification numbers (e.g. social insurance number, passport number or driver's license number), home address, personal email address and home telephone number. In some cases, it may also include medical and health information, insurance and claims experience, personal references, habits, personality, travel or movement details, lifestyle, leisure activities, qualifications, skills and career history.
Our handling practices with respect to personal information comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and similar legislation is enacted at the provincial level in Quebec, British Columbia, and Alberta. The practices disclosed herein apply to certain dealer entities within the Dundee group, including Dundee Goodman Insurance Agency Ltd. (“Dundee Insurance”). To meet our obligations, we closely follow the ten fundamental principles set out under PIPEDA.
Personal information is received by us from you or from your representative with your consent. Other sources from which we may receive your information with your consent include, but are not limited to, our affiliates, other financial institutions, through a credit check and employment information check, etc.
Finally, Dundee automatically collects certain information about your computer hardware and software, which may include: your IP address, browser type, domain names, access times and referring web site addresses. This information is used by Dundee for the operation of its websites, to maintain quality of the website, and to provide general statistics regarding use of the Dundee website.
Purpose of Collecting Personal Information
Dundee believes in collecting and using personal information responsibly and only for the purpose for which it was collected. We require your personal information in order to establish a relationship with you and provide you with the best possible service. Your personal information allows us to:
- establish and maintain communications with you;
- offer and provide insurance, investment and financial products and services that we believe meet your changing needs to you;
- provide you with quality customer service and support on your investment and insurance needs;
- assess your eligibility for our investment products, services and/or offerings;
- assess your insurance needs, including analyzing and assessing risks and providing and/or verifying personal information with government agencies, industry associations, brokers or insurers;
- determine and facilitate your payment of fees and premiums and facilitate notice of claims under insurance policies;
- develop and offer additional insurance, investment and financial products and services that we feel may be of interest to you;
- establish and verify your identity;
- ensure our records are accurate;
- verify previously given information when necessary;
- establish and administer your account;
- execute your transactions;
- maintain, store, record and determine your account holdings and transaction records;
- provide additional services requested by the client;
- properly report account status back to the client;
- provide you and your representatives with account statements/information;
- provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
- provide all required tax reporting;
- properly discharge our regulatory responsibilities with respect to suitability assessment and other securities rules;
- properly discharge our obligations under federal anti-money laundering and suppression of terrorism legislation;
- meet our obligations as a member of various self-regulatory organizations;
- conduct internal audits;
- compile statistics;
- protect the interests of Dundee, such as relates to the collection of debt owed;
- protect you and us from error and fraud;
- allow us to meet contractual requirements relating to the products and services provided to you;
- notify you or allow our affiliated companies to notify you of certain products or services offered by us, or our affiliated companies.
In the event that you would like to open additional accounts or obtain other investment products or services that are available through Dundee from time to time, Dundee may require personal information that was not previously collected. For example, Dundee 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.
For regulatory purposes, self-regulatory organizations, including the Ontario Securities Commission, the Investment Industry Regulatory Organization of Canada, the Toronto Stock Exchange, the Bourse de Montreal Inc., the Canadian Investor Protection Fund, Financial Services Commission of Ontario, Alberta Insurance Council, Insurance Council of British Columbia, the Autorité des marchés financiers and Financial Industry Regulatory Authority, Inc. (collectively, “SROs”) require access to personal information of current and former clients, employees, agents, directors, officers, partners and others collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including
- surveillance of trading-related activity;
- sales, financial compliance, trade desk review and other regulatory audits;
- investigation of potential regulatory and statutory violations;
- regulatory databases;
- enforcement or disciplinary proceedings;
- reporting to securities regulators, stock exchanges or insurance regulators; and
- information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
Please be advised that to the extent personal information is provided to or stored with a foreign affiliate or third party service provider in another country, such information may be available to the governments of such other countries (includes the United States government) under lawful order made in that country.
Dundee may track the websites and pages that you visit within the Dundee website for the operation of its websites, to maintain quality of the website, and to provide general statistics regarding use of the Dundee website.
Dundee Securities Ltd.’s consent form is contained in the New Client Application Form or, in the case of financial advisory agreement, the applicable engagement letter or contract. Consent may also be required when clients purchase a product or service subsequent to account opening. An authorized representative of the client (such as a legal guardian or a person having power of attorney) can give consent. Additionally, we may rely on the following actions by you as indications of your consent to our existing and future personal information practices:
- your voluntary provision of personal information directly to Dundee for the purpose of opening an account or acquiring an investment product, insurance contract or other financial service or product;
- your express consent or acknowledgement contained in a written, verbal or electronic communication; and
Your advisor may from time to time offer you products and services that are not the products and/or services that are available at Dundee. Your advisor is required to obtain your consent before using any of your personal information that was collected for purposes relating to non-Dundee business. 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 advisors in order to protect the interests of Dundee.
A client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting your investment advisor or the Privacy Officer. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.
Limiting Use, Disclosure and Retention
Dundee will use or disclose personal information only for the purpose(s) it was collected, unless the client consents to use or disclosure for another purpose, or if applicable laws require or condone such additional uses. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client.
Policies, procedures, guidelines, and safeguards have been put in place to ensure your personal information is protected. Our employees and service providers have access to your personal information to enable them to perform their duties in servicing you. We regard confidentiality and privacy as a cornerstone to our business. As such, our internal code of ethics requires all employees of Dundee to maintain client confidentiality. Each year, our employees receive a current copy of our code of ethics and are required to certify in writing that they will comply with it.
Your information may be made available to related companies or third-party service providers to fulfill the purposes for which it has been collected. The Company will NOT sell your personal information to anyone. However, we may share your information with:
- Third Party Service Providers (including Dundee’s carrying broker, Dundee US’s custodian and settlement agent and Dundee Insurance’s managing general agency). We hire third party service providers to perform services on your behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, the preparation and mailing of client statements, document storage, imaging, processing event registration and for the purpose of customer satisfaction surveys. As it relates to Dundee Insurance, third party service providers may include underwriting insurers, medical professionals and government health insurance plans. As it relates to certain financial products, third party service providers may include mutual fund companies, issuers and product manufacturers. In each case, they are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These third party suppliers are not permitted to disclose this information to others unless otherwise permitted by law.
- Referral Arrangements. We may provide you and a third party with one another’s contact information where Dundee has a referral arrangement in place with that third party. Any such disclosures will be made in accordance with National Instrument 31-103 – Registration Requirements.
- Your financial advisor and/or insurance advisor. We share your information with your advisor(s).
- Other Institutions. We may have to contact other financial institutions, mutual fund companies or insurance companies in order to gather complete information necessary to properly service your account with us.
- As Permitted or Required By Law. Dundee is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.
- SROs. We share your information with SROs, which may use the information to review, monitor, audit or investigate Dundee's compliance with securities and insurance rules. The information provided to the SROs may, in turn, be reported to other securities regulators, regulated marketplaces, other SROs or law enforcement agencies.
- Business Re-Organization. As we continue to grow, we may in the future re-organize or streamline parts of our operations. Since our business is based on our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business. These third parties are not permitted to disclose this information to others.
- Credit Bureau. We may provide your information to other lenders and credit bureaus.
Upon request, we will provide you with access to your personal information. In addition, we may provide you with a list of third parties to whom your personal information was provided. In certain circumstances, we may not be able to provide you with access to specific pieces of information. For example, (i) information containing references to other persons; (ii) information containing proprietary information confidential to Dundee or its affiliates; (iii) information that has been destroyed or may be too costly to retrieve.
Keeping Information Accurate
Dundee has a responsibility to ensure that all personal information on file is accurate, complete and up-to-date. When a client demonstrates the inaccuracy or incompleteness of personal information, the information will be amended as required. Please note that we may only alter that personal information required to fulfill the stated purposes.
Storing and Safeguarding Personal Information
Your personal information may be kept in electronic, microfilm or paper format at the offices of Dundee, its affiliates or its third-party service providers. Your information may also be kept in secure off-site storage facilities.
Please be advised that certain personal information may be provided to or stored with affiliates or third party service providers in other countries, including the United States of America and, accordingly, may be available to the governments of such other countries (including the United States government) under lawful order made in that country.
Security safeguards are in place to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification regardless of the format in which it is held. Dundee's safeguards vary depending on the sensitivity of the personal information. The highest level of protection is given to the most sensitive personal information.
Dundee ensures that clients have access to information regarding the policies and practices used to manage their personal information. This information is readily available in a variety of formats.
Inquiries and Complaints
Dundee is committed to providing its clients with access to an effective, fair and responsive inquiry and dispute resolution process. Your investment advisor should be able to answer most of your questions regarding Dundee's privacy policies and procedures. If you would like to make an inquiry or complaint regarding Dundee's personal information practices, please contact our Privacy Officer by e-mail at email@example.com, by facsimile at (416) 865-3463 or at the following address:
Dundee Securities Ltd.
1 Adelaide St. E., Suite 2100
Toronto, Ontario M5H 3R3
Attention: Privacy Officer
In most instances, the Privacy Officer will investigate and reply to inquiries or complaints 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. Telephone calls 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.
Foreign Dealer Affiliates
Please note that the information provided herein regarding Dundee’s privacy policies and procedures may not in all cases be applicable to Dundee’s foreign dealer affiliates, each of which comply with applicable domestic laws.
June 1, 2015