InstarAGF Asset Management Inc. (InstarAGF) and its subsidiaries are committed to protecting the privacy of its clients and any individuals from whom personal information may be collected from time to time. Privacy protection is integral to providing quality service.
WHAT IS PERSONAL INFORMATION?
Personal information refers to information that identifies an individual. It includes, for example, your signature, age, marital status, financial information, social insurance number, home address, personal email address and home telephone number. It does not include an individual's name and business contact information.
WHY DO WE NEED YOUR PERSONAL INFORMATION?
To establish a relationship and provide quality service, we require personal information in order to:
• Establish your identity
• Understand and assess your eligibility for our products and services
• Agree to and provide you with products and services
• Protect you and us from error and fraud
• Comply with the law
HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?
Personal information is obtained primarily from you, although we may also obtain information from other sources with your consent. These other sources may include, but are not limited to, your advisor or dealer, affiliates of InstarAGF, your bank, other financial institutions, etc.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your personal information for the following purposes:
• To identify you;
• To ensure our records are accurate;
• To establish and administer your account;
• To execute your transactions;
• To maintain, store, record and determine your account holdings and transaction records;
• To verify previously given information when necessary;
• To provide client reporting;
• To provide quality relationship management services;
• To protect the interests of InstarAGF, such as the collection of a debt owed; and
• To meet legal and regulatory requirements.
WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
Any information provided will only be used for the stated purposes. Personal information may be shared amongst financial intermediaries connected to the account and the services provided to the account for the purposes for which the third party is retained and to meet your service requirements. It may also be provided to other InstarAGF affiliates and their service providers, applicable government regulators, government agencies and regulators and any other party pursuant to legally binding requirements.
Contracts between InstarAGF and third party service providers ensure appropriate controls and protections are in place at the service provider to protect your personal information. Our service providers may, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and who require access to certain personal information to perform contracted services. In this case, InstarAGF's service providers are responsible for ensuring appropriate security measures and controls are in place to protect your personal information from unauthorized use, loss, theft, alteration and destruction.
DISCLOSING YOUR PERSONAL INFORMATION WHEN REQUIRED OR PERMITTED BY LAW:
InstarAGF may be required to provide your personal information in response to a search warrant, order to produce information or any other legally valid demand or inquiry. InstarAGF's third party service providers may also be required to provide your personal information in response to local legal requirements not unlike Canadian requirements.
OBTAINING YOUR CONSENT
Prior to providing any personal information consent will be obtained, either verbally, formally as evidenced by your signature or implied, by your acceptance of services.
WITHDRAWING YOUR CONSENT:
At any time you may withdraw your consent by contacting InstarAGF. Legal and other requirements may prevent you from withholding consent and your decision to withhold personal information may also limit the services or products InstarAGF is able to provide.
ACCESS TO AND ACCURACY OF YOUR PERSONAL INFORMATION:
Upon request, InstarAGF will provide you with access to your personal information, including a list of third parties to whom your personal information was provided. You may request to update your personal information. InstarAGF may not update or change personal information unless it is necessary to fulfill the purposes for which it was collected. In certain circumstances InstarAGF may not be able to provide you with certain information. For example: (i) if it contains references to other persons; (ii) it cannot be disclosed because of legal requirements; (iii) if it contains propriety information that is confidential to InstarAGF or its affiliates; (iv) if it has been destroyed or (v) if it is too costly to retrieve.
WHERE IS YOUR PERSONAL INFORMATION KEPT?
Your personal information may be kept in electronic or paper format in the offices of InstarAGF, in secure off-site storage facilities provided by storage service providers and its third party (administration) service providers.
InstarAGF is committed to treating you with respect and consideration. Providing the highest level of service is our commitment to you. However, from time to time there may be a misunderstanding, something may have gone wrong, or you may feel you have been treated unfairly. In such a circumstance, InstarAGF will act diligently in an effort to resolve the problem quickly.
InstarAGF may be contacted at:
Toronto-Dominion Bank Tower
66 Wellington Street West, 31st Floor
Toronto, Ontario M5K 1E9
InstarAGF will respond to your complaint in a timely fashion. If you find that the resolution is unacceptable, you may contact the Privacy Commissioner of Canada:
112 Kent Street
Ottawa, Ontario K1A 1H3
Tel: 613-995-8201 or 1-800-282-1376