Abria Financial Group Ltd. and its subsidiaries (“Abria”) are committed to ensuring and protecting the privacy and confidentiality of its clients’ personal information. Abria has therefore adopted this policy to comply with its obligations under current Privacy Legislation. This policy briefly describes how we collect, hold, use and whenever necessary, disclose your personal information. It also summarizes your right to have access to correct the information as necessary. If you have any questions about our privacy policies or your personal information, please contact Abria Client Services at 647-722-0304 or e-mail your privacy concerns investorservices@abriafunds.com.
Use of the Internet
Privacy issues, including security and confidentiality of personal information disclosed on or through this web site, are viewed very seriously by Abria. Policies governing the protection of privacy are strictly observed and enforced to ensure the highest standards of protection of privacy and personal information.
When you visit this web site, move from page to page, read pages, or download its content onto your computer, the following information may be recorded:
• The address you are connecting from
• Which pages are visited
• What content is downloaded
• The address of the web sites that you visited immediately
before coming to this web site.
Abria uses this information to find out how many people visit this web site and which sections of the web site are visited most frequently. Abria may use this information to determine what type of information is most useful, improve this web site, address your specific needs, provide better customer service and for general marketing purposes. The information may also be used to provide records of communication between Abria and you, and to comply with any legal and/or regulatory requirements.
None of the information collected is associated with any individual. It is measured only in aggregate. Abria records the statistical information on the numbers of visitors to this web site, but no information about individuals in particular is kept or used.
Certain Abria employees will be provided with information about a web site visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products. Abria employees are instructed to use strict standards of care in handling the personal, confidential information and the handling of such information is dealt with in the Abria Privacy Code. Non-compliance with this code will result in disciplinary sanctions that may include dismissal.
Client Record and Personal Information
In the course of our business relationship with you, the personal information collected about you is held in a "client record." This information likely includes, at a minimum, your name, address and telephone number(s), social insurance number, birth date, account holdings and if applicable, the name address and social insurance number of your spouse or beneficiary. Depending on the type of service you request, additional personal information may be held in your client record. This information was provided to Abria either by you or your financial advisor at the time the account was opened or as the information became necessary throughout the service process.
Collecting, Holding, Using and Disclosing Personal Information
Abria may collect, hold and use the personal information in your client record as well as collect personal information from and disclose personal information to the third parties identified below, for the following purposes:
- identifying you and ensuring the accuracy of information contained in your client record;
- establishing and administering your account, determining, maintaining, recording and storing account holdings and transaction information in your client record;
- executing transactions with or through Abria including transferring funds by electronic or other means;
- providing you and your financial advisor/dealer with investment account statements, tax receipts, financial statements for your investments, proxy mailings, transaction confirmations and other information that you or your financial advisor/dealer may request to service your account;
- protecting its own business interests including collecting a debt owed to Abria or allowing the performance of a transaction;
meeting legal and regulatory requirements; - verifying information previously given by you with any other organization when necessary;
- advising you of other similar Abria products, services or initiatives that may be of interest to you; and,
- for any other purpose you and Abria and/or your financial advisor may agree upon from time to time.
Consent
Your knowledge and consent to Abria’s collection, use and disclosure of your personal information is important. We rely on your actions as indications of your consent to our existing and future personal information practices:
- Your voluntary provision of personal information directly to Abria or through your financial advisor/dealer;
- Your express consent or acknowledgement contained within a written, verbal or electronic application process;
- Your consent solicited by Abria (or our agent) for a specified purpose; Your receipt of this Privacy Policy, until you notify Abria of a withdrawal of your consent; or
- Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent at any time. If you wish to withdraw consent or discuss the implications of such withdrawal, please contact us through one of the means described in the preface. In some circumstances, legal requirements may prevent you from withholding consent. Your decision to withhold consent may also limit the products and services that Abria is able to provide to you.
Third Parties
Abria may collect your personal information from third parties such as your financial advisor/dealer, other companies related to Abria and other financial institutions and mutual fund companies. Abria may disclose your personal information to these same third parties, to Canadian, provincial or municipal governments and government agencies (for example, Canada Customs and Revenue Agency), account and tax statement preparation and mailing companies, Canada Post, courier, imaging and document storage and shredding companies. When Abria transfers personal information to its service providers, we ensure by contract that the transferred information is only used for the purposes for which the provider was retained. Your personal information will not be disclosed to any other advisors or dealers other than your advisor and dealer of record.
Using Your Social Insurance Number
Abria is required by law to use your social insurance number when submitting tax reports to Canada Customs and Revenue Agency and may provide it to third parties engaged to prepare income tax reports for Abria.
Location of Your Client Record
Your client record, whether electronic or paper, is kept at the offices of Abria in Toronto, Ontario. Paper records forming part of your client record may also be kept in offsite storage. Your client record may be transferred to other locations for disaster recovery purposes.
Right to Access and Correct Your Personal Information
Except in limited circumstances described in the legislation, you are entitled to access, through a written request, the personal information contained in your client record. You may verify this personal information and request that any inaccurate information be corrected. For information on this process, please contact us at Abria Client Services, at 647-722-0304. If your concerns have not been resolved to your satisfaction, you may contact the Privacy Compliance Officer at Abria at 416-367-4777.
Limits on How Long Personal Information is Kept
Abria will only retain your personal information as long as it is necessary, including updating the product or service or as required by law. When we destroy the information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.
Safeguards for your Personal Information
Abria maintains appropriate technical and organization safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. If you find that the proposed resolution to your privacy concerns is not adequate, you may avail yourself of one of the following options:
1. You may contact:
The Privacy Commission of Canada
112 Kent St.
Ottawa, ON
K1A 1H3
Phone: 613-995-8210 or 1-800-282-1376.
http://www.ipc.on.ca
2. In Quebec, you may contact:
La Commission d’acces a l’information
575, rue St. Amable, Bureau 1.10
Quebec, Quebec
G1R 2G4
Telephone: 418-528-7741 or 1-888-528-7741
http://www.cai.gouv.qc.ca./eng/index_en.htm
