PRIVACY POLICY STATEMENT
Willoughby Asset Management Inc. (“Willoughby) is committed to making every effort to protect the privacy and the confidentiality of personal information that is provided to us. Willoughby handles your personal information in accordance with the Personal Information Protection and Electronic Document Act (“PIPEDA”).
- Purpose of Collection
Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, Willoughby will communicate the purpose for which personal information is being collected, either orally or in writing, before or at the time of collection.
- Scope of Collection
Willoughby will only collect personal information that is necessary to meet the regulatory requirement as an Investment Fund Manager (“IFM”). This includes, but is not limited to, the acceptance of subscription agreements, investigations of unitholding compliance, and the submission of exempt distribution reports required under National Instrument 45-106 Prospectus Exemption (“NI 45-106”).
Willoughby will not use or disclose client personal information for any additional purpose unless consent is obtained to do so.
Willoughby will not sell client, customer, member lists or personal information to other parties unless consent is obtained to so do.
- Consent
As an IFM, Willoughby does not interact directly with individual clients. However, the firm may acquire client personal information through its operations. If circumstances require Willougby to collect personal information from client directly, the firm will seek the client’s consent before collecting, using, or disclosing their personal information, unless specifically permitted or required by law to do so without consent. Consent from clients can be given orally, in writing, electronically, and/or through an authorized representative.
Clients retain the right to withhold or withdraw their consent for Willoughby to use their personal information in certain ways, except in limited circumstances. These exceptions included situations where:
- Personal information is necessary to provide a requested service or product
- Withdrawing consent would prevent Willoughby from fulfilling a legal obligation
If a client chooses to withhold or withdraw consent for specific uses of their personal information, this may impact Willoughby’s ability to deliver services or address a client complaint. In such cases, Willoughby will provide an explanation of the situation to help the client make an informed decision.
- Retention of Personal Information
If client personal information is used to make a decision that directly affects the client, Willoughby will retain the personal information for at least one year. This retention period ensures that the client has a reasonable opportunity to request access to their information.
Willougby will retain client personal information only as long as necessary to fulfill the identified purposes or to meet a legal or business requirement. Once personal information is no longer needed for these purposes, it will be securely deleted or destroyed in accordance with Willoughby’s data retention procedures.
- Protection of Information
Willoughby is dedicated to maintaining the security and confidentiality of client personal information. Willoughby has implemented a comprehensive set of safeguards and regularly update security practices in line with technological advancement to prevent authorized access, collections and use of client data.
- Privacy Rights
Clients have a right to access their personal information, subject to limited exceptions. Exceptions may include:
- Prohibitive cost
- References to other individuals
- Legal, security or commercial proprietary reasons
- Solicitor-client or litigation privilege
A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Chief Privacy Officer. Upon request, Willoughby will inform clients how their personal information is used and to whom it has been disclosed if applicable. Requested information will be available within 30 business days or provide written notice of extension where additional time is required to fulfill the request. A minimal fee may apply for providing access to personal information. If a fee is necessary, the client will be informed of the cost upfront and request further directions on whether to proceed with the request. If a request for access is refused in full or in part, Willoughby will notify the client in writing outlining the reason for refusal and any recourse available to the client.
- Who to Contact About Privacy Concerns
Should you have a complaint, please contact the Willoughby’s Chief Privacy Officer at 604-558-6822 or toll free at 1.877.588.6822 or by emailing at admin@willoughbyasset.com.