PRIVACY POLICY STATEMENT
Willoughby Asset Management Inc. is committed to making every effort to protect the privacy and the confidentiality of personal information that is provided to us. Our information handling practices comply with applicable privacy laws.
The following is a description of our privacy policy regarding the collection, use, and disclosure of personal information that is provided to us or that is shared with us from other sources.
1. Nature of Personal Information and why it is required by us.
Personal information refers to information that identifies you. It may include such information as age, marital status, employment history, social insurance number, credit history, home address, personal email address, and home telephone number.
Personal information may be required in order to establish a relationship and to provide the best possible service. A signature, financial history, current financial position, social insurance number, age, and other similar personal information allow us or our affiliates to:
- establish identity;
- assess eligibility and suitability for investment products and services;
- protect you and us from error and fraud.
In addition, we require personal information in order to allow us to meet regulatory or contractual requirements relating to the products and services we provide.
2. Obtaining Personal Information
Personal information may be 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 and other financial institutions.
3. Use of Personal Information
We may use your personal information for the following purposes:
- To identify you;
- To ensure our records are accurate;
- To maintain, store, record and determine your account holdings and transaction records;
- To verify previously given information when necessary;
- To provide you and your representatives with account statements/information;
- To provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed with regard to your holdings;
- To meet legal and regulatory requirements.
4. Sharing of Personal Information
Confidentiality and privacy of personal information is one of our fundamental principles, however, we may share your information with others in limited circumstances including:
- Third Party Service Providers. 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, and imaging. 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.
- Your Financial Advisor. We share your information with your financial advisor and the dealer with which she or he is registered. We may also have to contact other financial institutions or mutual fund companies in order to gather complete information necessary for your service requirements.
- As Permitted or Required By Law. Willoughby may be 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.
- 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.
5. Retention of Personal Information
Personal information may be kept in electronic, microfilm or paper format at the offices of Willoughby Asset Management Inc. or its affiliates or its third-party service providers. Such information may also be kept in secure off-site storage facilities.
6. Protection of Information
Policies, procedures, guidelines, and safeguards have been put in place to ensure that personal information is protected. Our employees and service providers may have access to personal information to enable them to perform their duties. Personal information collected will only be used for specifically identified purposes and will be retained for as long as is necessary to fulfill the service or as required by law.
7. Privacy Rights
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. If you wish to change or update your personal information, you may request to do so at any time. Please note that we may only alter that personal information required to fulfill the stated purposes. 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 Willoughby or its affiliates; (iii) information that has been destroyed or may be too costly to retrieve.
You may withdraw your consent for the use of your personal information by contacting Willoughby at any time subject to reasonable notice. 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.
8. Who to Contact About Privacy Concerns
Should you have a complaint, please contact the Willoughby Privacy Officer at 604-558-6822 or toll free at 1.877.588.6822 or by emailing at admin@willoughbyasset.com.