Collection, Use & Disclosure of Personal Information
Primary Purposes

• to provide Portfolio Management service and advice
• to contact the client

About Members of the General Public

• to gather and review information that is relevant to our work
• to provide notice of special events (seminars or conferences, for instance)
• to make the general public aware of our services in general or our firm in particular
• on our website, we only collect, with the exception of cookies, the personal information that we provide and we only use that information for the purposes for which you gave it. Cookies are only used to help you navigate our website and are not used to monitor you.

We will, on request, remove such personal information from our distribution lists. We do not sell personal information or address lists to third party marketing companies.

Collection, Use & Disclosure of Personal Information
Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related or secondary purposes are as follows:

• to advise clients and others of new developments in our area of expertise " to send greeting cards, invitations to events or firm marketing materials
• to ensure high quality services (ie) assessing performance of staff and partners
• to assist external advisors with audits or other quality assurance reviews
• Various government agencies have the authority to review our files and interview our staff as part of their mandates. In these circumstances, we may consult with professionals (lawyers and accountants, for instance).
• Clients or other individuals may have questions about the services that we have provided after they have been received
• We retain our client information, as required by the Ontario Securities Commission.
• If our firm or its assets were to be sold, the purchaser would want to conduct a "due diligence" review of the firm's records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may include some review or our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser would be required to sign a confidentiality agreement. Only reputable purchasers who have already agreed to buy the organization's business or its assets would be provided access to personal information, and only for these limited purposes.
• In providing services, we use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information that we hold. These consultant include computer consultants, office security and maintenance, bookkeepers, accountants, file storage companies, temporary workers, credit card companies, website managers, cleaners. We restrict their access to any personal information that we hold as much as is reasonably possible. We also have their assurance that they will follow appropriate privacy principles.

How Do We Protect Personal Information?

• Paper information is either under supervision or secured in restricted areas.
• Electronic hardware is either under supervision or secured in restricted areas. In addition, passwords are used on computers.
• When information is delivered outside our offices, whether by fax, phone, email, courier or otherwise, we endeavour to use only reputable companies and agencies.
• Staff are trained to collect, use and disclose personal information only as it is necessary to fulfill their duties and in accordance with our Privacy Policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.