This document informs you of Pollitt’s policies on privacy and the ways that we ensure the protection of your privacy and the confidentiality of your personal information. This policy applies to Pollitt’s individual clients, including persons who carry on business alone or in partnership with other individuals.
When we collect information from you, we will explain what information we collect and how we intend to use it. Pollitt will not use or disclose it for any purpose. Should we wish to use your information for other purposes, you can refuse to give Pollitt such permission. However, if you choose not to provide requested personal information or consents, we may not be able to provide certain or any products or services to you.
We will provide your information to other parties: where we have your consent, where the other parties are our suppliers or business partners who provide service to your account, where we are required to or permitted to do so by law, and where transfers of your business are involved.
We will take appropriate steps to protect your information. We will retain your information as long as it is necessary to service your account or as is required by our industry’s regulations.
We will provide you with access to your information upon your request. We will take reasonable steps to ensure that your personal information is accurate and up-to-date.
Addressing Your Concerns
We will address and respond to any of your concerns about our handling of your information.
Why We Need Your Information
The only occasions we are permitted to disclose client information is when it is authorized by the client or required or permitted by law.
We may use and share your personal information with our employees, third party agents employed by us, third party service providers and other financial institutions, but they will not share this information with others. The information will only be used for the following purposes:
We may also use or share your personal information in order to meet the requirements of legal and securities regulatory authorities and self-regulatory organizations including Market Regulation Services Inc., the Investment Industry Regulatory Organization of Canada, the Mutual Funds Dealers Association, and the Canadian Investor Protection Fund (collectively, “SROs”). SROs collect, use or disclose such personal information obtained from registrants for regulatory purposes, including:
surveillance of trading-related activity;
Products And Services
When you provide your consent, we may share your information with other affiliated companies. This will help us serve you better by identifying related products and services, which may be of use to you. Sharing information within the Pollitt group of companies will also help ensure that the information we have on file for you is complete and up-to-date. Your consent to our providing information to other parties is optional and may be withdrawn by you at any time.
With your consent, we may obtain information about you from third parties such as credit agencies. This information helps us assess your eligibility for certain products and services such as a margin account. Please remember that if you do not agree to provide your consent for this, we may not be able to extend margin privileges to you. We may also, with your consent, provide your information to outside sources. For example, service providers who we hire to do things like process your trades and send your month-end statements to you will have access to certain account information including your name and address in order to perform their required functions. We require our third party service providers to sign a Privacy Agreement to help ensure that they will protect the confidentiality of your information. We are also obliged to provide your information to regulatory bodies within the investment industry. We may also be required to disclose your information to government agencies or law enforcement agencies, or when we are in receipt of a valid Court Order or search warrant.We may also disclose your information to outside sources to help us collect a debt owed to us by you. As well, we may disclose your information as a result of a transfer of our business, should we decide in the future to sell off all or part of our business or to merge with another financial institution. Your personal information may be disclosed to Self-Regulatory Organizations.
Protection Of Information
We have thorough security standards in place to protect your information against unauthorized access and use. We also provide training to our employees so they will understand the need for confidentiality when dealing with your information. We retain your information only as long as we need it to service your account, or as long as industry regulations demand. When we no longer need your information, we will delete electronic records and destroy physical records.
Your Right To Access Information
Most of your information is in the form of account documentation and transaction records. You will receive copies of any documents you sign to open your account with Pollitt. You will also receive copies of monthly (or quarterly) statements of your account, which detail all of the transactions that have taken place in your account during that period. If you require further details about your information, you may contact us at any time. Naturally, we will have to assess your request to ensure that it does not contain references to other persons, or violate our legal privilege.
Accuracy Of Information
Having accurate information about you will enable us to give you the best possible service. We expect that you will provide us with updated information when you move or change telephone numbers, or have any other material changes in your information. If you detect any errors in information (such as the information appearing on your copy of your application form), please let us know immediately.
Your Right To Withdraw Consent
When you sign the documentation required to open your account, you will see that within that documentation is our PrivacyAgreement. By opening an account with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us. However, please note that withdrawing consent may mean that we will be unable to provide certain services to you. We will explain the consequences of withdrawing consent, should you choose to do so.
Inquiries and Complaints
The Privacy Officer can be reached in writing at the following address:
330 Bay Street, Suite 405, Toronto, ON M5H 2S8
Attention: Privacy Officer
or by facsimile at (416) 368-0141.
Please be advised that all inquiries and complaints must be IN WRITING to the attention of the Privacy Officer. Telephone calls WILL NOT be accepted.
Please be sure to include your name, address, phone number and information relating to the nature of your inquiry or complaint.
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