Privacy Statement: August 2014
Privacy and confidentiality are fundamental to our business’s
success. We are proud to demonstrate our commitment to your privacy,
by complying with the laws and regulations under applicable privacy
laws in Canada, including the Personal Information Protection
and Electronic Documents Act. Strathbridge Asset Management Inc.
(as follows, “Strathbridge”, “we” or “us”)
to ensure compliance with these regulations.
The purpose of this Privacy Statement is to inform you about the
types of personal information Strathbridge collects, uses and discloses.
It explains how we use and disclose that information, the choices
you have regarding this use and disclosure, and how you may correct
We will treat personal information in a manner consistent with the
unless we have your consent to treat it differently. This Privacy
Statement applies to any information we collect, use or disclose,
or receive about you, from any source.
We will address the following questions in this Privacy Statement.
Please click on the question for the response.
2. What is “personal information”?
” is any
information that is identifiable with you. This information
may include but is not limited to your name, mailing address,
phone numbers, email address, business fax, social insurance
number, household income, banking information, and creditor
information. Personal information, however, does not include
your name, business title or business address and business
telephone number in your capacity as an employee of an organization.
3. How do we collect your personal information?
We will collect your personal information fairly and lawfully
(for example, when you complete an investment application
form or speak to a Strathbridge representative). After we have
obtained your consent to do so or as otherwise permitted
by law, we will collect personal information from you and
from third party service providers.
4. How do we use Google Analytics?
You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Google Ad settings
or through the Google Analytics opt-out browser add-on
5. How do we use your personal information?
Either before or when we collect information about you we
will obtain your consent to do so and explain how we intend
to use it. One of the primary reasons we collect your personal
information is to setup investment accounts, evaluate your
investment objectives and provide financial advice. For
example, we will use your personal information to help evaluate
your financial situation and needs in terms of investment
objectives, time horizons, income requirements, liquidity,
tax efficiency and asset mix.
6. To whom do we provide your personal information?
At the time we collect your personal information from you
we will explain how we intend to use it and to whom it may
For example, we may disclose your personal information:
(a) to third party service providers with whom we have a
contractual agreement to:
(i) assist us in managing
and calculating the value of your investments;
(ii) perform functions such
as data processing, database services or
technology support; and
(iii) market or providing any
of our products;
(b) to persons for whom you have provided your consent;
(c) as otherwise permitted or required by law.
When and how do we obtain your consent?
Before collecting, using or disclosing your personal information
for any reason, we will obtain your consent.
You can provide your consent to us either orally or in writing.
For example, when you submit an application form to a Strathbridge
representative, you give your consent to allow us to disclose
information such as your name, address, or social insurance
number to third parties, such as financial institutions
and other service providers, in order to assist in the management
of your financial assets.
From time to time, we may also collect, utilize or disclose
your personal information based on your consent and as permitted
or required by law.
How long will we utilize, disclose or retain your Personal
We keep a record of your personal information, correspondence
or comments, in a file specific to you. We will use, disclose
or retain your personal information only as long as it is
necessary to meet the purposes for which it was collected
and as permitted or required by law. Strathbridge has a Record Retention
policy, which establishes the retention periods for maintaining
How do you know that the personal information we have on you
We will make every reasonable effort to keep your information
as accurate, complete and up-to-date as possible. We do
not routinely update your personal information, unless such
a process is necessary. You can help by keeping us informed
of any changes or if you find any errors in our information
What if the personal information we have on you is inaccurate?
At any time, you can question the accuracy or completeness
of the personal information we have about you. If the information
we have is inaccurate or incomplete, we will update it accordingly.
Where appropriate, we will transmit the updated information
to third parties that require access to your personal information.
How fast will we respond to your written requests?
We will make every reasonable effort to respond to your
written request within thirty-days (30) after receiving
it or we will advise you in writing if we cannot meet your
requests within this time limit. You have the right to make
a complaint to the federal Privacy Commissioner if we are
unable to respond to you within the thirty-day (30) time limit.
If you would like to access the information we have about
you, simply forward a written request to Strathbridge’s Chief
Privacy Officer. We will advise you in advance if a minimal
charge will be required for obtaining this information or
You can withdraw your request for access to your information
by notifying us within a thirty-day (30) notice period disclosed
on the estimate we provide to you. Please notify us if you
still require the information and accept the cost estimate
or if you want to withdraw your request.
What safeguards have we implemented to protect your personal
We will protect your information with appropriate safeguards
and security measures such as physical, organizational,
contractual and technological means. The only employees
who have access to your personal information are those with
a business ‘need-to-know’ or whose duties reasonably
require this information.
How do you contact us regarding access to your personal information
All comments, questions, concerns or complaints
should be forwarded to our Chief Privacy Officer as follows.
Attn: (Ms.) Peggy Shiu
Strathbridge Asset Management Inc.
121 King Street West
Standard Life Centre, Suite 2600
Toronto, Ontario M5H 3T9
Toll Free: 1.800.725.7172