The Notice applies to any person who communicate with us, regardless of the means used, and any individual whose personal information we collect in carrying out our business activities including,
Personal information refers to information that identifies you. We collect personal information directly from you or indirectly through someone you authorize or from third parties in accordance with applicable law.
The information that we collect or receive from you or other depending on the nature of your relationship with us. To learn about the collection practices that relate to you please click on the relevant categories that apply to your relationship with us below:
We collect information directly from you or from your authorized representative(s), such as your financial advisor or their dealership. Depending on how you do business with us, this information may be collected on applications, forms, over the phone, in person, through the internet, through your mobile device or through other forms of communication. We also collect information about you indirectly where permitted by law. We limit the collection of information to what is necessary to fulfill the purpose for which the information is collected.
The information we collect includes,
We collect information directly from you or from your authorized representative(s), such as your Dealership. Depending on how you choose to do business with us, this information may be collected on applications, forms, over the phone, in person, through the internet, through your mobile device or through other forms of communication. We also collect information about you indirectly where permitted by law. We limit the collection of information to what is necessary to fulfill the purpose for which the information is collected.
Video Recordings or Photographs, as we may use video or photo surveillance in and around our offices for the safety of our clients and employees, and to protect against theft, property damage, and fraud.
We are accountable for the personal information under our control by establishing, training our staff in, and enforcing our privacy policies and procedures to promote compliance with these privacy principles. We have designated a privacy officer who is accountable for personal information under our control and responsible for compliance with this Privacy Notice. Please see Contact Us for information on how to reach the privacy officer.
We have strict policies and procedures governing how we deal with your personal information, including the retention and destruction of personal information, the roles and responsibilities of our personnel in the handling of personal information and procedures for handling complaints regarding our protection of personal information. Every employee is responsible for respecting and protecting the personal information to which the employee has access.
We inform you about the purposes for which we collect, use, and disclose your personal information and we collect, use, and disclose your personal information only for those purposes.
We collect, use and disclose personal information only for the purposes for which it was collected. When we collect personal information, we use it to:
Your personal information will also be used for purposes named in your respective application forms and account agreements.
If a new purpose for using your personal information develops, we will inform you of that purpose.
We obtain your consent to collect, use, or disclose personal information and you may at any time revoke that consent, subject to legal and regulatory requirements. In some cases, we may not be able to provide certain services to you if you do not consent or withdraw consent to our collection, use or disclosure of the required information to perform those services.
If you have any questions or require assistance understanding the scope of the consent we request from you, please Contact Us.
Depending on the type and sensitivity of the personal information and the way you interact with us (in person, internet, phone, email, etc.), we may obtain your consent in different ways.
Before we make information available to third parties, other than an agent or service provider who needs it to provide services to you, we will tell you at the time of consent or before we make the information available, who those third parties are, the kind of information we want to share with them, and why.
You may withdraw your consent for the collection, use and disclosure of your personal information at any time by forwarding a written request to the Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.
However, there are certain times when you may not withhold or revoke your consent including certain legal, regulatory, or contractual requirements.
We must receive reasonable notice of your request in order to honour your consent withdrawal.
Your decision to withhold or revoke your consent may limit the products and services that we may provide to you and may require you to close your accounts with us.
We limit collection of your personal information to that which we determine is necessary for the purposes we identify for you.
We only collect the personal information we determine we need for our identified purposes.
We do not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as required by law.
We only use or disclose your information for the purpose(s) it was collected and as otherwise identified in this Notice.
We use natural language processing technology to create a transcript and assess the sentiment of our callers and employees, representatives, and agents during certain phone interactions. The technology compares the language used during the call to a database of words and phrases and classifies the sentiment of call into various categories. We use this information to classify calls, identify issues, assess callers experience and to improve our services.
We do not sell or rent client lists or personal information to third parties.
Our employees or authorized representatives, who are responsible for functions relevant to the purposes identified within this notice, and other persons authorized by you or by law, will have access to your personal information. Our employees and authorized representatives are required to maintain the information in the strictest of confidence and do not provide access to the information to anyone who is not authorized.
We may disclose information to any person or organization, including an investigative body, in order to prevent, detect or suppress, financial abuse, fraud, criminal activity, protect our assets and interests, or manage or settle any actual or potential loss or in the case of a breach of agreement or contravention of law. We may also disclose information to help us collect a debt owed to us
We may buy or sell a business (or evaluate those transactions) which would result in certain personal information forming business assets that would be purchased or sold as part of a transfer. We may also transfer personal information as part of a corporate reorganization or other change in corporate control
For instance, sharing your information with your Dealership, Financial Advisor or a joint account holder.
We disclose to them only such personal information as they need to perform the services. We do not authorize them to use or disclose the personal information for their own marketing or other purposes. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. They may be located in Canada or other jurisdiction or countries and may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries in accordance with the applicable law in that jurisdiction or country. For more information on our third party service providers, including where they are located, please Contact Us.
We disclose information to your financial advisor and their dealership for administrative purposes to permit them to provide you with service and deliver your instructions to permit us to administer your account.
We disclose information upon your request or in accordance with the authority that you have provided these legal representatives, such as an individual that you have granted power of attorney and/or trading authority.
We disclose information to comply with your requests, such as transfer of funds to your banking institution or external another dealership or fund manager.
We share personal information among any of the subsidiaries and affiliated companies that comprise CI Financial Corp. who perform administrative services for us and/or to better understand your financial needs and to provide products and services we believe may interest you.
We share personal information when required or permitted to do so by law, including in response to a search warrant, court order, or other demand or inquiry which we believe to be valid
We have policies in place that govern the retention of your personal information, so we keep it only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal or self- regulatory organization requirements. When we no longer retain your personal information, we have procedures to destroy, delete, erase, or convert it to an anonymous form, in a manner that keeps it safe in the process.
Information collected will be communicated outside of Quebec, both within Canada and other jurisdictions or countries and we may disclose information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries in accordance with the applicable law in that jurisdiction or country.
Information may be transferred to, accessed and/or retained by these third parties. We may store your personal information via third party entities that reside in foreign jurisdictions. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. We and/or a third party may be compelled, by law or otherwise, to provide information to a third party, subject to applicable privacy law. We must abide by applicable privacy law in the jurisdiction(s) in which we operate.
Your personal information is kept in electronic or paper format:
We have policies in place that govern the retention of your personal information, so we keep it only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. The length of time we keep your information will depend upon the product or service and the nature of the information.
When we no longer retain your personal information, we have procedures to destroy, delete, erase or convert it to an anonymous form, in a manner that keeps it safe in the process.
We maintain your personal information in as accurate, complete, and up-to-date form as is needed for its use.
We are committed to maintaining the accuracy of your personal information and take reasonable efforts to keep your information complete and up-to-date. We maintain your personal information in as accurate, complete, and up-to-date form as is needed for its use.
We maintain appropriate security safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information in our custody or control. These safeguards are appropriate to the sensitivity of the information.
We maintain appropriate physical, electronic, technological, procedural, and organizational safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information in our custody or control. These safeguards are appropriate to the sensitivity of the information.
We have agreements in place with third party service providers requiring that personal information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the provider to perform.
Upon request, we will inform you of the existence, use and disclosure of your personal information and will give you access to that information, with few exceptions.
We encourage you to contact our Client Services department to correct or access your information on file with us. However, you do have the right, subject to certain limitations, to formally request to review or verify your personal information, or to find out to whom we have disclosed it. To make a formal request for access, send a written request addressed to the Privacy Officer in Contact Us below. Please include your full name, address, telephone number, and account number(s) on all correspondence to us and provide enough detail to allow us to identify the information you want and the details of the information that you are seeking.
Upon request, we will provide you with access to your personal information we have on record at the time of the request. Please note that we may not be able to provide you with this information in certain circumstances, for example without limitation, where such information:
If we are unable to provide some of the personal information, we hold about you, we will tell you why, when permitted by law.
We will advise you in advance if a minimal charge will be required for conducting the search and we will respond to your request within 30 days.
If you discover inaccuracies in our records, or your personal information changes, please notify your financial advisor or contact our Client Services Department directly so that we can make the necessary changes. Failure to notify us of changes to your personal information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your personal information that we may have released to them.
You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact us in writing using the contact information set out in the “Contact” section below.
Each time you use our online, mobile, and electronic services, you are indicating your acknowledgement and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services.
We collect personal information when you use our websites, online, mobile applications, and other electronic services (collectively, digital channels), including:
We may use or disclose this information collected online to:
We and our service providers may use various tracking tools, such as (Cookies, Pixel Tags and Web Beacons). Using cookies and other technologies, we can enhance your experience with improved design, personalized content that may be relevant to you, and effective navigation.
Most browsers and mobile devices offer their own settings to manage cookies. You can refuse or delete cookies using these settings. Please refer to your browser’s online help for further instruction and information on setting Cookie preferences.
If you do not accept any category of Cookies, you may continue to browse our websites; however, please be aware that certain features of our website may not function properly without Cookies. You should note that if you would like certain services, you will be required to accept the Cookies to maintain session integrity and enhanced security. Additional resources that may assist you in managing Cookies used for advertising include the Digital Advertising Alliance (DAA): https://youradchoices.ca.
If you refuse a cookie when using the Services, or if you delete cookies, you may experience some inconvenience in your use of the Services. For example, you may not be able to sign in and access your account, or Assante may not be able to recognize you, your device, or your online preferences.
In order to ensure compliance with Canada’s Anti-Spam Legislation, commercial electronic messages (including email marketing) will be based on an individual’s consent. CI will request consent to send commercial electronic messages prior to sending commercial messages (including emails), unless we have an individual’s implied consent through a pre-existing business relationship. We provide individuals with the ability to unsubscribe from receiving promotional emails from our company, and/or Partners and Associates. Upon establishing an Investor Online account, where available, you will be asked to choose your document delivery preferences. You will be sent notification e-mails when documents are added to your Investor Online account. We will also send you e-mail alerts when you make changes on your Investor Online profile.
You may choose to enter your information to participate in online surveys, feedback, contests, or other activities we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or identifying products and services that might interest you. This information will be used for the purposes outlined in the Privacy Notice. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
You may choose to enter your information to participate in online meetings, webinars or educational events that we sponsor. We use this information for a number of purposes, such as assessing the performance of the website, or improving products and services, or issuing continuing education credits. This information will be used for the purposes outlined in the Privacy Notice. The information you enter may be transmitted through or to our 3rd party providers of webinars. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
We take our responsibility to safeguard customer information very seriously. To protect certain communications between your computer and our servers, we use a technology solution called “Secure Sockets Layer” (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of “defense in depth”, in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network.
You are responsible for ensuring the security of your unique web login ID and password. You must avoid selecting an obvious password, such as a street address, date of birth, or telephone number and to change your password on a regular basis, in order to reduce the potential for unauthorized use. Any web login ID, password, or any other piece of information chosen by you or provided to you as part of CI’s security procedures, must be treated as confidential and personal to you, and you must not disclose it to any other person or entity.
Do not respond to text messages, pop-ups, emails, or other internet requests that ask you to reveal personal information about yourself or your account when using the Services. CI will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. CI will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails.
|CI Global Asset Management||Privacy Office|
15 York Street
The best way to address a concern or question is to raise it with our Client Services Department as soon as it comes up by contacting them.
Our financial service representatives are available between 8 a.m. to 8 p.m. ET, Monday to Friday.
If our Service group are unable to address your concern or question you can escalate in the following ways:
If after contacting us you do not feel that your concern has been adequately addressed, you may wish to contact:
The Office of the Privacy Commissioner of Canada
Last Update September 2023