As of January 1, 2004, organizations in Canada that collect, use or disclose personal
information in the course of commercial activity have to comply with the federal
Personal Information Protection and Electronic Documents Act ("PIPEDA").
Value Partners Investments Inc. ("Value Partners") is committed to maintaining the
confidentiality, integrity and security of personal information of each of its clients.
This document summarizes the policies and procedures in place to effectively safeguard
any personal information that we may have on file or collect.
How We Collect, Use and Disclose Personal Information
Where does my personal information come from?
We may collect personal information about you from any of the following sources:
- You or your representative on applications or forms submitted to us (personal information
such as name, address, social insurance number, birth date, telephone number)
- Transaction activity in your account (such as purchases, redemptions and account
balances)
- Third party intermediary or self-direct providers (if account is held through them)
- Telephone, email or mail inquires by you the client.
- Other sources with your consent or with the consent of your representative
What types of personal information do you collect?
We collect only the personal information we need for the purposes we have identified
to you.
Personal information shall be collected by fair and lawful means. We may collect
personal information about you including:
- Information from your purchase application and other forms relating to your account
(such as name, date of birth, address and social insurance number, marital status,
phone number)
- Personal information about a spouse or beneficiary, if applicable (may include name,
sin, date of birth and social insurance number)
- Information about the transactions in your accounts (such as purchases, redemptions
and account balances)
- Information about any bank account you use for automatic purchases, redemptions
or other transfers between your bank account and your Value Partners' account(s).
Page 1 of 4
- Information we receive about you or your accounts as a result of your inquiries
by mail, email or telephone
- Other information required to meet obligations imposed by securities regulators
Why do you need this information?
We may use your personal information to develop, offer, and deliver products and
services; process transactions in your account, respond to inquiries from you or
your representative; or to fulfill legal and regulatory requirements.
In addition, we also collect personal information to ensure that we have all information:
- To establish, administer and maintain your account
- To provide additional services as requested by you the client
- To provide you with investment account statements, tax receipts, transaction confirmations
and other information that you request to service your account
- To properly identify you and to ensure the accuracy of information
- To provide all required tax reporting
- To properly discharge our obligations under federal anti-money laundering and suppression
of terrorism legislation
How long do you keep this information?
We require accurate information to responsibly service your account and update services.
To this end, we must keep your personal information as long as it is necessary,
including updating the product or service or required by law. To meet the requirements
of some regulatory bodies, this information may be kept after the account has terminated.
Who is this information disclosed to?
We do not sell your personal information and do not disclose it to anyone except
as permitted or required by law or as described in this statement.
In order to complete transactions you authorize or request and so that we can provide
you information about Value Partners' products and services, we may disclose the
information we collect about you to the following entities:
- Contracted mutual fund service providers including our data processing company or
record keeper
- Information service providers such as printers and mailers that prepare and distribute
materials to you
- Your financial representative as well as applicable fund companies, dealers, intermediaries,
self-direct account providers, trustees and custodians
- Government agencies, other regulatory bodies and law enforcement officials
- Other organizations, as permitted by law (for example, for fraud protection)
The companies that provide services to us use that information only to perform the
services for which they were contracted and are not permitted to use or disclose
that information for any other purpose, except with the permission of the individual,
or as permitted by law.
Is my permission required to provide information?
Yes.
Your prior knowledge and permission is required for the collection, use or disclosure
of personal information, except for legal or security reasons. Your permission may
be expressed in writing or be implied and you may give it to us verbally, electronically,
or through your authorized representative.
Can I access and correct my personal information?
Yes.
You have the right to be informed of the existence, use and disclosure of your personal
information and shall be given access to this information. In addition, you have
the right to challenge the accuracy and completeness of this information and have
it amended as appropriate.
Except in limited circumstances prescribed by the Protection of Personal Information
and Electronic Documents Act (Canada) and similar provincial privacy protection
legislation, you are entitled to access your personal information through a written
request. You may verify this personal information and request, in writing, that
any inaccurate information be corrected by sending a request to:
Privacy Officer
Value Partners Investments Inc.
300-175 Hargrave Street
Winnipeg, MB, R3C 3R8
Is my personal information and privacy protected?
Yes.
Within Value Partners and among our service providers, access to information about
you is restricted to those employees who need to know the information to service
your account. All employees are trained to follow our procedures to protect your
privacy and are instructed to access information only when they have a business
reason to do it.
Value Partners maintains appropriate technical and organizational safeguards to
protect your personal information against loss, theft, unauthorized access, disclosure,
use or modification. These safeguards extend to the destruction of personal information.
To effectively meet the obligations above, Value Partners strictly adheres to the
ten fundamental principles set out under PIPEDA. These principles are as follows:
1. Accountability
Value Partners is responsible for personal information under its control and shall
designate an individual or individuals who are accountable for overall compliance
with the following principles.
2. Identifying Purposes
The purposes for which personal information is collected shall be identified at
or before the time the information is collected.
3. Consent
The knowledge and consent of the individual are required for the collection, use,
or disclosure of personal information, except where inappropriate.
4. Limiting Collection
The collection of personal information shall be limited to that which is necessary
for the purposes identified. Information shall be collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those
for which it was collected, except with the consent of the individual or as required
by law. Personal information shall be retained only as long as necessary for the
fulfillment of those purposes.
6. Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary
for the purposes for which it is to be used.
7. Safeguards
Personal information shall be protected by security safeguards appropriate to the
sensitivity of the information.
8. Openness
Value Partners shall make readily available to individuals specific information
about its policies and practices relating to the management of personal information.
9. Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure
of his or her personal information and shall be given access to that information.
An individual shall be able to challenge the accuracy and completeness of the information
and have it amended as appropriate.
10. Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the
above principles to the designated individual or individuals accountable for compliance.
If you have questions, suggestions or complaints regarding compliance to our privacy
policy or the security of your personal information, please contact us at 1-866-323-4235
or email us at info@vpinvestments.ca.