We are dedicated to respecting and protecting the privacy and confidentiality of the information you have entrusted to us. This Privacy Notice outlines our privacy principles and practices.
What is Personal Information?
Personal information refers to information that identifies you. The word “information” means personal, financial and other details about you that you, or someone you authorize, provide to us or we obtain from others within or outside the Company.
What Does It Apply to?
This Privacy Notice applies to the operations of CI Investments Inc. in Canada. It applies regardless of how you choose to do business with us – over the phone, in person, through the internet, through your mobile device or through email.
Who Does It Apply to?
The Notice applies to all individuals whose personal information we collect, including clients who are individuals, individuals carrying on business alone or in partnership with other individuals, signing officers of our business clients, and beneficiaries of clients to the extent that we collect, use or disclose their personal information.
Changes to the Notice
We may amend this Notice from time to time and will post the revised Privacy Notice on our website
Our privacy principles
The Privacy Notice outlines our privacy principles and informs you of the practices we have in place to manage personal information. We aim to respect and protect your privacy by following the key privacy principles below.
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 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 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 to our collection, use or disclosure of the required information to perform those services.
We limit collection of your personal information to that which we determine is necessary for the purposes we identify for you.
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 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. 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 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 make readily available to our clients, employees and agents, information about our policies and procedures relating to our management of personal information.
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.
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.
What Personal Information Do We Collect
We may collect personal information when you use our websites, online, mobile and other electronic services (collectively, digital channels), including:
- Personal information you provide like account and contact information, including your name, email address, user ID, password and service preferences – refer to your specific app for additional applicable information
- Financial information – that you provide to us at the time of account creation of an account through our online or mobile account creation process
- Transactional data about your use of our products and services
- Mobile phone number
- Device-related information like:
- Internet Protocol (IP) address, which is a unique set of numbers assigned by internet service providers (ISP) to all devices used to access the Internet. While CI Private Counsel LP (“CIPC”) is not able to identify an individual using the IP address alone, in certain circumstances, it could be used to identify an individual using the site.
- Mobile country code, which is a three-digit number that indicates the country in which your mobile device is registered (for example, 302 is the mobile country code for Canada)
- Geolocation (if enabled on your device) provides the approximate physical location of your device
- Device ID, which is a unique number that identifies your device
- Make and model of your device
- Operating system of your device
- Information about the screen size of your device
- Date and time of your use of our app
- Browser data
- Software applications data
- Mobile device identification number (IMEI) Mobile marketing identification (if enabled) such as AAID and IDFA
- Statistical information about how users interact with our digital channels, such as average time spent on a specific mobile or web page
- Website use information, such as browsing behaviour on our websites and links, location you click, form data and downloads, as well as other data gathered from the use of web tools (for example, cookies, web beacons, tagging)
- Other information, such as any feedback you may provide us
For What Purposes Do We Use and Disclose Your Personal Information
We may use or disclose this information collected online to:
- Verify your identity and authenticate you during online sessions
- Provide and manage the online products and services
- Provide you with services and offers compatible with your device and relevant to your region
- Determine eligibility of your device
- Protect against fraud, security threats and otherwise manage risks
- Communicate with you regarding products and services that may be of interest, including displaying targeted and relevant advertising, and offering you special promotions
- Evaluate and improve our websites, online apps, mobile apps and other electronic offerings
- Tailor our services and otherwise enhance the online customer experience to better meet your needs through digital channels
- Perform analytics and measure the effectiveness of our digital channels and services, including obtaining insight into how to improve the design, content and navigation of our digital channels
- Satisfy legal or regulatory requirements
Use of Web Tools
- Cookies: A cookie is a string of data containing a unique identification number that our website sends to your computer’s web browser.
- When you first visit our website, you will be presented with a banner which allows you to review the various category of cookies that are on our website and select which category of cookies you would like to accept. Additionally, you can 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.
- Tagging: Tagging software is customized code on our websites, designed to monitor user activity on our websites, to help us in presenting users with content relevant to their use of our website.
- Web Beacons: Web beacons are small and transparent images embedded in web pages and email communications that, when combined with cookies, help provide us with information about the use and effectiveness of a website or email communication. As an example, we may include web beacons within email communications to receive confirmation of receipt of an email communication or clicks on links within our websites
- Email Communications: 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. CIPC 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 or “opt out” from receiving emails from our company, and/or Partners and Associates.
- Voluntary Participation: 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.
- Educational Webinars: You may choose to enter your information to participate in online meetings and 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 third-party providers of webinars. If you do not want your information used for the disclosed purposes, do not participate in these voluntary activities.
Our Security Measures
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.
Your Security Measures
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 CIPC’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. CIPC will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. CIPC will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails.
Our Privacy Office
If you have any questions or concerns about our privacy practices, the privacy of your personal information, or you want to change your privacy preferences, please let us know. We are committed to helping resolve your questions or concerns.
Step 1: Voice your question or concern
The best way to address the concern or question is to raise it with your CI Private Wealth Advisor as soon as it comes up. For your own security and safety, never send your account numbers, usernames, passwords or any other personal information by email. If you are not satisfied with the answer or resolution provided in Step 1, please proceed to Step 2. If you are not satisfied with the answer or resolution provided in Step 1, please proceed to Step 2.
Step 2: Escalate your concern to the Privacy Office
You can escalate your concern in the following ways: Ask the individual you are dealing with in Step 2 to escalate on your behalf. Escalate the concern directly with the Privacy Office, using the following contact information:
CI Private Wealth
Privacy Office: 2 Queen Street East
Toronto, Ontario M5C 3G7
Step 3: Further Escalation
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