PRIVACY NOTICE

Our Privacy Policy

This Privacy Policy applies to the operations of  CI Private Counsel LP and its division CI Private Wealth. It applies regardless of how you communicate with us – over the phone, in person, through the internet, through your mobile device or through email.

We are dedicated to respecting and protecting the privacy and confidentiality of the information you have entrusted to us. Our Privacy Policy outlines our privacy principles and practices.

Who does it apply to?

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,

What is Personal Information?

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.

What Personal Information Do We Collect?

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,

  • Contact Information, including name, address, telephone number, and email address
  • Date of birth to help us identify and authenticate you
  • Social Insurance Number (SIN), as required to comply with Canada Revenue Agency’s reporting requirements. We also use your SIN as a unique file number because it is necessary to keep your information separate from that of other clients with a similar name
  • Financial Information including bank account information to facilitate deposits and withdrawals from your account with us. When required we also use your financial information including your assets and liabilities, income and investment holdings to ensure that products, services, and advice we provide are appropriate for you and the investments you make are suitable for you.
  • Employment Information to open accounts and in order to comply with anti-money laundering and other regulations
  • Audio Recordings, we monitor or record incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes, and to establish a record. If you do not wish to have your call recorded, you have other options to conduct business with us, such as in person, online, or by communicating with us in writing
  • Email Information, when you send us an email or ask us to respond to you by email, we learn your exact email address and any information included in the email. We use your email address to reply to you and we will store your communication and our reply in case we correspond further. IMPORTANT: We will not ask you to provide personal information or login information, such as username, passwords, PINs, security question and answers or account numbers, through unsolicited email. If you receive an email claiming to be from us that you believe to be fraudulent, do not respond and do not open or click any links or open attachments contained in the email. Please notify us immediately and then delete the email.
  • Website and Mobile Applications Use: when you choose to use our website or mobile application we collect information about your use of these services, please refer to our Online and Mobile Privacy Policy for details.

 

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.

  • Contact Information, including name, address, telephone number, and email address to facilitate communications with you about your business.
  • Provincial Securities Registration Status Information to determine categories and status of registration with provincial securities commissions and self regulatory organization.
  • Audio Recordings, when we monitor or record incoming or outgoing telephone calls with you to ensure accuracy, security, service quality, for training purposes, and to establish a record. If you do not wish to have your call recorded, you have other options to conduct business with us, such as in person, online, or by communicating with us in writing
  • Email Information, when you send us an email or ask us to respond to you by email, we learn your exact email address and any information included in the email. We use your email address to reply to you and we will store your communication and our reply in case we correspond further. IMPORTANT: We will not ask you to provide personal information or login information, such as username, passwords, PINs, security question and answers or account numbers, through unsolicited email. If you receive an email claiming to be from us that you believe to be fraudulent, do not respond and do not open or click any links or open attachments contained in the email. Please notify us immediately and then delete the email.
  • Website and Mobile Applications Use: when you chose to use our website or mobile application we collect information about your use of these services, please refer to our Online and Mobile Privacy Policy for details.

 

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.

  • Contact Information, including name, address, telephone number, and email address to facilitate communications with you about your business.
  • Attendance Information, including the events that you have participated in, the date, time and location of your attendance in order to provide you with professional accreditation certificates of training or event participation.
  • Responses to Surveys, Feedback, Contests, or other activities we sponsor, 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 event, or improving our events, 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.
  • 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.

 

  • Social Media, when communicating with us through social media, we may monitor or record our discussions to maintain a record of the interaction, to enhance client service, and to confirm our discussions with you.
  • Device Information such as information about your browser, operating system, software applications, IP address, geolocation, security status, and other device information to improve your experience, to protect against fraud, and to manage risk
  • Website and Mobile Application Use Information such as browsing behaviour on our sites and links, location you click, form data and downloads, as well as other data gathered from the use of web tools (for instance, Cookies, Web Beacons, Tagging) to better understand your interests and needs so that we can serve you better. For more information, see our Online and Mobile Privacy Policy.

 

Changes to this Policy

We may amend this Policy from time to time and will post the revised Privacy Policy on our website.

Our Privacy Principles

The Privacy Policy 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.

Taking Accountability

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 Identify the Purposes for Our Collection, Use, Or Disclosure

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.

The Purposes that we Collect, Use and Disclose Personal Information

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:

Including to:

  • Open and operate your account,
  • Verify your identity,
  • Execute transactions you request,
  • Record account information and report account status back to you,
  • Respond to any request or questions you may have,
  • Provide you with quality personalized service and support

 

Including to:

  • Determine suitability of products and services, 
  • Determine your eligibility for certain of our products and services, or products or services of others
  • Communicate with you about products and services that may be of interest,
  • Market and advertise our products and services,
  • Conduct internal research and data analytics, including effectiveness of digital marketing,
  • Anonymize data or create aggregated datasets, such as for consolidating reporting, research, or analytics

 

Including to

  • Provide all required tax reporting,
  • Comply with legal, regulatory, and contractual requirements, or as otherwise permitted or required by law 
  • Fulfill obligations under federal anti-money laundering and suppression of terrorism legislation, 
  • Protect our interests, including recovering any debts you may owe us,
  • Protect against fraud and other crime and to manage risk, including conducting investigations and proactive crime prevention measures

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 Consent and Provide Choices

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.

  • We may obtain your express consent verbally, online, or in writing. For instance, when we collect your information via our account application form, you will formally indicate your consent for us to collect and use the information when you sign the application.
  • We may, however, get your implied consent through your use of a product or service, or when you approach us to obtain information, inquire or apply for products or services from us.
  • Also, we may obtain consent directly from you or by your authorized representative, such as your financial advisor or your dealership.

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 the Collection of Personal Information

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.

Limiting Use and Disclosure

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.

Use

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.

 

Disclosure

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.

Why do we disclose personal information:

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.

What third parties do we disclose your information to?

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

Retaining Information

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:

  • In our offices
  • In secure off-site storage facilities, or
  • In the offices of our service providers

 

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.

Keeping Information Accurate

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.

Protecting Information

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 have policy and procedures in place which inform our employees, representatives, and agents of our and their responsibilities when collecting, using, and disclosing the personal information that we collect.  We provide our employees with annual training on our privacy policy.

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.

See Mobile and Online Privacy Policy

Accessing or Correcting 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.

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:

  • Contains references to other persons
  • Contains proprietary information confidential to us or your financial advisor
  • Has been destroyed
  • Is too costly to retrieve
  • Is subject to legal or some other form of privilege
  • Cannot be disclosed for legal reasons
  • Relates to an investigation

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.

Online and Mobile Privacy Policy

Scope

This Online and Mobile Privacy Policy supplements the Privacy Notice and specifically addresses the way in which we collect, use, disclose, and manage personal information in connection with our online, mobile and other digital channels and services. It should be read in conjunction with the Legal Notice and Terms of Use.

Your Consent

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 collect personal information when you use our websites, online, mobile applications, and other electronic services (collectively, digital channels), including:

  • Personal information you provide within our digital channels, such as account and contact information, including your name, email address, user ID, password, and service preferences. Please Refer to your specific app for additional, applicable information.
  • Account Opening information – that you provide to us at the time of account creation through our digital channels to create you account and/or user profile.
  • Device-related information including:
    • Internet Protocol (IP) address - An IP address is a unique set of numbers assigned by Internet Service Providers (ISP) to all devices used to access the internet. While we are 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 phone number
    • 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)
    • Device ID which is a unique number that identifies your device
    • Make and model of your device
    • Operating system of your device
    • Information about screen size of your device
    • Mobile device identification number (IMEI)
    • Geolocation (if enabled on your device) provides the approximate physical location of your device
  • Digital Channel Use Information including:
    • browsing behaviour such as average time spent on a digital channel.
    • Date and time of your use of our digital channels.
    • Browser data when using our digital channels.
    • Software applications data.
    • Mobile Marketing ID (if enabled) such as AAID and IDFA
    • Data and downloads, as well as other data gathered from the use of web tools (for example, Cookies, Web Beacons, Tagging)
  • Voluntary Participation Information, such as any feedback you may provide us through our website or mobile applications.

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
  • Determine eligibility of your device
  • Provide you with services and offers compatible with your device and relevant to your region
  • Communicate with you, with your consent, regarding products and services that may be of interest, including displaying targeted and relevant advertising, and offering you special promotions
  • Tailor our services and otherwise enhance the online customer experience to better meet your needs through digital channels
  • Evaluate and improve our websites, online apps, mobile apps, and other electronic offerings
  • 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
  • Protect against fraud, security threats, and otherwise manage risks
  • Satisfy legal or regulatory requirements

Use of Web Tools

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.

Cookies: A Cookie is a string of data containing a unique identification number that our website sends to your computer’s web browser. We use cookies and online analytics tools, to collect information to understand how people are using the Services and how we can make them better.

How Can I Refuse Cookies?

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.

Online Authentication Process: Upon registration for our online services and mobile applications, you will be asked to provide certain personal information and maybe asked to establish security questions or other security setting, such as multifactor authentication. This information is used solely to verify your identity and maybe cross-referenced against the information you provided to us when you opened your account. If you choose to utilize a biometric solution provided by your device for authentication with our mobile applications the biometrics utilized in the authentication process will not be received by us and will remain within your device and be subject to your devices manufacture’s privacy policy.

Your Digital Channel Choice

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. 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.

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.

Online Meetings, Webinars or Events

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.

Safeguards

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 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.

Third Party Links

For your convenience, the Services may provide links or pointers to third party sites. You are subject to any terms and conditions of such third-party sites. Non-CI websites are not subject to CI’s privacy policy or security standards.

 

Contact Us

CI Private Wealth, a division of CI Private Counsel LLPPrivacy Office
15 York Street, 2nd Floor
Toronto, ON
M5J 0A3
Phone: 1-800-792-9355
Email: privacy@ci.com

How to Report a Concern or Obtain More Information

STEP 1: Voice your question or concern

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.

STEP 2: Escalate your concern to the Privacy Office

If our Service group are unable to address your concern or question you can escalate in the following ways:

  • Ask the individual you are dealing with in Step 1 to escalate on your behalf.
  • Escalate the concern directly with the Privacy Office, using the following contact information.

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
Call: 1-800-282-1376
Visit: www.priv.gc.ca

 

Last Update September 19, 2023