Timbercreek Asset Management Inc. (collectively "Timbercreek") takes its commitment to the privacy of client information seriously. In doing so, Timbercreek follows these 10 principles:
1. Accountability: We are responsible for personal information under our control. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.
2. Identifying purposes: The purposes, for which personal information is collected, will be identified by us, or through our, or your, authorized representatives before or at the time the personal information is collected.
3. Consent: Your consent is required for the collection, use and disclosure of personal information, subject to certain exceptions. Such exceptions are set out in the law and include where legal, medical or security reasons make it impossible, or impractical, to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our, or your, authorized representatives. In certain circumstances, it may also be implied.
4. Limiting collection: The collection of your personal information must be by fair and lawful means, and be limited to that which is necessary for the purposes identified.
5. Limiting use, disclosure and retention: Your personal information may only be used or disclosed for the purposes for which it was collected, other purposes you consent to, or as required or permitted by law. It may only be kept for as long as is necessary to satisfy the purposes for which it was collected, or as required or permitted by law.
6. Accuracy: Any personal information that is collected, used or disclosed should be as accurate, complete and as up-to-date as is necessary for the purpose for which it is to be used.
7. Safeguards: Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.
8. Openness: Information about our privacy policies and practices for managing your personal information shall be made available to you upon request.
9. Individual access: Upon written request, you will be informed of the existence, use and disclosure of your personal information and you will be given access to it, subject to certain exceptions, as permitted by law. You may also verify the accuracy and completeness of your information, and request that it be amended, if appropriate.
10. Inquiries and concerns: You may contact us if you have any inquiries or concerns about our privacy policies and practices.
The Information we Collect
Personal information is information that refers to you, specifically.
When we begin our relationship with you, we will tell you the purposes for which we need the personal information we collect.
We will use fair and lawful means to collect your personal information. We will only collect information that is pertinent and consistent with the purposes of the collection. Whenever practical, we will collect the required information directly from you, or from your authorized representative(s), in completed applications and forms, through other means of correspondence, such as the telephone, mail or the Internet, and through your business dealings with us.
In some cases, and with your consent, we may need to ask an independent source to verify or provide supplemental information. These sources could include service providers we retain, financial institutions, your employer or credit reporting agencies.
What we Need to Know and Why
We collect information from you and about you, only with your consent, or as required or permitted by law. In general, we will collect personal information such as your name, address, telephone number(s) or other identifying information, such as your Social Insurance Number (SIN) or date of birth.
The information gathered may be financial, which would include such information as place of employment, annual income, assets and liabilities. It may be investment or advice related, requiring information on such things as your financial goals and retirement plans.
Generally, we collect, use and disclose your personal information to:
- Confirm your identity, and to protect both you and us against errors, fraud or other misrepresentations,
- Evaluate your financial needs and determine the suitability of our products and services for you,
- Determine your eligibility for products and services,
- Properly administer the products and services we provide,
- Comply with a variety of legal requirements, including any tax reporting obligations under the federal Income Tax Act.
We will only keep your personal information in our records for as long as it is needed to fulfill the identified purposes, or as required or permitted by law.
Personal information that is no longer required will be destroyed, erased or made anonymous.
We collect, use and share your personal information only for disclosed purposes related to the products and services we offer, and only with your consent, or as permitted or required by law. Your consent may be expressed in writing, or it may be given verbally, electronically, or through our, or your, authorized representative(s), such as your financial services advisor.
Your consent may also be implied or inferred from certain actions. You may withhold or withdraw your consent for us to collect, use and share your personal information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested. Generally, the disclosure of your personal information will be restricted to those who have a need for, and the right to, the information.
Your personal information will only be provided to:
- Our employees, agents and representatives, who need the information in the performance of their duties for us,
- Our affiliates, to resolve your concerns about any related products and services with us or to make you aware of other products or services that may be of interest to you.
- Service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us,
- Any person or organization to whom you gave consent, and,
- Anyone who is otherwise authorized by law.
For regulatory purposes, regulatory bodies such as FINTRAC or the Ontario Securities Commission may require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Timbercreek.
Such regulators may use the information for such purposes as:
- Surveillance of trading-related activity,
- Sales, financial compliance, trade desk review and other regulatory audits,
- Investigation of potential regulatory and statutory violations,
- Regulatory databases,
- Enforcement or disciplinary proceedings,
- Reporting to securities regulators, and,
- Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
Because Timbercreek is a regulated entity, unless you provide consent to the sharing of information with these bodies for these purposes, Timbercreek cannot provide financial services to you.
Accessing and Amending Your Information
We will make all reasonable efforts to ensure that any personal information we collect and keep is as accurate, complete and as up-to-date as required for the identified purposes. To do so, we will rely on you to provide us with accurate information and to inform us of changes, such as changes in your contact information.
Under Canadian privacy law you have the right to access and verify your personal information maintained in our files, and to request that any factually inaccurate personal information be corrected, if appropriate.
If we receive a request to release your personal information, we will only do so upon satisfactory identification and proof of entitlement of the requestor, or as required or permitted by law.
Should you wish to inquire about the personal information about you we maintain, or about any other matter relating to our privacy policies, please contact
Timbercreek’s Privacy Officer at firstname.lastname@example.org or telephone 1.844.304.9967 for assistance or write to:
Timbercreek Asset Management Inc.
25 Price Street
Toronto, Ontario, Canada