Privacy Policy

Cowan Asset Management has been in the investment business since 2012.

The Princeton Holdings group of companies has long practiced confidentiality in the handling of all personal information we have collected from our clients. Cowan Asset Management only uses the information it is given to provide the services for which it has been retained. These services include:

  • Providing investment knowledge and expertise 
  • Wealth management products

This Privacy Policy is based on the Canadian Standards Association Model Code for the Protection of Personal Information, and the Federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Within this policy, we, Cowan Asset Management will address how the staff, Officers and Directors of Cowan Asset Management intend to collect, use, and disclose Personal Information in the context of these principles. This policy reflects Cowan Asset Management’s commitment to the privacy of our clients’ Personal Information. Cowan Asset Management’s collection, use and disclosure of its staff’s Personal Information is dealt with in a separate policy.

Cowan Asset Management may disclose Personal Information to any individual or organization for services that are provided to assist it in the conduct of its mandate, including an individual or organization that performs services on its behalf, but only if that individual or organization agrees to use the Personal Information solely for the purposes of performing tasks on behalf of, and under the instruction of, Cowan Asset Management and, with respect to that information, to act in a manner consistent with the relevant principles articulated in this Privacy Policy.

In order to be certain you are aware of the scope of the information to which our Privacy Policy refers, please note the following definition (as defined in PIPEDA):

Personal Information: Means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. 

Personal Information for the purpose of this policy, shall not include information disclosed as aggregate data. Aggregate data for the purpose of this policy, refers to data that does not reveal, and cannot be manipulated to reveal, member-specific information.


1. Accountability

The Personal Information Cowan Asset Management collects, or is provided, is used and disclosed for the purposes of conducting the services it provides. As part of the employment process, Cowan Asset Management's staff, Directors and Officers will sign a code of conduct which outlines Cowan Asset Management's expectation of its employees to act responsibly in the handling of client information.

  • Cowan Asset Management’s management has developed and adopted this Privacy Policy and is refining its Security and Records Retention policies.
  • Cowan Asset Management has assigned a Privacy Officer to provide client service on matters of privacy relating to Cowan Asset Management’s use, disclosure, security and retention of personal or personal health information. Cowan Asset Management’s Privacy Officer(s) will also be responsible for maintaining this policy and updating staff on changes to both privacy legislation and business practices.
  • Cowan Asset Management will continue to update all staff on privacy related issues and legislation.

Cowan Asset Management collects personal information in the course of providing services to our clients.

2. Identify the purpose

Cowan Asset Management collects personal information in the course of providing services to our clients. The following is an example of circumstances in which Cowan Asset Management may be provided, or required to collect, personal information:

3. Obtain consent

Consent to use personal information is required to be obtained at the time of its collection. If Cowan Asset Management collects personal information directly from an individual, Cowan Asset Management will obtain express consent for the collection, use and disclosure of such information. However, Cowan Asset Management may receive personal information collected by other parties. Where possible in these circumstances, Cowan Asset Management will take reasonable measures to require that consent for its use of the personal information has been obtained.

If Cowan Asset Management uses personal information it has collected, or has been provided, for any reasons other than those disclosed to an individual at the time consent was given, then Cowan Asset Management will seek to obtain consent for the new use of the information.

4. Limit collection

Cowan Asset Management limits its collection of personal information to that which is reasonably required to accurately complete the services for which it has been retained. It is committed to respecting the privacy of an individual’s personal information and will not collect personal information which is not reasonably required.

5. Limit use, disclosure and retention

Cowan Asset Management limits its use and disclosure of personal information to the purpose(s) described at the time the information is collected. Cowan Asset Management retains personal information it collects only as long as is necessary to completely fulfill our services. Cowan Asset Management maintains a records retention policy. The retention policy has been developed to meet Cowan Asset Management record retention requirements consistent with good business practices and known industry standards.

In the event that Cowan Asset Management decides to purchase, sell, reorganize or transfer the assets of a business, including any Personal Information held by that business, Cowan Asset Management’s client information may be subject to review for such purpose by another party. Should Cowan Asset Management or such other party wish to use any Personal Information for purposes not described herein, then consent for such use of the information will first be obtained.

Note: As is the case with all companies, Cowan Asset Management may be lawfully bound to disclose personal information for purposes other than those described at the time consent was obtained. These purposes have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

6. Be accurate

Cowan Asset Management recognizes that personal information can change and encourages its clients to keep their personal information current so that Cowan Asset Management may provide the best services possible. Within a reasonable time of being notified, Cowan Asset Management will update records to reflect changes in personal information. 

7. Use appropriate safeguards

Cowan Asset Management has inventoried the various ways in which it stores personal information, and has taken reasonable measures to ensure the security of this information within its premises, at offsite storage locations and in its system databases. 

Furthermore, Cowan Asset Management will require its staff to sign a code of conduct within which is detailed its expectation that staff will respect and safeguard client information. Through this agreement, employees are aware that a breach of confidentiality could result in termination of their employment.

8. Be Open

Cowan Asset Management’s Privacy Officer is mandated to ensure that its Privacy Policy and internal Security and Record Retention Policies are maintained. 

Should you wish to question why specific information is required, our Privacy Officer is available to answer any such inquiries.
In all matters of privacy, including access requests and privacy concerns, we encourage our clients to contact our Privacy Officer:

Michael Kosmalski
President and Chief Investment Officer, Cowan Asset Management
705 Fountain Street North | PO Box 1510
Cambridge, ON, N1R 5T2
Phone: 1-844-334-3323

9. Give individual access

It is extremely important for clients to know that they have access to their personal information. Requests for personal information held by Cowan Asset Management, or corrections to such information, can be made by contacting the sponsoring employer, or, in the case of direct client relationships, personal information can be requested or corrected by contacting the Privacy Officer(s) by e-mail, phone or fax. In response to such requests, Cowan Asset Management will correct or provide that personal information which can be corrected or retrieved at a reasonable cost to Cowan Asset Management or the sponsoring employer, and will do so in a timely manner. In order to guard against fraudulent requests for access, Cowan Asset Management will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections. 

Note: As is the case with all companies, Cowan Asset Management may be lawfully bound to deny access of an individual to their personal information. Reasons for such a denial have been described in applicable privacy legislation as those designed to protect personal and/or public interest.

10. Provide recourse

Cowan Asset Management will review any and all concerns over privacy matters that are submitted to Cowan Asset Management. Privacy concerns are managed by its Privacy Officer(s), who provide both a response to the concern as well as contact information for regulatory authorities. Cowan Asset Management’s Privacy Officer(s) will use any concerns to assist in measuring the effectiveness of its Privacy Policy, as well as business practices. Amendments to the Privacy Policy will be described on Cowan Asset Management’s website, alongside the updated policy. Whether or not Personal Information already collected and used at Cowan Asset Management will be affected by any such amendments, will also be discussed on the website alongside the notice of the change.