Cowan Asset Management Ltd. (“we” or “us”) has been in the investment business since 2014. We practice confidentiality in the handling of all Personal Information we have collected. We only use the information we are given to provide the services for which we have been retained. These services include:
- Providing investment knowledge and expertise
- Wealth management products
PERSONAL INFORMATION means information about an identifiable individual. Personal Information does not include certain business contact information.
Personal Information, for the purpose of this policy, shall not include anonymous information disclosed as aggregate data. Aggregate data, for the purpose of this policy, refers to data that does not reveal individual-specific information.
WHY WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
Generally, we require your Personal Information so we may:
- Verify and confirm your identity
- Offer and provide products and services that meet your needs
- Determine your eligibility for products and services
- Communicate with you and provide ongoing service
- Process billings and payments
- Comply with laws and regulations
- Detect and prevent fraud
We will make sure you understand why we need your Personal Information by using clear, understandable language when we identify the purpose. In order for us to provide our services, we may disclose your information to other parties.
PERSONAL INFORMATION WE MAY ASK YOU FOR
We collect only the information we need for the purposes we have identified to you. Personal Information we collect will depend on the service you request and may include:
- Name, address, telephone and fax numbers, email addresses
- Birth date
- Marital status
- Social Insurance Number
- Driver’s license information
- Passport information
- Employment information
- Financial information
- Banking information
- Spousal information which may include all of the above
We may ask you to provide this information or, where permitted by law, we may obtain it from third parties such as financial institutions.
We collect, use or disclose your Personal Information with your consent when it is legally required. You may provide express consent in writing (e.g., through a signed application form or other signed document), in person or over the telephone. Alternatively, there may be times when we determine that your consent is implied, for example, when you contact us for our services.
There are special circumstances where your consent is not required. This includes, but is not limited to, situations involving investigations of fraud or responding to reports of financial abuse. We may also be requested to disclose information to securities regulatory and securities oversight organizations that govern us as well as to taxation authorities.
OPTIONS AVAILABLE TO YOU
You can decline to provide us with your Personal Information or withdraw a previously given consent to collect, use and disclose information, subject to legal and contractual conditions. However, we may not be able to provide you with the services or products that we determine best fit your needs without your consent to use your Personal Information.
PROTECTING AND RETAINING YOUR PERSONAL INFORMATION
We are responsible for all Personal Information in our possession, including information that may be transferred to other parties. Access to your Personal Information is restricted to those employees, agents and authorized service providers who require this information to assist us in providing services and products to you.
Your information may be stored outside of Canada. While this does not change our responsibility, such information that is outside of Canada is subject to the laws of the country in which it is held.
We have developed security procedures to safeguard and protect Personal Information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.
Furthermore, we require our staff to sign a Confidentiality Agreement and annually sign a Code of Business Conduct within which is detailed our expectation that staff will respect and safeguard client information. Employees are aware that a breach of confidentiality could result in termination of their employment.
We will keep your Personal Information as long as it is necessary or as required by law.
When we destroy Personal Information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.
ACCESSING YOUR INFORMATION AND KEEPING IT ACCURATE
You have the right to request access to your Personal Information which we hold. Requests for Personal Information held by us, or corrections to such information, can be made by contacting our Privacy Officer(s) by email, phone or fax:
Cowan Asset Management Ltd.
705 Fountain Street North, PO Box 1510
Cambridge, ON N1R 5T2
Phone: 1-844-334-3323 x2
In response to such requests, we will provide or correct that Personal Information which can be retrieved or corrected at a reasonable cost to us and will do so in a timely manner. In order to guard against fraudulent requests for access, we will require sufficient information to allow us to confirm the identity of the person making the request before granting access or making corrections.
Note: As is the case with all companies, we 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.
QUESTIONS OR CONCERNS?