We ask our clients for no more personal information than necessary.
ShareOwner needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal obligations. ShareOwner is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.
The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone number, email addresses, birth date, social insurance numbers (for tax reporting purposes), and information about your investments, and investment experience. We also collect your chequing account information and optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).
Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Policy. We also collect your responses to other regulatory questions that we are required by law to collect.
We limit the use of your personal information.
The personal information we collect when you open an account is used for the following purposes:
- understanding your financial needs and delivering financial products and services that meet them;
- verifying your identity and other information you have provided to us;
- opening and servicing your account;
- sending and receiving bill payments through your chequing account;
- detecting and preventing fraud and other unauthorized or illegal activities;
- meeting legal and regulatory requirements;
- transferring your account to or from another institution; and
- as otherwise required or permitted by applicable law.
Other ways we collect and use personal information.
Referral Program: If you participate in our referral program (or other “Invite a Friend” features that may be available in our App and/or on our Websites), we collect the email address of the individual(s) who you wish to refer to ShareOwner. We use this information to send the recipient a one-time email containing information about the referral program. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you.
Marketing Communications: From time to time, we may obtain your consent to send you email, SMS text messages and other communications about ShareOwner products, services, or events that may be of interest to you, as well as products, services or events of our affiliates. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at firstname.lastname@example.org.
Customer Service: If you contact a customer service agent with a comment, question or complaint by email, text message, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and, product and service offerings.
Employment: If you inquire about or apply for a job with ShareOwner or any of its affiliates, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
How we collect personal information.
We limit access to clients’ personal information.
We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.
We implement safeguards to protect personal information.
ShareOwner maintains reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.
Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
We restrict disclosure of personal information.
Service Providers: We may transfer your personal information to our affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting.
Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of ShareOwner or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Securities Regulations: We may share your name, contact information and holdings with issuers of securities that you hold in your account and other persons/companies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations. We may also disclose certain personal information, including the number of and purchase price of units purchased, to the applicable Canadian securities regulatory authority where required by law.
Legal: We and our Canadian, US and other affiliates and third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by Canadian, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
We expect similar safeguards from our service providers.
Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.
We take privacy seriously.
We will provide you with access to your information.
Individuals have the right to access, update, and correct inaccuracies in his/her personal information in ShareOwner's custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Settings”. Otherwise, an individual wishing to request access, updating and corrections of inaccuracies in other of his or her personal information in our possession or control may send a written request to this effect to ShareOwner's Chief Compliance Officer at the contact information below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.ShareOwner
862 Richmond Street West, 2nd floor
Toronto ON M6J 1C9 Canada
We collect and use information about your visit.
In general, you can visit our Website and our App without indicating who you are or submitting any personal information. However, we collect and/or maintain the IP (Internet protocol) addresses of all visitors to the Website and users of the App and other related information such as page requests, browser type, operating system and average time spent using the App and the Website. We use this information to help us understand Website and App activity and to monitor and improve the Website.
Tracer Tags & Web Beacons: The Website may also use a technology called “tracer tags” or “Web Beacons”. This technology allows us to understand which pages you visit on the Website. These tracer tags are used to help us optimize and tailor the Website for you and other future visitors to the Website.
Website Analytics: We may use third parties to help us gather and analyze information about the areas visited on the Website in order to better understand, evaluate and improve the user experience and the convenience of the Website.
Social Media: We may offer you the opportunity to engage with our content on or through third- party social networking websites, plug-ins and applications. When you engage with our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender) to deliver the content or as part of the operation of the website, plug-in or application. When you provide information from your social media account, we may use this information to personalize your experience on the Website and on the third-party social networking websites, plug-ins and applications, and to provide you with other products or services you may request.
We use online advertising.
To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Digital Advertising Alliance of Canada website at www.youradchoices.ca/choices.
We may provide links to third party websites.