General Privacy Policy and Policy Statement
At Tradex Management Inc., we take the issue of privacy seriously. The security and confidentiality of personal information that you disclose will be respected. In accordance with current federal privacy legislation, Tradex has adopted new privacy practices to protect customer information.
What is personal information?
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal e-mail address and home telephone number.
What information do we collect?
The personal information in your client account may include your name, mailing address and phone number, social insurance number, birth date, account holdings and transactions and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request. For example, where you have established a pre-authorized chequing plan, which enables you to make purchases at regular intervals, we hold your financial institution account number.
How do we collect your personal information?
Personal information is collected directly from you or through your advisor when you open an account with us. The information is obtained by us when you send us a completed application form or when your advisor transmits information to us electronically. In servicing your account, we will also generate personal information, including transaction information. From time to time, we may be required to collect information from a third party who is not your advisor. The executor of an estate is an example of a third party who may provide information about you or your account to us
How do we obtain your consent?
Before you open an account with Tradex you will be required to provide certain personal information. In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information.
How do we use your personal information?
We may use your personal information for these stated purposes:
- Identifying you
- Establishing and administering your account
- Ensuring the information in our records is accurate
- Executing your transactions
- Verifying previously given information when necessary
- Providing you and/or your advisor/dealer with account statements and other account related information
- Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account
- Communicating with you regarding service offering or products which may be of interest to you
- Communicating with you regarding general research in an effort to enhance our service and product offerings
- Meeting legal and regulatory requirements.
With whom is your information shared?
We may share your information with others outside Tradex in certain limited circumstances including:
- With Third Party Suppliers whom we hire to perform services on our behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, the preparation and mailing of client statements, document storage, imaging and market research. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These third party suppliers are not permitted to disclose this information to others.
- With Other Third Parties. If you purchase Tradex mutual funds through a financial advisor or through another registered dealer, we will share your personal information with the financial advisor and or the other registered dealer. We may also have to contact other financial institutions or mutual fund companies in order to gather information necessary to properly service your account with us.
- When Permitted or Required by Law. Tradex is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry.
We may disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our or your legal rights.
We may also disclose information to various regulators to which we are subject in order to comply with their regulatory requirements. For regulatory purposes, self regulatory organizations including Market Regulation Services Inc., the Investment Dealers Association of Canada, the Mutual Fund Dealers Association of Canada, Bourse de Montreal Inc., and the Canadian Investor Protection Fund (collectively, “SROs”) require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons. SROs collect, use or disclose such personal information obtained from Regulated Persons for regulatory purposes, including:
- 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.
How can you withdraw your consent?
You may withdraw your consent to our use of your personal information at any time by contacting us at 1-800-567-3863. If you withdraw consent, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.
How can I access my personal information?
Upon request Tradex will provide you with access to your personal information. In addition, Tradex may provide you with a list of third parties to whom your personal information was provided.
Where is your personal information kept?
Your personal information may be kept in electronic or paper format in the offices of Tradex or its third-party service providers. Your information may also be kept in secure off-site storage facilities.
How is your information protected?
Tradex and our service providers have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our records and passwords. Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your client account.
How long do we keep your information?
We only keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). Once it is no longer needed, it is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.
Who do you contact about privacy concerns at Tradex?
Tradex has appointed a Privacy Officer to handle all privacy issues. If you have any questions, concerns or issues about our Privacy Policy or about confidentiality issues or other issues raised here, you may contact Mr. Brien Marshall at 1-800-567-3863.
Web Site Privacy Policy Statement
We do not collect any personal information about those who visit our Website for browsing purposes only. Personal information is collected if you order literature by mail or through download or send an e-mail message to us.
We recommend that visitors to our Website send e-mail messages to us. E-mail is one of the fastest and most effective ways to have your inquiries about our products and services addressed. We retain copies of these e-mail messages. The information provided by you will only be used to respond to your inquiry and to provide you with better customer service.
We use the information collected from you when you visit our Website to address your specific requests and to provide better customer service, including the provision of the latest information regarding our products and services. The information collected may also be used to document communications between Tradex Management Inc. and our online visitors and to comply with any applicable legal and/or regulatory requirements.
Employees will have access to information about a Website visitor in order to fulfill that visitor’s requests and provide the visitor with requested information regarding specific products. Our employees are instructed to use strict standards of care in handling the personal information of our clients.
Tradex Management Inc. does not transmit any personal information collected through its Website to any third parties. Personal information may be transmitted, however, if there is a specific need to complete a transaction requested by the online visitor.
