This policy applies across the Wellington-Altus group of companies, including Wellington-Altus Private Wealth Inc., Wellington-Altus Private Counsel Inc., Wellington-Altus Insurance Inc., and Wellington-Altus USA Inc. (collectively referred to as “Wellington-Altus”) including all Websites and mobile content operated by Wellington-Altus.
At Wellington-Altus we are committed to protecting the privacy of your personal information. We know how important your privacy is to you. We have adopted the following principles and guidelines that set out how we collect, use, and disclose personal information, and how we hold ourselves accountable and accessible to you.
Personal information is any information that identifies you as an individual. Personal information can include facts about, or related to, an individual, as well as an individual’s opinions or beliefs. Personal information does not include publicly available information (for example, names, addresses and telephone numbers which are published in telephone directories) or any information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work email address.
Wherever possible, we try to collect personal information directly from you. With your consent, we may also obtain personal information about you from third parties such as lenders or credit reporting agencies. We collect information only by lawful and fair means, and not in an unreasonably intrusive way.
We collect personal information to know our clients so that we can understand their needs and eligibility for products and services and then recommend particular products and services to meet those needs, to comply with legal and regulatory requirements, including disclosure requirements connected with tax, auditing, and securities legislation, and to otherwise administer and provide products and services to our clients. Personal information we typically collect from our individual clients include that individual’s name, address, telephone number, social insurance number, date of birth, employment information, bank information, investment information, as well as relevant personal information regarding that individual’s spouse. The information we collect depends on the products or services you request and in most cases is required by law or Canadian securities regulatory bodies.
There are a variety of circumstances where we may need to disclose some personal information. For example, we may disclose your personal information to your legal, tax, financial, banking and other advisors so that they may provide appropriate advice and services to you (for example, the preparation of income tax returns), to any other third party where you have consented to such disclosure or to a third party where such disclosure is required or permitted by our regulators or by law (for example, to comply with Anti-Money Laundering statutes). We may also, from time to time, be requested to disclose information to securities regulatory and securities oversight organizations to which we are subject for the purposes of an audit or investigation relating to specific accounts or our business generally. Also, we may disclose your personal information if we believe, in good faith, that disclosure is necessary or advisable to protect our interests. We will not disclose your personal information to any third party for the purpose of enabling them to market their products or services to you without first seeking your express consent to do so.
In order to protect your personal information, we will not collect, use or disclose your personal information for any purpose other than those identified above, except with your further consent. We maintain security standards and procedures to help prevent unauthorized access to personal information. Our security standards and procedures are updated and tested from time to time to improve the protection of personal information and to assure the integrity of your personal information. We take appropriate measures to enforce employee privacy responsibilities. Our suppliers and agents are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required, otherwise we will seek your consent prior to disclosing any information.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.
We store personal information on our internal servers and/or with our services providers. Our service providers may store and/or process personal information outside of Canada (including in the United States of America). When information is stored or processed outside of Canada, it may be subject to the laws of and be accessible by legal authorities in such other jurisdictions. We have taken appropriate technical, organizational, and legal steps to secure this information.
We would like to have your consent to continue to collect, use and disclose your personal information for the purposes identified above. However, you do have choices, and you can refuse or withdraw your consent at any time. However, in either case, this may limit or eliminate our ability to provide products and services to you and/or to communicate with you. You may also have your name removed from our telephone, mail or email lists. We use these lists to communicate with you and to inform you of relevant information and/or products or services that we think may be of interest to you.
We attempt to keep our records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. If you would like to access the personal information that Wellington-Altus holds about you, please contact our Privacy Officer at the contact information below.
If you have any questions or concerns about our privacy practices, please contact our Chief Privacy Officer at our Winnipeg office by email at [email protected] or by mail at 300-201 Portage Avenue, Winnipeg, Manitoba R3B 3K6. Otherwise, we will operate on the basis that we have your consent to collect, use and disclose your personal information (including personal information that we have previously collected) for the identified purposes and in a manner consistent with this Policy.