Accountability

 

Greenfield Investment Management Limited is responsible for the personal information you have provided to us.  We have procedures in place to appropriately safeguard this information and review these processes regularly.  All employees and officers of Greenfield Investment Management Limited must abide by the principles outlined below.  Our Chief Privacy Officer is accountable for Greenfield Investment Management Limited’s compliance with the principles described in this privacy policy.

 

Protecting your privacy and the confidentiality of your personal information is a fundamental part of our responsibility to our clients.  Through our policies and procedures and computer security measures, we protect your privacy and the confidentiality of your information.

 

What is Personal Information?

 

Personal information is any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number, birth date, assets and/or income information, employment history, and credit history.

 

Personal Information Collected through Our Website or Email

 

By using this website or contacting us by email, you are consenting to the collection, use, and disclosure of your personal information by Greenfield Investment Management Limited as outlined in this privacy policy and are agreeing to be bound by the terms of this privacy policy.  If this privacy policy is not acceptable to you, do not submit any of your personal information either via the website or email.  We may update this privacy policy from time to time and you are responsible for periodically reviewing the most current version of this privacy policy on this website.  By using this website, you acknowledge that you have read this privacy policy, understand it, and agree to all the terms and conditions within it.  Your continued use of the site or submission of information will be deemed to be your conclusive acceptance of the updated privacy policy.

 

This section describes our policies regarding the collection, use, and disclosure of the personal information that we may collect about you through our website or email, such as your name, address, phone number, fax number, email address or mailing address.  We may collect this information when you subscribe to any of our marketing and correspondence services, when you fill out forms made available through our website, or when you email us with inquiries, comments, or suggestions.  We will limit the information we collect to what we need for the purposes for which it was collected. If we wish to use your personal information for any other purpose, we will obtain your consent before using your personal information.  When you send us an email or when you ask us to respond to you by email, we use the email address you sent your message from to acknowledge your comments and reply to your questions unless otherwise specified in your message.  As well, we will save your communication and our response in case we correspond further.  We may use your email address to send you educational information or information about services you have purchased. If you do not wish for us to send this information to you via email, you may tell us to stop sending such correspondence at any time.  We recommend that you do not send any confidential information or ask for information about your account via regular email as it is not encrypted or secure.  Please contact us for additional account information, or if you have any questions of a confidential nature.

 

Purpose of Collecting Personal Information from Clients

 

Greenfield Investment Management Limited will identify the purposes for which personal information about clients is collected at or before the time it is collected. Greenfield Investment Management Limited collects the personal information that is necessary for its business functions or services.  Unless required by law, we shall not use or disclose, for any new or other purpose, the personal information that has been collected without first identifying and documenting the new or other purpose and obtaining your consent.

 

Collection and Use of Personal Information

 

When you open an account at Greenfield Investment Management Limited, we will obtain personal information about you that will be kept on file in accordance with industry regulations.  Only authorized individuals and entities have access to this information.  Personal information includes your name, address, and telephone number, email address, birth date, social insurance, government issued photo ID, banking information, and your financial asset and investment information.  Personal information is collected through account applications, other forms, questionnaires that you submit to us, contracts that you enter into with us, your transactions with us, meetings and telephone conversations with you, e-mail communications with us, our website (www.greenfieldinvestment.ca), or other correspondence with you.  We collect this information about you to identify you, to contact you or a designated representative, to understand your investment needs, to make suitable investment decisions for your portfolio, to manage the administration of your account, and to satisfy legal, regulatory, custodial and tax reporting requirements.  If you are an individual, Greenfield Investment Management Limited will collect, use, and disclose your social insurance number for income tax reporting purposes.  Greenfield Investment Management Limited will collect, use, and forward a photocopy of your personal ID to our custodian as proof of residency for U.S. withholding tax purposes.

 

Disclosure of Personal Information to External Third Parties

 

When necessary, your personal information will be disclosed to our external third-party service providers such as our custodian, financial institutions, agents, suppliers, and other parties who provide services to us in connection with the services we provide you.  We require third party service providers to agree to abide by our privacy policy which means they will not share your information with others.  These third parties are only provided with the information necessary to perform the required services.  Greenfield Investment Management Limited will use contractual or other means to provide a comparable level of protection while the information is being handled by a third-party service provider or agent.  Greenfield Investment Management Limited can release your personal information to your personal tax accountant, lawyer, or other advisors if we have written instructions from you.

 

Other third parties provided with your personal information may include:

 

• Third parties who provide services to us such as account statement preparation and mailing, compliance consultants, storage facilities, information technology providers, auditors, and lawyers;

• Financial institutions and securities dealers when necessary to carry out your instructions, such as automatic deposits or withdrawals; and

• Governments, government agencies, regulators, courts, or other entities to whom we are legally obliged to provide information.  For example, we may be required to report your income to taxation authorities.  We may also be required to disclose your personal information to self-regulatory organizations (“SROs”), which collect, use, and disclose such personal information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases, and enforcement proceedings.  SROs may, in turn, disclose such personal information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.  Your personal information may also be delivered to the Ontario Securities Commission and is thereby being collected indirectly by the Ontario Securities Commission under the authority granted to it under applicable securities legislation for the purposes of the administration and enforcement of the securities legislation of Ontario. 

 

The Foreign Account Tax Compliance Act (FATCA) is U.S. tax legislation enacted in 2010 to target tax avoidance by U.S. persons using accounts with financial institutions outside of the U.S.  In general, FATCA requires financial institutions outside of the U.S., like Greenfield Investment Management Limited or any other Canadian financial institutions, to collect and report information about the financial accounts held by U.S. persons, who are individuals or entities.  Accounts held by U.S. persons would be reportable for FATCA purposes.  Effective July 1, 2014, Canada adopted these FATCA rules in the Canadian tax legislation which requires Canadian financial institutions to collect information from account holders and report information to the Canada Revenue Agency (CRA) on accounts held by U.S. persons as well as account holders who fail or refuse to certify their FATCA status.  The CRA may then provide this information to the Internal Revenue Service (IRS) in accordance with the provisions of the Canada-U.S. Tax Convention.  Greenfield Investment Management Limited is complying with the Canadian tax legislation that implements these rules.  Generally, subject to certain threshold exemptions, all non-registered accounts opened with a Canadian financial institution are subject to these rules. Registered accounts (including RRSP’s, TFSA’s, RESP’s, RRIF’s) are exempted.  For accounts that are opened on or after July 1, 2014, the Canadian financial institution is required to collect information from the account holder to document and determine whether the account holder is a U.S. person.  Should the information that you provided or communicated to Greenfield Investment Management Limited lead the firm or our custodian to believe that you may be a U.S. person, Greenfield Investment Management Limited will contact you to obtain the necessary documentation or information to decide as to whether your account is reportable to the CRA for FATCA purposes.  If we contact you for such requests, please reply as soon as possible as Greenfield Investment Management Limited may be required to report your account to the CRA for FATCA purposes if we are unable to gather the necessary information from you within the specified time frame. Should you have any questions about FATCA, please contact your tax advisor or visit the following website:

CRA: http://www.cra-arc.gc.ca/tx/nnrsdnts/nhncdrprtng/menu-eng.html

 

Greenfield Investment Management Limited may be involved in the sale, transfer, or reorganization of some or all its business at some time in the future.  As part of that sale, transfer, or reorganization, Greenfield Investment Management Limited may disclose your personal information to the acquiring organization.  However, we will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this privacy policy.

 

We do not sell, lease, barter, or otherwise market your personal information to third parties.

 

Obtaining Your Consent

 

The knowledge and consent of individuals, express or implied, are required for the collection, use, or disclosure of personal information by Greenfield Investment Management Limited, except where inappropriate.  Greenfield Investment Management Limited’s account documents including the Know Your Client Questionnaire, Investment Policy Statement, and Investment Management Agreement contain sections in which you are requested to supply personal information about yourself.  We only request information that is necessary for the opening and operating of your investment account.  By completing and signing these documents and opening an account with us, or by providing us with personal information by any other means including through email or our website, and by continuing to do business with us, you are consenting to the collection, use, and disclosure of your personal information and any subsequent personal information that is collected by us for the purposes which we have set out herein.  Greenfield Investment Management Limited will not, as a condition of the supply of services, require you to consent to the collection, use, or disclosure of your personal information beyond that required to fulfill those purposes. 

 

Generally, your consent is required before we may provide your information to any third parties. However, Greenfield Investment Management Limited does not require your consent to the collection, use, and disclosure of your personal information where such collection, use, and disclosure is reasonably required:

 

• In the normal course of providing service to your accounts;

• By a law enforcement agency, securities regulatory authority, or self-regulatory organization; or

• By legal counsel for the purpose of obtaining advice.

 

You may refuse or withdraw all or any part of your consent at any time, subject to legal and contractual conditions, and we will respect your choices, however this may have an impact on the services that we are able to provide to you.  If you wish to exercise this option, please send a written request to: Chief Privacy Officer, Greenfield Investment Management Limited, 51 Hawarden Crescent, Toronto, Ontario M5P 1M8.  We will inform you of any implications of such withdrawal of consent on our continued provision of services.

 

How we use Personal Information

 

We limit the collection, use, retention, and disclosure of your personal information to that which is permitted or required by law, or that which is reasonably necessary.  We collect and maintain your personal information to give you the best possible service and allow us to establish your identity, protect us from error and fraud, comply with the law, and assess your eligibility for purchasing investments and portfolios that we manage.  We may use your personal information for these stated purposes:

 

• Establishing your account;

• Administering your account;

• Executing your transactions;

• Communicating with you;

• Ensuring our records are accurate;

• Providing transaction confirmations;

• Providing account statements and other reports;

• Issuing tax slips and proxy mailings;

• Contacting your other financial advisors (when requested by you); and

• Meeting legal and regulatory requirements.

 

Safeguarding personal information

 

We carefully safeguard your personal information by taking appropriate steps to ensure it is protected from unauthorized access and disclosure.  We may store your personal information (in encrypted form where we believe it to be highly sensitive) in electronic databases or email servers hosted by us or our service providers, for periods of time and with safeguards that we believe are reasonable depending on the nature and sensitivity of the information.  We restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you.  Greenfield Investment Management Limited’s employees are responsible for ensuring the confidentiality of all personal information they may access.  We ensure that account information is only supplied to people who are expressly authorized by you to receive it.  To maintain awareness of our practices and procedures, annually each of Greenfield Investment Management Limited’s employees is required to sign an agreement affirming their undertaking to faithfully abide by our code of conduct, which contains policies on the protection of personal information.

 

Limiting Retention

 

Personal information is retained as long as necessary to fulfill the identified purposes or in accordance with applicable laws or corporate policies.  Generally, to satisfy regulatory requirements, personal information is retained for at least seven years.  Greenfield Investment Management Limited must therefore retain your personal information on file for some period after you cease to be a client.

 

Accuracy

 

Greenfield Investment Management Limited will strive to keep personal information as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.  Greenfield Investment Management Limited will minimize the possibility that inappropriate information is used to make decisions about an individual.  In general, we will rely on you to provide accurate and complete information and to advise us if your circumstances change over time.

 

Openness

 

Greenfield Investment Management Limited is open about its policies and procedures with respect to the collection, use, management, and disclosure of personal information.  Greenfield Investment Management Limited ensures that individuals can acquire information about our policies and procedures without unreasonable effort.  We strive to make this information available in a form that is generally understandable. 

 

Location

 

Personal information about you is primarily maintained on our networks, or on the networks of our technology providers, which are accessible from our offices at 51 Hawarden Crescent, Toronto, Ontario, M5P 1M8.  Personal information about you may also be located with our other service providers for reasons described herein.

 

Individual Access

 

At Greenfield Investment Management Limited, we want you to understand our commitment to privacy.  Upon a request in writing, Greenfield Investment Management Limited will inform clients of the existence, use, and disclosure of his or her personal information and the individual will be given access to that information, except where the law requires or permits Greenfield Investment Management Limited to deny access.  You may request access to your personal information by writing to Greenfield Investment Management Limited, 51 Hawarden Crescent, Toronto, Ontario, M5P 1M8, Attention: Chief Privacy Officer.  We will respond to your written request promptly.  Greenfield Investment Management Limited may be unable to provide you with full access to your personal information if we are prohibited by law or regulations, or if it has been destroyed.  Greenfield Investment Management Limited will provide you with an explanation if we are unable to fulfill your access request.

 

Corrections

 

You are entitled to challenge the accuracy and completeness of your personal information and have it amended as appropriate, subject to some exceptions as prescribed by law.  You may review the information you have provided to Greenfield Investment Management Limited and make corrections to it.  We may request that you provide corrections in writing.

 

Concerns, Questions, Complaints

 

You may direct a challenge concerning compliance with our policies to our Chief Privacy Officer.  A reply will be provided to you within thirty days of the written complaint being received by us.  You may address questions or privacy-related complaints to the Chief Privacy Officer, Greenfield Investment Management Limited, 51 Hawarden Crescent, Toronto, Ontario, M5P 1M8.  Alternatively, you may contact us by telephone at (647) 636-2119, or by e-mail at info@greenfieldinvestment.ca.