Privacy Policy

1832 Asset Management, a division of 1832 Asset Management L.P., is committed to providing investors with the highest standard of service. As part of our commitment, we strive to protect your privacy and the confidentiality of personal information that you provide to us. Our information handling practices comply with applicable privacy laws.

The following is a description of our privacy policy regarding the collection, use and disclosure of personal information that you provide to us or that is shared with us from other sources. For your convenience, our Privacy Policy is set out in a question and answer format:

What is Personal Information and Why Do We Need it?
How Do We Obtain Your Personal Information?
How Do We Use Your Personal Information?
With Whom is Your Personal Information Shared?
Where is Your Personal Information Kept?
How is Your Information Protected?
What Privacy Rights Do You Have?

1. What is Personal Information and Why Do We Need it?

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 email address and home telephone number.

We require your personal information in order to establish a relationship with you and provide you with the best possible service. Your signature, financial history, current financial position, social insurance number, age and other similar personal information allow us to:

establish your identity;
assess your eligibility for our investment products and services;
continue to offer you the full range of products and services that we believe meet your changing needs; and
protect you and us from error and fraud.

In addition, we require your personal information in order to allow us to meet regulatory or contractual requirements relating to the products and services provided to you.

2. How Do We Obtain Your Personal Information?

Personal information is received by us from you or from your representative with your consent. Other sources from which we may receive your information with your consent include, but are not limited to, our affiliates and other financial institutions, etc.

3. How Do We Use Your Personal Information?

We may use your personal information for the following purposes:

To identify you;
To ensure our records are accurate;
To establish and administer your account;
To execute your transactions;
To maintain, store, record and determine your account holdings and transaction records;
To verify previously given information when necessary;
To provide you and your representatives with account statements/information;
To provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
To provide you with quality customer service and support on your investment needs;
To develop and offer additional products and services that we feel may be of interest to you;
To protect the interests of 1832 Asset Management, such as relates to the collection of debt owed; and
To meet legal and regulatory requirements.

4. With Whom is Your Personal Information Shared?

We are not in the business of selling or distributing our client's personal information to others. Client confidentiality and privacy remains one of our fundamental principals. However, we may share your information with others outside 1832 Asset Management in limited circumstances including:

Third Party Service Providers. We hire third party service providers to perform services on your 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, and imaging. 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.
Your financial advisor. We share your information with your financial advisor and the dealer with which she or he is registered. We may also have to contact other financial institutions or mutual fund companies in order to gather complete information necessary to properly service your account with us.
As Permitted or Required By Law. 1832 Asset Management 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 also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.
Business Re-Organization. As we continue to grow, we may in the future re-organize or streamline parts of our operations. Since our business is based on our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business. These third parties are not permitted to disclose this information to others.

5. Where is Your Personal Information Kept?

Your personal information may be kept in electronic, microfilm or paper format at the offices of 1832 Asset Management, its affiliates or its third-party service providers. Your information may also be kept in secure off-site storage facilities.

6. How is Your Information Protected?

Policies, procedures, guidelines, and safeguards have been put in place to ensure your personal information is protected. Our employees and service providers have access to your personal information to enable them to perform their duties in servicing you. Personal information collected from you will only be used for the identified purposes and will be retained for as long as is necessary to fulfill the service or as required by law.

We regard confidentiality and privacy as a cornerstone to our business. As such, our internal code of ethics requires all employees of 1832 Asset Management to maintain client confidentiality. Each year, our employees receive a current copy of our code of ethics and are required to certify in writing that they will comply with it.

7. What Privacy Rights Do You Have?

Upon request, we will provide you with access to your personal information. In addition, we may provide you with a list of third parties to whom your personal information was provided. If you wish to change or update your personal information, you may request to do so at any time. Please note that we may only alter that personal information required to fulfill the stated purposes. In certain circumstances, we may not be able to provide you with access to specific pieces of information. For example, (i) information containing references to other persons; (ii) information containing proprietary information confidential to 1832 Asset Management or its affiliates; (iii) information that has been destroyed or may be too costly to retrieve.

You may withdraw your consent for the use of your personal information by contacting 1832 Asset Management at any time subject to reasonable notice. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.