Picton Mahoney keeps all personal information in strict confidence and controls access to, and use of, such information based on the practices and procedures described in this statement.
Personal Information and Obtaining Consent
Personal information is any information that identifies an individual, including the person's name, address, age, financial records, social insurance number, credit history, personal email address and home telephone number.
As a fund dealer and manager, we obtain investors' personal information directly from clients and obtain their consent to appropriate use of that information, in account forms and subscription agreements. Where investors are introduced to our products through dealers or other intermediaries, those firms also may provide us access to the investors' personal information. In those cases, such firms are required to obtain their customers' personal information as well as consent for its use. An investor's personal information allows us to:
Our Use of Personal Information
- Establish an investor's identity;
- Determine an investor's eligibility for a product or service;
- Protect all parties against errors or fraudulent activity; and
- Comply with the law.
Picton Mahoney may use personal information to:
- Identify the investor;
- Ensure our records are accurate;
- Establish and administer an investor's account(s);
- Execute transactions;
- Maintain, store, record, and determine investor account holdings and transaction records;
- Provide investors and their authorized advisors with statements/information;
- Provide investors with financial statements, tax receipts, unitholder mailings, transaction confirmations and other information that may be requested or needed to service their accounts;
- Provide investors with quality customer service and support; and
- Meet legal and regulatory requirements.
An investor's personal information will only be used for the purposes for which it was collected. Picton Mahoney may share personal information with other parties as required by law and with third parties assisting us in providing services, including investor recordkeeping, statement preparation and printing. Picton Mahoney has legal agreements with such third party providers to ensure the proper handling and protection of personal information. Additionally, we may be required to provide personal information when responding to a search warrant, court order or other legally valid request. In particular, we disclose your Social Insurance Number in order to comply with Canada Revenue Agency's income reporting requirements and the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
An investor should contact Picton Mahoney's Privacy Officer to withdraw consent to any use and disclosure of their personal information; however this may limit the investor's opportunity to access our services or products.
An investor who wishes to access or correct his or her personal information should contact our Privacy Officer and we will accommodate the request to the extent possible.
Storage and Security
Personal information in our possession may be kept in electronic or paper format in the offices of Picton Mahoney or our third party providers. Personal information may also be kept in secure offsite storage facilities. At Picton Mahoney we maintain such security measures as passwords and restricted access to our offices and records to protect personal information against unauthorized access, theft or misuse.
Any personal information collected from an investor will be used for the specified purposes and will be retained for as long as is necessary to provide the service or as required by law.
Picton Mahoney does not collect any personal information from visitors browsing our website although personal information may be requested if a visitor chooses to send Picton Mahoney an email message. In addition, in the course of saving the contact information you enter in the forms on this site, Picton Mahoney uses a cookie to store information locally on your computer.
Questions and Concerns
Any inquires and complaints received will be reviewed by Picton Mahoney's Privacy Officer and, if required, forwarded to an investor's dealer or other intermediary. Contact information for Picton Mahoney's Privacy Officer is provided below.
to see that agreement. You may withdraw your consent to collection, use and disclosure of your personal information at any time, subject to legal and contractual restrictions and reasonable notice.
What information is collected and how is it used?
Picton Mahoney Asset Management (“Picton Mahoney”) collects personal and other information provided by you. Picton Mahoney also collects information about your device through our website, such as device model, unique device number, browser type, and Internet Protocol address. Information provided by you or about your device helps us improve the website functionality, meet our clients’ needs, provide information that may be of interest to you, measure the effectiveness of our services, enhance security measures and protect our customers. We track user activity of individuals who log in to allow our wholesalers to review your use of the site and use this info to contact you with recommendations for portfolio construction as well as other articles or links that may be of interest to you. (There is detailed event driven tracking of your use of the site).
Does Picton Mahoney collect information about physical location?
No, Picton Mahoney does not collect information about your device’s approximate physical location.
Will Picton Mahoney share the information?
For the purposes stated above or as described within the website, Picton Mahoney may share the information collected with our employees or third parties acting as our service providers or agents, who are required to maintain the confidentiality of the information. We may share the information collected with government agencies, public bodies, regulators or other entities where permitted or required by law.
Picton Mahoney uses appropriate physical, organizational and technological measures to protect the personal information you provide to us against loss or theft, and unauthorized access, disclosure, copying, use, or modification. However, no online data transmission or storage can be guaranteed to be secure from access by unintended recipients and Picton Mahoney will not be responsible for any breach of security unless this breach is due to its gross negligence.
If you have a question or concern about any collection, use or disclosure of personal data by Picton Mahoney or wish to access or correct your personal data, please contact our privacy officer by sending an e-mail to firstname.lastname@example.org.
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