Personal Information Defined
Personal information is defined in PIPA as information about an identifiable individual such as someone’s name, home address, social insurance number, sex, income or family status.
Contact Information means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Employee personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish, maintain, manage or terminate an employment relationship between the Company and its employees.
Collection of Personal Information
In accordance with securities and exchange regulations, the Company collects personal information on subscription agreements and shareholder documents. Personal information is also collected when clients (or members of the public who are potential clients) complete and submit a request for information form through the Company website.
Use of Personal Information
Prospective client and shareholder personal information obtained on subscription agreements or other documents is disclosed only in accordance with securities regulations and only with the prior consent of the client or shareholder. Personal information received through the Company website will not be disclosed to anyone outside the Company unless the client/shareholder has specifically authorized such disclosure, or unless the Company is otherwise required to do so by law.
PIPA allows the Company to disclose employee personal information, without consent, if it is reasonable for the purposes of establishing, managing or terminating the employment relationship.
Retention and Security
Personal information received from shareholders is retained in secure filing cabinets at the corporate offices of the Company for a minimum of one year. Expired shareholder contracts and other documents containing personal information that is no longer valid are moved to secure storage at the offices of the Company and are held for five years or until the transaction for which the information was obtained is completed. Once the purpose for which the information was obtained is fulfilled, forms containing personal information are destroyed.
Personal information received through the Company’s website is stored on a secure database with restricted access. The database is reviewed annually and information received more than a year prior to the review is purged. Clients and shareholders may request the removal of their personal information from the database at any time by sending an email to the Company and the information will be immediately deleted from the database.
Employee personal information is maintained in a secure filing cabinet located in the Company’s offices. Former employee files are kept in secure storage for up to five years and then destroyed.
Any requests to access personal information or requests for information regarding this policy should be directed to:
c/o Bassam Moubarak
Any questions or complaints about the Company’s collection, use or disclosure of personal information either through the website or through other documents should also be sent to the Privacy Officer.