"Professional, practical, an outstanding way to build a brand around your key product - you"
Michael Evans
Senior Vice President, Regional Sales Manager
Mackenzie Financial

Privacy Policy for Clients

Protecting Client Information

AdvisorBranding considers protection of its clients' information an important part of its business. Ensuring that it holds confidential all information respecting its clients' financial affairs is an operational imperative. AdvisorBranding has long-standing security measures in place to preserve the confidentiality of sensitive information, including personal information received on behalf of its clients.

Background

The federal government has passed legislation dealing with the collection, use and disclosure of information about any identifiable individual. This legislation is called the Personal Information Protection and Electronic Documents Act or PIPEDA, and applies to commercial activities across Canada that collect, use and/or disclose personal information, except in those provinces that have passed substantially similar legislation. In those jurisdictions, the substantially similar provincial legislation will apply.

Scope of this Policy

This policy sets out ten principles that will be observed by AdvisorBranding in the collection, use and disclosure of information of clients. If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but still will be treated with appropriate safeguards.

AdvisorBranding collects personal information for the purpose of providing its clients with discretionary portfolio management and financial counselling services. It obtains consent at the time of gathering of the information.

Our Client Personal Information Protection Principles

Accountability

AdvisorBranding is responsible for all personal information under its control and its Personal Information Protection Officer ("PIP Officer") is accountable for T. Haugthon compliance with the principles described in this Policy.

The AdvisorBranding PIP Officer may be contacted at 416-504-7921 x112

Identifying Purposes

AdvisorBranding will identify the purposes for which personal information is collected at or before the time the information is collected. AdvisorBranding will also document the purposes for which personal information is collected.

Consent

The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information. Consent may be given orally or in writing. The type of consent obtained relates to the sensitivity of the information disclosed. For example, when we collect information relating to your discretionary portfolio, we obtain your express written consent to its collection and use.

Limiting Collection

AdvisorBranding will limit the amount and type of personal information collected to that which is necessary for the purposes identified by AdvisorBranding. The personal information will be collected by fair and lawful means.

Limiting Use, Disclosure and Retention

AdvisorBranding will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. For example, you have authorized us to place orders with brokers, investment dealers, banks, trust companies and other financial institutions for the purchase and sale of securities.

Personal information will be retained only as long as necessary for the fulfillment of those purposes. New uses and disclosure require new consent.

Accuracy

AdvisorBranding will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. AdvisorBranding will minimize the possibility that inappropriate information is used to make a decision about the individual.

Safeguards

AdvisorBranding will protect personal information with security safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized disclosure, copying use or alteration.

Openness

AdvisorBranding will be open about its policies and procedures with respect to management of personal information. AdvisorBranding will ensure that individuals are able to acquire information about AdvisorBranding's policies and procedures without unreasonable effort. AdvisorBranding will make this information available in a form that is generally understandable.

Individual Access

Upon a client's request in writing, AdvisorBranding shall inform a client of the existence, use, and disclosure of his or her personal information and the client shall be given access to that information, except where the law requires or permits AdvisorBranding to deny access.

"AdvisorBranding took the time to understand who we are and how we are different. They presented us a marketing solution that encompassed our beliefs while maintaining a very professional deliverable. The finished results have been very well received and we are only in the beginning of this endeavor. We have found it has already paid for it self - well done, it works."

McGrath Tenpenny Group
Wellington West Capital Inc.
Campbellville, ON