Harris Douglas Privacy Policy

This privacy policy applies to personal information that Harris Douglas Asset Management Inc. (“we” or “us”) collects from actual or prospective clients (“you”). “Personal information” means information about an identifiable information.

We may change this policy from time to time in our sole discretion. The most current version of this policy may be accessed through our website.

  1. Personal Information We Collect
  1. For prospective clients, we collect contact information (such as your phone number or e-mail address) if you have asked us to send you information or to contact you. We may also collect information related to your assets and financial position.
  2. For existing clients, we collect personal information that is essential to providing services to you, such as: your contact information; information related to your assets and financial position; information related to your investment preferences, requirements, objectives and risk tolerances; copies of government-issued identification; your social insurance number; your bank account details; and information related to the investments we manage for you.
  1. How We Collect Personal Information
  1. We collect personal information directly from you in meetings or through telephone conversations when you become a client or request that we contact you or send you information.
  2. We also collect personal information that you send to us by mail, e-mail, our secure file sharing portal, our website or other means.
  3. We strongly advise against sending personal or other sensitive information or transaction instructions by e-mail, as e-mail is not a secure means of communication. If you wish to provide us with such information, please call us or use our secure file sharing portal. We will never ask you to provide personal or sensitive information through an unsolicited e-mail. If you receive such an e-mail that appears to come from us requesting such information, or otherwise appears to be questionable or fraudulent, we strongly advise against responding or opening any links or attachments. Instead, please forward the e-mail to us at phishing@harrisdouglas.com and delete it.
  4. If specifically requested by you, we may also collect personal information from others, such as your accountants or tax advisors.
  1. Use of Personal Information
    We use personal information to:
  1. manage our relationship without, including communicating with you, understanding your needs and preferences, and sending you information you’ve requested, such as publications or event invitations;
  2. provide investment management services to you, including assessing the suitability of investments, managing investments, executing transactions, correcting or updating our records, sending and receiving funds and providing information related to your investments, such as statements, reports and tax documents;
  3. validate your identity and the authenticity of instructions we receive from you;
  4. safeguard you and us from, and detect, prevent or investigate actual or suspected fraud, crimes, errors or security incidents;
  5. enforce obligations or advance or defend claims;
  6. inform you of new products or services we may offer from time to time; and
  7. comply with legal, tax and regulatory requirements.
  1. Transferring Personal Information
  1. We may transfer personal information to third party service providers as reasonably required to provide you services or to fulfill your requests. Such third party service providers include:
    1. National Bank Financial Inc. (“National Bank”), which provides financial services such as trade execution, custodial services and reporting services. Such services are essential to our provision of investment management services to you. In order for National Bank to provide such services, you must open an account with National Bank and agree to their Accounts and Services Agreement and Disclosures (provided to you when you open an account with National Bank and their privacy policy, both of which govern personal information you provide to National Bank or which we collect from you and provide to National Bank to enable them to provide such services; and
    2. other suppliers and service providers which provide products and services that are essential to our provision of investment management services to you, such as secure portal services, customer relationship management systems, data storage services and accounting, auditing and legal services. The terms of our agreements with such suppliers and service providers limit their use and disclosure of personal information to what is necessary to provide such products and services.
  2. We may also transfer personal information:
    1. if you instruct us to do so and we are not prohibited or restricted by applicable law from doing so;
    2. in connection with corporate transactions, such as an asset or share sale or financing;
    3. to the extent we are obligated to do so under applicable law, regulation or are otherwise compelled to do so by legal authority, including self-regulatory organizations;
    4. if we reasonably believe there has been a violation of applicable law, your or our rights or the rights of others, to the extent reasonably required to address such violation;
    5. to the extent reasonably required to detect, prevent or investigate actual or suspected errors, fraud, crimes or security incidents; and
    6. if there is a danger or threat to persons or property which could be reduced or avoided by such disclosure.
  3. Personal information may be transmitted, stored or processed outside of Canada by us or our suppliers and service providers, and may therefore be subject to the jurisdiction of other countries.
  1. Consent
  1. For prospective clients, we obtain your consent to our collection, use and disclosure of your personal information verbally at the time of collection, followed by e-mail confirmation. For existing clients, we obtain your consent when you execute an agreement with us for the provision of our services (the “Client Agreement”).
  2. You may withdraw your consent to our collection, use and disclosure of personal information for marketing and promotional purposes by notifying us in writing of such withdrawal. If you are an existing client, you may otherwise only withdraw your consent in connection with the termination of our services in accordance with the Client Agreement, as we otherwise limit our collection, use and disclosure of personal information to that which is essential to the provision of such services to you.
  1. Retention of Personal Information
    We retain your personal information for so long as it is required for the purpose for which it was collected and for a further retention period in order to address any issues that may subsequently arise, as may be required by applicable law or our record retention policies. Thereafter, we will erase or destroy such information.
  1. Access, Updates and Corrections
    You may request access to personal information we have collected about you by contacting us. We will promptly provide such access, subject to any limitations or prohibitions of applicable law. If any such information requires correction, please let us know and we will promptly correct it. We use reasonable measures to keep such information accurate and up to date, but rely on you for most updates. If your contact information or other details have changed, please let us know.
  1. Safeguards
    We and our service providers use security practices and procedures that are consistent with industry standards with a view to safeguarding your personal information. We limit disclosure to employees and service providers who have a need to know in order to fulfill the purpose for which the personal information was collected.
  1. Contacting Us
    If you have questions regarding this policy or our collection, use or disclose of personal information, please email us at info@harrisdouglas.com.

    Last Revised: October 24, 2019.