STEADYHAND INVESTMENT FUNDS INC. AND STEADYHAND INVESTMENT MANAGEMENT LTD. PRIVACY POLICY
Last updated: September 16, 2021
Introduction
Protecting your privacy is very important to us. This Policy explains how Steadyhand Investment Funds Inc. and Steadyhand Investment Management Ltd. (collectively, “Steadyhand”) collects, uses, discloses and retains personal information, including personal information you may provide while using our services or our website at www.steadyhand.com (the “Website”). By providing Steadyhand with your personal information, you consent to the collection, use, disclosure and retention of your personal information in accordance with this Policy and as otherwise permitted by applicable law.
1. Personal Information
In this Privacy Policy, “personal information” means information about an identifiable individual, such as an individual’s name and email address, but does not include (to the extent permitted by law) information that is publicly available in a telephone directory or that is business contact information that enables an individual to be contacted at a place of business.
2. How Steadyhand Collects Personal Information
(a) Personal Information You Specifically Provide
You may be asked to voluntarily give your personal information to Steadyhand when you interact with Steadyhand, including when in the course of completing new Account Application forms and related documents, and during your use of our services or the Website.
For example, Steadyhand may collect:
In those circumstances, you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of the Website, or otherwise receive the full benefit of Steadyhand’s services.
If you give Steadyhand the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to Steadyhand and to Steadyhand’s use, disclosure and retention of the personal information.
(b) Automated Collection
Steadyhand may use technologies to automatically collect certain information regarding your use of the Website or online services, such as the dates and times that you access the Website or online service, the browsers, operating systems, software, devices and networks that you use to access the Website or online service and details of your use of the Website or online service.
Steadyhand’s Website, online services, email messages, and advertisements may also use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to automatically collect information that assists Steadyhand to improve its products, services, customer communications and advertising and to prevent fraud.
Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and Steadyhand will deal with that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.
(c) Information from Other Sources
In some cases, and only with your express consent, we might also collect your personal information from third party sources, such as your accountant, financial planner or lawyer.
2. How Steadyhand Uses Personal Information
(a) General
Steadyhand may use your personal information for various purposes in connection with its relationship and transactions with you and as otherwise set out in this Privacy Policy or permitted by applicable law, including: (i) to provide investment management services to you, including the administration, operation and maintenance of your accounts; (ii) to enter into and process transactions within your portfolio; (iii) to transfer your account to or from another institution; (iv) to comply with Steadyhand’s legal and regulatory obligations; (v) to contact and correspond with you and others that you may designate as your agents from time to time; (vi) to facilitate your interactions and transactions with Steadyhand; (vii) to provide products and services to you; (viii) to process and respond to your inquiries, requests and other communications; (ix) to provide you with information (including by email and other electronic messages) regarding Steadyhand and its products and services and the products and services offered by other businesses, to the extent permitted by applicable law; (x) to maintain, protect and improve Steadyhand’s services and website; (xi) to develop, deliver and improve Steadyhand’s advertising and marketing; (xii) in accordance with express consents that you give during your interactions and transactions with Steadyhand; and (xiii) to protect and enforce Steadyhand’s legal rights, interests and remedies and to protect the business, operations and customers of Steadyhand or other persons.
Steadyhand may combine your personal information collected by Steadyhand through various sources.
Steadyhand may use your personal information to create non-personal information, and Steadyhand may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.
(b) Information Collected by Technological Means
Steadyhand may use information collected by technological means to recognize you as a user of the Website, to facilitate and improve your use of the Website and online services, to confirm that messages have been delivered to and opened by you and to provide you with targeted advertisements. Steadyhand may use web beacons, pixels or gif tags and action tags to confirm that email messages have been delivered and opened. You may opt out of receiving emails in accordance with this Privacy Policy.
Information provided by cookies may be collected and processed by Steadyhand or by its third party service providers, including Google and Facebook.
You may choose to decline or disable cookies if your web browser or device permits, but doing so may affect your ability to access or use certain features of the Website. Information about how Google uses cookies and how you can limit or disable certain kinds of cookies on your personal computer or mobile device is available here: https://www.google.com/policies/privacy/partners/ and https://www.google.com/policies/technologies/ads/.
3. How Steadyhand Discloses Personal Information
(a) General
Steadyhand discloses your personal information for purposes relating to or arising from your relationship and transactions with Steadyhand and as otherwise set out in this Privacy Policy or permitted by applicable law. We do not sell your personal information to third parties.
(b) Specific Consents
Steadyhand may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Steadyhand.
(c) Suppliers and Service Providers
Steadyhand discloses your personal information to its suppliers and service providers to assist Steadyhand in the provision of products and services to you, to provide services to Steadyhand, to assist Steadyhand to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.
(d) Self-Regulatory Organizations
For regulatory purposes, self-regulatory organizations (“SROs”), including the Mutual Fund Dealers Association of Canada, may require access to personal information of current and former clients, directors, officers, employees, agents, partners and others that have been collected by Steadyhand. SROs collect, use or disclose such personal information for regulatory purposes, including surveillance of trading activity; sales, financial compliance, trade desk review and other regulatory audits; investigation of potential regulatory and statutory violations; regulatory databases; enforcement or disciplinary proceedings; reporting to securities regulators; and information-sharing with securities regulatory authorities, regulated marketplaces, other SROs and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
(e) Business Partners and Other Third Parties
In some circumstances, Steadyhand may share your personal information with its business partners, such as strategic business partners who provide products and services that enhance your experience with Steadyhand or that may be of interest to you, and other third parties. For example, Steadyhand may disclose your personal information to your accountant or an external accountant or financial planner on your request. Steadyhand will only disclose your personal information to a third party if Steadyhand has your consent to do so, if you have provided your consent to the third party, or if Steadyhand is legally required or permitted to do so.
(f) Law Enforcement/Legal Disclosures
Steadyhand may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant or court or arbitral order or litigation disclosure obligation. Steadyhand may disclose your personal information to law enforcement agencies or other independent organizations if Steadyhand reasonably believes the disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance, or if Steadyhand reasonably believes the disclosure is necessary or appropriate to protect and enforce Steadyhand’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Steadyhand or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of Steadyhand’s products and services). Steadyhand has no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom Steadyhand discloses the information in the foregoing circumstances, and the use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.
(g) Business Transactions
Steadyhand may disclose your personal information in connection with a proposed or actual business transaction in which Steadyhand is involved (e.g. a corporate amalgamation, reorganization, merger or acquisition, or the sale or transfer of some or all of Steadyhand’s business or assets), but Steadyhand will require the information recipient to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.
4. Your Right to Withdraw Consent
You may withdraw your consent to Steadyhand’s collection, use, disclosure and retention of your personal information as set out in this Privacy Policy at any time, subject to legal and regulatory or contractual restrictions and reasonable notice. To withdraw your consent, you may contact us at the contact information set out at the end of this Privacy Policy.
If you withdraw your consent to the collection, use, disclosure and retention of your personal information for purposes that are integral to the provision of Steadyhand’s products and services, then you might not be able to proceed with your intended interactions or transactions with Steadyhand or otherwise receive the full benefit of Steadyhand’s products and services.
If you withdraw your consent to the collection, use, disclosure and retention of your personal information for additional purposes that are not integral to the provision of Steadyhand’s products and services (e.g., to send advertising and marketing messages to you, to administer and facilitate your participation in contests and promotions, and to conduct surveys) then withdrawing your consent for those purposes will not affect the provision of Steadyhand’s products and services to you.
5. Advertising/Marketing Messages from Steadyhand
You may elect to receive advertising or marketing messages containing information about Steadyhand and related matters Steadyhand believes will interest you. At any time after electing to receive such messages, you may ask Steadyhand to stop sending them to you by sending your request to our Privacy Officer at one of the addresses noted below. Also, each advertising or marketing message Steadyhand sends to you will explain how you can withdraw your consent.
6. Audio and Video Recordings
Steadyhand may collect and retain audio recordings of phone calls made by you to Steadyhand or a Steadyhand representative to you. In some cases, to facilitate your interactions with Steadyhand, we may collect and retain video recordings of virtual meetings you have with a Steadyhand representative.
Steadyhand uses audio and video recordings to comply with our legal and regulatory obligations, to monitor quality control, to confirm investment decisions and other instructions you may give to Steadyhand and to protect and enforce Steadyhand’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Steadyhand or other persons (including to detect and prevent fraud and other illegal activities).
Steadyhand will never record a phone call or virtual meeting with you without your consent.
7. Location of Personal Information
Steadyhand will always store your financial information in Canada. Steadyhand and its service providers may process, store and use other personal information at facilities in Canada and the United States. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to Steadyhand, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
8. Retention of Personal Information
Steadyhand will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Steadyhand’s legal obligations or enforce or protect Steadyhand’s legal rights, or a longer period required or permitted by applicable law. Steadyhand will delete or dispose of your personal information, or depersonalize the information, when Steadyhand is no longer reasonably required to retain the information for the purposes set out or referenced in this Privacy Policy.
9. Protection of Personal Information
Steadyhand uses reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in Steadyhand’s possession or under Steadyhand’s control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and Steadyhand cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy. You will not permit any other person to access or use your online client portal, and you agree to safeguard your client portal credentials to prevent any unauthorized access or use.
10. Accuracy and Access to Personal Information
Steadyhand will rely on you to ensure that the personal information you provide to Steadyhand is as accurate, complete and up to date as necessary for the purposes for which Steadyhand uses the personal information. You will promptly notify Steadyhand of any changes to the personal information you provide to Steadyhand using the procedures made available for that purpose by Steadyhand or by contacting Steadyhand’s Privacy Officer using the contact information noted below.
You may request access to your personal information and information about Steadyhand’s collection, use and disclosure of that information by sending your request to our Privacy Officer at one of the addresses noted below. Subject to certain exceptions and limitations prescribed by law, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. Steadyhand may decline to process an access request that is unreasonably repetitive, frivolous, vexatious or impracticable, or if Steadyhand reasonably believes that the requested access would infringe or jeopardize the privacy of other persons, or violate any applicable law or legal requirement, or for other reasons permitted by applicable law.
11. Non-Personal Information
Steadyhand may use your personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Steadyhand may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with personal information, then Steadyhand will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with the personal information.
12. Other Websites and Businesses
The Website and correspondence (including emails and messages) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. Steadyhand has no responsibility or liability for, or control over, those other independent businesses, their websites, products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure and retention of your personal information by independent businesses or through independent websites or online services. If you have questions about how those independent businesses or their websites or online services collect, use, disclose or retain personal information, please contact the owner or operator of the independent businesses, websites and services.
13. Social Media
When you interact with Steadyhand’s social media pages (e.g. Steadyhand’s Facebook, Twitter or LinkedIn pages), the personal information that you post or share in connection with the social media sites is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages. Any information provide to a social media sites and other sites is governed by their own privacy policies. You are solely responsible for the personal information that you choose to post or share in those situations. Steadyhand has no control over, or responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations, and the use, disclosure, and retention of the disclosed information is not subject to this Privacy Policy.
14. Children and Personal Information
Steadyhand does not knowingly collect personal information from children under 13 years of age without the consent of a legal guardian. If Steadyhand learns that Steadyhand has collected or received personal information from a child where parental or guardian consent was required, Steadyhand will delete that information unless the parent or guardian provide the required consent. If you believe Steadyhand might have any information from or about a child where parental or guardian consent was required, please contact Steadyhand’s Privacy Officer using the contact information set out at the end of this Privacy Policy.
15. Other Matters
(a) Disclaimers, Liability Exclusions/Limitations and Disputes
The agreements (including any website terms of use) that you accept when you apply, register for, order or use Steadyhand’s products and services contain important provisions, including provisions disclaiming, limiting or excluding the liability of Steadyhand and other persons (including service providers) and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or Steadyhand’s collection, use, disclosure and retention of your personal information, and are of the same force and effect as if they were reproduced directly in this Privacy Policy. Nothing in this Privacy Policy amends any of those other agreements.
(b) Changes to this Privacy Policy
Steadyhand may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on the Website. Steadyhand’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with Steadyhand after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by Steadyhand as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version.
(c) Notices to You
You consent to Steadyhand sending you emails (to the email addresses you provide to Steadyhand) regarding this Privacy Policy and related matters and as otherwise permitted by applicable law.
16. Contacting Steadyhand
We welcome the opportunity to discuss our privacy practices further with you. Steadyhand’s Privacy Officer may be contacted by the following methods: (a) by telephone - 1.888.888.3147; (b) by email - privacyofficer@steadyhand.com; or (c) by postal mail to “Privacy Officer”, 1747 West 3rd Avenue, Vancouver, BC, V6J 1K7.