- Queensbury and Your Privacy
- Queensbury’s Principles on Privacy
- Why Does Queensbury Collect Personal Information?
- How Does Queensbury Collect Personal Information?
- When Does Queensbury Release Personal Information?
- Does Queensbury Provide Options?
- How Long Does Queensbury Retain Personal Information?
- How Does Queensbury Protect Personal Information?
- What about the Internet?
- How Do I Access My Personal Information
- How Do I Keep My Personal Information Accurate?
- Who Should I Contact Regarding Privacy Issues?
Queensbury considers your personal privacy to be an important part of our service to you. We understand the need to safeguard information about you that you have entrusted to us. As part of our commitment to you we have adopted principles designed to protect your privacy and prevent misuse of your personal information and help you understand our commitment to your personal privacy.
References to “Queensbury”, “we” or “our” are to Queensbury Securities Inc., Queensbury Strategies Inc., Queensbury Insurance Brokers Inc. and their subsidiaries and affiliates, depending upon the context. Where we use the term “personal information” we are referring to any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and web site use information, together with your personal references and identification numbers (such as a social insurance number).
- Collecting and Using Personal Information – We will explain how we intend to use your personal information prior to or when we are collecting it and we will limit the personal information we collect to what we need for those purposes. We will use it only for those purposes we have explained to you and we will obtain your consent if we wish to use your personal information for any other purpose.
- Disclosing Personal Information to Others – We may provide your personal information to other persons not affiliated with Queensbury, such as regulators, service providers or credit reporting agencies, but only where we have your consent or where we are required or permitted to do so by law.
- Retaining and Protecting Personal Information – We will retain your personal information only for the time it is required for the purposes we explain or as otherwise required by law. We will protect the personal information we obtain about you with appropriate safeguards and security measures.
- Access and Accuracy – We will provide you with reasonable access to your personal information on record with Queensbury and information about Queensbury’s use and disclosure of that information. We will make every reasonable effort to keep your personal information accurate and up-to-date.
We collect, retain, and use personal information about you only when we reasonably believe that it will help administer our business or provide products, services and other opportunities to you as our client. We collect and retain personal information about you only for specific business purposes – and we will tell you why we are collecting and retaining it on your request. The information we ask for depends on the products or services you request and in most cases are required by law or the policies of the regulatory bodies which we are subject.
Your social insurance number is required for products that earn investment income, in order to comply with the Canada Customs and Revenue Agency’s income reporting requirements. If you provide your social insurance number, we also use it to keep your personal information separate from that of other clients with a similar name. Health information may be required for some insurance products to ensure you are eligible for coverage. Health information that may have been provided in connection with any insurance product is never shared.
With your consent, we may share your personal information, where not prohibited by law, to affiliated companies of Queensbury for the purposes of referring investment, life insurance, disability insurance, annuities and other specific insurance products and services to you. Queensbury may use your personal information to provide you with information about Queensbury’s products and services and other matters. This consent is optional and you can decide to withdraw it at any time. Please refer to our section regarding your options below.
We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties.
Queensbury does not sell client lists or personal information to others.
We do not reveal personal information about you to parties outside our affiliated companies for their independent use unless you request or authorise it or the information is provided in order to complete a transaction initiated by you or the disclosure otherwise is lawfully permitted or required. We may disclose information to the authorities to serve a clear public interest and fulfil our public duty – such as to protect against fraud, money laundering or other criminal activity. We may, from time to time, be requested to disclose information to securities regulatory and securities oversight organisations to which we are subject for the purposes of an audit or investigation relating to specific accounts or our business generally. In certain circumstances, Queensbury may disclose your personally identifiable information if it believes, in good faith, that disclosure is otherwise necessary or advisable to protect its interests.
Sometimes it is necessary to provide personal information about you to a party outside our affiliated companies, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. These vendors and service companies agree to safeguard confidential information about you and your products and services with us and must abide by applicable law.
It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from third parties. In many cases you are free to refuse or withdraw your consent at any time. If you choose not to provide requested personal information or consents, we may not be able to provide certain products and services to you or you may be ineligible for or be unable to use certain products and services we provide.
Queensbury will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record and respect your choices. If you wish to discuss your options you may do so by contacting Queensbury’s designated privacy officer set out below, or contacting our Compliance Department. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.
Queensbury stores and processes your personal information in Toronto, Ontario, Canada. Certain personal information about you is retained by the Queensbury office that handles your account.
We maintain security standards and procedures to help prevent unauthorised access to confidential information about you. Our security standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity of our personal information.
We have procedures that limit employee access to personally identifiable information to those employees with a business need to know such information about you. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.
All our suppliers and agents, as part of their contracts with Queensbury, are bound to maintain your confidentiality and may not use the information for any unauthorised purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required – otherwise we will seek your consent prior to disclosing any information.
You may be asked to provide certain personal information as part of an application for use of our Web site service. If, as part of such application, Queensbury requests that you transmit confidential information to us over the Internet, we ensure that such transmission is encrypted. We use your logon id to identify you as a user of the service. We use the transaction information in the aggregate to assess and improve the service. You can contribute to the confidentiality of your personally identifiable information when using the Queensbury web site by not disclosing your designated username and password to anyone.
When you send us an e-mail or when you ask us to respond to you by e-mail, we learn your exact e-mail address and any information you have included in the e-mail. We use your e-mail address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We will not sell your e-mail address to anyone outside of Queensbury. We may use your e-mail address to send you information about our products or services that we believe may be of interest to you. If you don’t want us to contact you with product information by e-mail, you may tell us so at any time. Remember e-mail over the Internet is generally unencrypted. We recommend that you do not send us sensitive or confidential information by ordinary e-mail, as unencrypted e-mail is generally not secure.
Our Web site may contain links to other Web sites. When you click on one of those links, you are contacting another Web site for which Queensbury has no responsibility and over which Queensbury has no control.
You may request access to your personal information on record with Queensbury and information about Queensbury’s use and disclosure of that information by contacting your investment advisor or by contacting the office manager of the Queensbury office that handles your account. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request promptly but in any case within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to Queensbury, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.
Queensbury attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.
Queensbury has designated a privacy officer, John Webster, to respond to your concerns or questions about privacy and confidentiality – or any concerns about the way a request for personal information was handled. To reach our privacy officer, please refer to the following: in writing, at 69 Yonge Street, 2nd Floor, Toronto, Ontario, M5E 1K3; by telephone, at 416-866-8600; by facsimile, at 416-866-8123; or by e-mail, at firstname.lastname@example.org. Your concerns will be passed on to the appropriate Compliance personnel at Queensbury so that further action is taken to resolve the matter, if necessary.
If your concerns remain unresolved, you can contact Queensbury’s Chairman & C.E.O. directly in writing, at 69 Yonge Street, 2nd Floor, Toronto, Ontario, M5E 1K3, or by telephone at 416-866-8600.