Dynamic Funds, a division of Scotia Global Asset Management1 ("we" or "us") are committed to providing investors with the highest standard of service. As part of our commitment, we strive to protect your privacy and the confidentiality of personal information that you provide to us. Our information handling practices comply with applicable privacy laws.
The following is a description of our privacy policy regarding the collection, use and disclosure of personal information that you provide to us or that is shared with us from other sources. For your convenience, our Privacy Policy is set out in a question and answer format:
- Our privacy framework
- What is Personal Information
- How Do We Obtain Your Personal Information?
- Why we collect and use personal information
- Why we share your personal information
- How we protect and retain personal information
- How we maintain accurate personal information
- How to refuse or withdraw your consent
- How to access or update your personal information
- How we notify you of changes to this Privacy Agreement
- Policies & Procedures Regarding Personal Information
- How to contact us
1. Our privacy framework
We follow the established privacy framework of Scotiabank that sets out the structure and accountability for the secure and respectful treatment of personal information. Our privacy framework is overseen by a dedicated Privacy Office, led by our Global Privacy Officer. You can contact our Global Privacy Officer using the contact information at the end of this Privacy Agreement.
2. What is Personal Information
Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and home telephone number.
3. How Do We Obtain Your Personal Information?
Personal information is received by us from you or from your representative with your consent. Other sources from which we may receive your information with your consent include, but are not limited to, our affiliates and other financial institutions, etc.
4. Why we collect and use personal information
We collect and use personal information to establish to establish a relationship with you and provide you with the best possible service. Your signature, financial history, current financial position, social insurance number, age and other similar personal information allow us to:
establish your identity;
assess your eligibility for our investment products and services;
continue to offer you the full range of products and services that we believe meet your changing needs; and
protect you and us from error and fraud; and
communicate with you by phone, fax, mail, email, SMS text message or other electronic means to provide you with information related to the products and services you hold with us, or to collect on a debt owed to us. You can also choose to sign-up to receive alerts (including push notifications) regarding your account, in addition to electronic alerts we may send you to comply with regulatory requirements.
In addition, we require your personal information in order to allow us to meet regulatory or contractual requirements relating to the products and services provided to you.
We may use your personal information for the following purposes:
To identify you;
To ensure our records are accurate;
To establish and administer your account;
To execute your transactions;
To maintain, store, record and determine your account holdings and transaction records;
To verify previously given information when necessary;
To provide you and your representatives with account statements/information;
To provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
To provide you with quality customer service and support on your investment needs;
To develop and offer additional products and services that we feel may be of interest to you;
To protect the interests of Dynamic Funds, such as relates to the collection of debt owed;
To perform data analytics;
To prevent and detect fraud and criminal activity and
To meet legal and regulatory requirements.
5. Why we share your personal information
We are not in the business of selling or distributing our client's personal information to others. Client confidentiality and privacy remains one of our fundamental principles. However, we may share your information with others outside Dynamic Funds in limited circumstances including:
Third Party Service Providers. We hire third party service providers to perform services on your behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, the preparation and mailing of client statements, document storage, and imaging. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These third party suppliers are not permitted to disclose this information to others.
Your financial advisor. We share your information with your financial advisor and the dealer with which she or he is registered. We may also have to contact other financial institutions or mutual fund companies in order to gather complete information necessary to properly service your account with us.
As Permitted or Required by Law. Dynamic Funds is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry. We may also disclose information to our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.
Business Re-Organization. As we continue to grow, we may in the future re-organize or streamline parts of our operations. Since our business is based on our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, transfer or financing of parts of our business. These third parties are not permitted to disclose this information to others.
Sharing information with members of the Scotiabank Group of companies: We may share personal information with members of the Scotiabank group of companies who provide operational, administrative and support services on our behalf, to meet legal and regulatory obligations, for fraud prevention purposes, and to perform analytics.
Members of the Scotiabank group of companies may be located outside of your province of residence or outside of Canada and may access and process your personal information from the United States or other jurisdictions. For a list of Scotiabank’s principal affiliates and subsidiaries enterprise-wide, please refer to Scotiabank’s most recent annual report.
6. How we protect and retain personal information
Policies, procedures, guidelines, and safeguards have been put in place to ensure your personal information is protected. Our employees and service providers have access to your personal information to enable them to perform their duties in servicing you. Personal information collected from you will only be used for the identified purposes and will be retained for as long as is necessary to fulfill the service or as required by law.
Your personal information may be kept in electronic, microfilm or paper format at the offices of Dynamic Funds, its affiliates or its third-party service providers. Your information may also be kept in secure off-site storage facilities.
7. How we maintain accurate personal information
We require accurate, complete and up-to-date records to provide our products and services, and we have implemented processes to help ensure this.
We also rely on you to provide us with information that is true and complete. If any personal information changes or becomes inaccurate or out of date, please advise us using the contact information set out below so we can update our records.
8. How to refuse or withdraw your consent
You may withdraw your consent for the use of your personal information by contacting Dynamic Funds at any time subject to reasonable notice. Legal and other requirements may prevent you from withdrawing consent and your decision to withdraw personal information may also limit the services or products we are able to provide to you.
If you wish to withdraw consent, you may do so at any time by calling us toll-free at the telephone numbers listed below. You can also contact the Customer Relations Center, as set below.
Toll Free 1-800-268-8186
Telephone 514-908-3212 (English) or 514-908-3217 (French)
Fax 514-940-3511 or 1-800-419-5119
For email inquiries, please contact invest@dynamic.ca
9. How to access or update your personal information
Upon request, we will provide you with access to your personal information. In addition, we may provide you with a list of third parties to whom your personal information was provided. If you wish to change or update your personal information, you may request to do so at any time. Please note that we may only alter that personal information required to fulfill the stated purposes. In certain circumstances, we may not be able to provide you with access to specific pieces of information. For example, (i) information containing references to other persons; (ii) information containing proprietary information confidential to Dynamic Funds or its affiliates; (iii) information that has been destroyed or may be too costly to retrieve.
10. How we notify you of changes to this Privacy Agreement
We may amend this Agreement from time to time to reflect changes in our personal information practices. We will post the revised Agreement on our website. We encourage you to visit this area frequently to stay informed. If you access our web site after we have posted changes to this Privacy Agreement, you are agreeing to accept the changes.
11. Policies & Procedures Regarding Personal Information
We have established and implemented governance policies and procedures of Scotiabank approved by the Global Privacy Officer and owned by the Enterprise Privacy Office regarding personal information to ensure its protection. These documents provide a framework for the retention and destruction of the information, define the roles and responsibilities of personnel, and provide a process for responding to inquiries regarding the protection of the information. A list of the policies and procedures is below:
Privacy Risk Management Framework - Provides an overview of the key governance components for the oversight and management of Privacy Risk. Serves as an overarching framework for material elements of Privacy Risk management activities and is a source document to which all other Privacy Risk policies and procedures are aligned.
Privacy Risk Management Policy - Provides a description of the general policies and principles applicable to Privacy Risk Management. It is part of the effective management and mitigation of Privacy Risk.
Roles and Responsibilities Matrix of the Privacy Risk Management Program - This tool identifies roles and responsibilities associated with tasks.
Access to Personal Information Procedures - Sets out the framework for handling access requests and requests to amend personal information pursuant to applicable laws. The Procedures are part of the Privacy Risk Management Program.
Privacy Case Management Tool Governance Procedures - A privacy case management tool is a system used to track privacy-related incidents in a centralized location and to report that data to the relevant personnel. The governance procedures outline the structure and process for decision-making, accountability, and control relating to the relevant privacy-related incidents tracked by the tool.
Guidelines for Use of PII in Digital Initiatives - Provides an overview of the privacy implications that must be considered when devising a digital initiative involving personal information. These Guidelines assist employees to distinguish between permissible and impermissible uses of personal information.
Incident & Breach Management Procedures – Provides steps for handling Privacy Concerns that impact the Bank and its customers, employees or other individuals.
Privacy Impact Assessment Procedures - Outlines the processes involved to complete a Privacy Impact Assessment. These Procedures are part of the Bank’s Privacy Risk Management Program.
Employee Privacy Policy - Sets out how the Bank collects, uses, discloses and otherwise manages personal information of its employees while administering and managing the employment relationship.
Enterprise Records Management Policy — Establishes foundational principles applied across the Bank to facilitate the creation, retrieval, use, maintenance, retention, and disposition of records in a manner consistent with the Bank’s business priorities and applicable legal and regulatory requirements.
12. How to contact us
Telephone: 1-877-700-0043
Email: escalatedconcerns@scotiabank.com
Letter: Privacy Office c/o the Escalated
Customer Concerns Office, Scotiabank
44 King Street West
Toronto ON M5H 1H1
If you are not satisfied, you may file a complaint with the Office of the Privacy Commissioner of Canada:
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591
www.priv.gc.ca
1. Scotia Global Asset Management is the business name of 1832 Asset Management L.P. 1832 Asset Management L.P. is a subsidiary of The Bank of Nova Scotia (Scotiabank)