When you visit a Website, you can expect to be notified of:
What information this Website gathers/tracks about you. What this Website does with the information it gathers/tracks. With whom this Website shares the information it gathers/tracks.
Questions regarding this Statement should be directed to email@example.com for clarification.
INFORMATION COLLECTION AND USE
Transcend is the sole owner of the information collected on this Website. It will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.
In order to use certain restricted pages, a User must be a registered client or advisor of Transcend. Please contact your Transcend representative if you require access to the restricted Website pages.
When you login to the Transcend Website it will set a temporary cookie on your computer in order to facilitate and customize your use of Transcend.ca and its services. The cookie stores your encrypted User ID, Password and any information regarding your use of Transcend.
If you wish to learn more about cookies, check http://www.cookiecentral.com.
Transcend may use IP addresses to analyze trends, administer the Website, track Users movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that "serve up" Web pages, automatically identify your computer by its IP address, and when you request a page from Transcend, its servers log your IP address.
This Website may also contain links to other Websites. Please be aware that Transcend is not responsible for the privacy practices of other such Websites. Transcend encourages Users to be aware when they leave its Website and to read the Privacy Statements of each and every Website that collects personally identifiable information. This Privacy Statement applies solely to information collected by this Website.
From time-to-time this Website may request information from Users via surveys. Participation in these surveys is completely voluntary and the User therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and mailing address), and demographic information (such as postal code, age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Website.
Transcend takes every precaution to protect its Users' information. When Users submit sensitive information via the Website, your information is protected both online and off-line. While SSL encryption is used to protect sensitive information online, Transcend also does everything in its power to protect User information off-line. All of its Users' information, not just the sensitive information mentioned above, is restricted. Only employees who need the information to perform a specific job (for example, customer service representatives) are granted access to personally identifiable information. Employees are kept up-to-date on security and privacy practices and what they can do to ensure our Users' information remains private. Employees are also notified and/or reminded about the importance Transcend places on privacy frequently throughout the year. All other personally identifiable information is stored in its databases and Transcend takes commercially reasonable steps to ensure that the information is treated securely in its systems.
WEBSITE AND SERVICE UPDATES
We may send our Users Website and service announcement updates. Users are not able to un-subscribe from service announcements, which contain important information about Transcend. We may communicate with you to provide requested services and in regards to issues relating to your registration via email or telephone.
NOTIFICATION OF CHANGES
We are committed to respecting and protecting the privacy and confidentiality of our clients' personal information. We want you to know, in plain terms, why we ask for your personal information, how we use your personal information in establishing and maintaining your relationship with us, how we keep your personal information confidential, and how you can inquire about the personal information we hold about you.
Each and every one of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility which governs their actions, even if they leave or retire from Transcend. We keep our employees informed about our policies and procedures for protecting personal information and reinforce the importance of complying with them. All employees are required, as a condition of their employment, to conform to this Policy.
WHAT IS PERSONAL INFORMATION
The term "personal information" refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes information that you provide or that we collect from other sources with your permission, for example: your name and address, age and gender, personal financial records, identification numbers including your social insurance number, personal references, and employment records.
WHY WE ASK FOR YOUR PERSONAL INFORMATION
We want to work with you to help you achieve your financial goals, to provide you with value-added service on an ongoing basis, and to establish a lasting financial relationship with you that will grow and change as your financial needs evolve. The better we know you, the better we are able to serve you. We therefore ask you for your personal information for the following purposes:
to verify your identity and protect against fraud,
to understand your financial service requirements,
to determine the suitability of products and services for you,
to offer you products and services that may be of interest to you,
to set up and manage products and services you have requested, and
to comply with laws and securities regulations.
For example, in the case of our managed account program, we ask for detailed personal information to ensure that the advice we give is appropriate for you and suitable for your circumstances. Some of the information we will ask for and use, either at the time of account opening or on an updated basis is also required to satisfy the legal or regulatory requirements of federal and provincial governments and/or other regulatory authorities.
In general, you can choose not to provide us with some or all of your personal information. However, please understand that if you make this choice, we may not be able to provide you with the product, service, or information that you requested or that was offered to you, or is typically offered to clients.
OBTAINING, VERIFYING AND ACCESSING YOUR PERSONAL INFORMATION
We obtain personal information about you primarily from you. We may also obtain financially-related information from other sources with your consent.
If you want to review or verify your personal information, or find out to whom we have disclosed it as permitted by this Policy, you can ask at our Head Office. At that time, we will need specific information from you to enable us to search for, and provide you with, the personal information we hold about you.
If we are unable to provide you with access to your personal information, we will always explain the reason why.
KEEPING YOUR INFORMATION ACCURATE
We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes set out in this Policy, and provided that you keep us up-to-date. Prompt notification of any changes, such as your mailing address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your personal information, that amendments are required, please advise us. We will make our best efforts to advise others of any important amendments to your personal information that we may have released to them.
If we do not agree to make the amendments that you require, you may challenge our decision. We will make a record of this challenge and, if necessary, disclose the challenge to third parties who also possess that personal information.
RELEASING YOUR PERSONAL INFORMATION
Transcend does not sell your personal information to third parties. Transcend does not disclose your personal information to third parties other than in the following circumstances or for the following purposes:
in connection with normal business operations to open, maintain, administer, or service your account, including, without limitation the mailing of materials and the scanning of account documentation into customer databases, the provision of customer service (including services rendered by third party agents or affiliates), the provision of back office administrative services (including clearance and settlement services, the mailing of transaction confirmations, account statements and reviews, and record-keeping services), for audit or statistical purposes;
to ensure that any updated contact information you provide is processed efficiently, and to engage in surveillance, compliance, and reporting activities required by applicable law;
to legal counsel for the purpose of obtaining legal advice; where we are required or permitted to do so by law, including to any law enforcement agency, securities regulatory authority or self-regulatory organization;
in connection with offers made to Transcend customers or prospective customers, or other promotional activities or service offerings engaged in by Transcend where (a) third party product or service providers assist Transcend or otherwise participate in fulfillment of the offer or provision of the service; (b) Transcend has contracted with a third party for the fulfillment of the offer or provision of the service or otherwise has an ongoing business relationship with such third party; (c) fulfillment of the offer or provision of the service requires disclosure of certain limited personal information for fulfillment purposes only to such third party; (d) the disclosed personal information is to be used for fulfillment purposes only and the third party agrees not to disclose the personal information to others, or (e) in an aggregated form for the purpose of analyzing statistics and metrics about our business and operations.
By opening or maintaining an account with Transcend or using our services, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described above.
KEEPING YOUR PERSONAL INFORMATION CONFIDENTIAL
Personal information is protected at Transcend by safeguards that are reasonable to the sensitivity against loss or theft and against unauthorized access, disclosure, copying, use or modification. Safeguards include physical protection (such as locked cabinets and restricted access to offices), organizational measures (such as security clearances) and technological measures (such as passwords and encryption).
In circumstances where we use third parties to provide services to you on our behalf, such as administrative functions or trade processing, they are given only the information needed to perform those services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed and require that any information provided by us must be kept strictly confidential and used only for the purposes of the contract. We have strict procedures in place when destroying, deleting, or disposing of personal information when it is no longer required for the purposes set out in this Privacy, or by law.
RETENTION OF YOUR PERSONAL INFORMATION
We only keep your personal information for as long as we need it to meet the purposes set out in this Policy. The length of time we retain your personal information depends on:
the type of product or service you have with us, and
any legal or regulatory requirements we may have to meet.
For example, we must be able to respond to any concerns you may have, even if you are no longer a client of ours. We have retention policies in place that govern the destruction of personal information.
You can choose not to provide us with some or all of your personal information. You can also withdraw your consent to our use of your personal information, as long as:
you give us at least sixty (60) days written notice;
there are no legal requirements for the use of your personal information; and
we can continue to fulfill our contractual obligations to you.
Transcend has designated its Chief Compliance Officer as the individual who is accountable for its compliance with this Policy and any questions, requests or complaints should be direct to the Chief Compliance Officer at the address or phone number below.
Transcend Private Client Corp.
18 King Street East, Suite 303
Toronto, Ontario M5C 1C4
Toll free: 1 (800) 988-5608