Your Privacy is Important to Us
WHAT IS PERSONAL INFORMATION?
Personal information is any piece of information, either factual or subjective, about an identifiable individual. Personal information does not include the name, title, business address, or telephone number of an employee of an organization.
THE 10 PRINCIPLES OF PRIVACY
Chief Privacy Officer
The Sygnet Group Inc.
130 Adelaide Street West
Toronto, Ontario M5H 3P5
Sygnet is responsible for any personal information under its control, including personal information that Sygnet may transfer to a third party for processing. Sygnet will use contractual or other means to provide a comparable level of privacy protection when personal information is being processed by a third party on Sygnet’s behalf.
2. Identifying Purposes: Why Information is Collected
Whenever Sygnet collects information about an individual, it will explain how it intends to use it, either at that time or earlier. Sygnet will limit the information it collects to what it needs for those purposes, and will use it only for those purposes. Sygnet will obtain an individual’s consent if it wishes to use that individual’s information for any other purpose.
Sygnet asks an individual for information to establish a relationship and serve the individual. Sygnet obtains most of its information about an individual directly.
Sygnet collects, uses, and discloses personal information for the following purposes:
establishing and maintaining communications with the individual;
dissemination of promotional material;
providing and servicing financial and insurance products and services that it believes are right for the individual, over his/her lifetime;
assisting in the individual’s financial planning and estate matters;
understanding the individual’s needs, determining his/her eligibility, continuing to offer the individual the full range of products and services that Sygnet believes meets his/her changing needs and to service such products and services;
meeting regulatory or contractual requirements relating to the products and services provided to the individual.
Some or all of the personal information that Sygnet collects uses, and discloses may be stored and processed on computers located in Canada, and/or other countries in which Sygnet, or any of its affiliates does business or maintains facilities.
If Sygnet plans to use or disclose personal information which it has collected for a purpose not previously identified, Sygnet will identify and document this purpose. Sygnet will make a reasonable effort to specify such new purpose, either orally, in writing, by e-mail, or by electronic means, to the individual from whom the personal information was collected before such new use or disclosure. Sygnet will state the new purpose in such a manner that an individual can reasonably understand how personal information will be used or disclosed.
Sygnet seeks and confirms the consent of any individual to use his or her personal information at the time of collection or in advance. Sygnet will endeavour to employ clear, understandable language when it obtains your consent.
Consent may be expressed in writing or implied, and in some cases, an individual may provide it verbally, electronically or through his or her authorized representative, such as a lawyer. Written consent includes completing and signing a form of consent. Implied consent may be found where an individual chooses to accept services from Sygnet after being made aware of its intentions to collect, use or disclose the individual’s personal information.
The way in which Sygnet will seek consent, including whether express or implied consent is sought, may vary depending on the sensitivity of the personal information and the reasonable expectation of the individual supplying it. Typically, Sygnet will seek consent for the collection, use, and disclosure of personal information at the time it is collected. In certain circumstances, Sygnet may seek consent after the personal information has been collected but before it uses or discloses same (such as when it wishes to use personal information for a purpose not previously identified by it).
The choice to provide Sygnet with personal information is always up to the individual. Upon request, Sygnet will explain an individual’s options of refusing or withdrawing consent to the collection, use, and release of his or her information, and Sygnet will record and respect the individual’s written choices. However, an individual’s decision to withhold particular details may limit Sygnet’s ability to offer its services. This measure is necessary to protect the integrity of the services offered by Sygnet. As an example, Sygnet Capital Inc. is prohibited from opening accounts for clients who do not consent to the disclosure and use of personal information to/by securities regulators. Furthermore, any refusing or withdrawing of consent is always subject to any overriding legal requirements or commitments.
4. Limiting Collection
Information is not collected by Sygnet without a specific, limited requirement. Sygnet collects information by fair and lawful means.
5. Limiting Use, Disclosure, and Retention
The information Sygnet requests from an individual is used for the purposes defined. Sygnet will seek an individual’s consent before using the information for purposes beyond the scope of his or her original consent.
Sygnet will retain an individual’s information only for the time it is required for the purposes it describes. Once the personal information is no longer required, it will be destroyed, erased or made anonymous.
All decisions involving personal information should be based on accurate and timely information. Sygnet will rely on individuals to disclose all material information and to inform it of any relevant changes.
Sygnet will use its best efforts to ensure that personal information under its control is accurate, complete, and up-to-date as is necessary for the purposes for which it is used. The extent to which Sygnet will ensure that such personal information will be accurate, complete and up-to-date will be dependant upon the use such personal information will be put to, taking into account the interests of the individual.
7. Safeguards: Protecting Individual Information
Sygnet will protect an individual’s information with appropriate safeguard and security measures against loss or theft, as well as against unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the personal information is held.
Sygnet maintains personal information in a combination of paper and electronic files. Records concerning individuals' personal information may be stored in files kept on site at head office or at an offsite, storage facility.
Access to personal information will be authorized only for Sygnet Personnel who require access in the performance of their duties and to any person granted access by the individual through the consent process, and to those otherwise authorized by law.
For regulatory purposes, securities regulators require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Sygnet Capital Inc. The securities regulators collect, use or disclose such personal information for regulatory purposes, including:
Surveillance of trading-related activity,
Sales, financial compliance, trade desk review and other regulatory audits,
Investigation of potential regulatory and statutory violations,
Enforcement or disciplinary proceedings,
Information-sharing with regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
8. Openness: Keeping the Individual Informed
If an individual has any additional questions or concerns about privacy, Sygnet invites the individual to contact the Chief Privacy Officer by phone, fax, mail, or e-mail, and Sygnet will address the individual’s concerns to the best of its ability.
9. Providing Individual Access
Sygnet will give an individual access to the information it retains about that individual within a reasonable time, with a written request, satisfactory identification and proof of entitlement. Sygnet will assist any individual which needs assistance in completing such request subject to the individual providing sufficient information to permit Sygnet to provide an account of the existence, use, and disclosure of personal information under its control. An individual also has the right to know:
● how Sygnet collected the personal information;
● how Sygnet is using it; and
● to whom it may have been disclosed, except where such disclosure was to a governmental body.
While Sygnet’s response will typically be provided at no cost to the individual, Sygnet reserves the right, depending on the nature of the request and the personal information involved, to charge the individual for its costs to process each such request. If it does so, such costs must be paid to Sygnet by the individual in advance of it beginning to process such request.
If an individual finds any errors in this information, he or she should contact the Chief Privacy Officer as soon as possible (by phone, fax, mail or e-mail), and Sygnet will make the appropriate corrections immediately, based on the receipt of satisfactory evidence.
In some cases, Sygnet may not provide access to personal information within its possession or control. These exceptions will be limited to those permitted or required by law. This may occur when:
● providing access would be likely to reveal personal information about a third party or could pose a threat to the security of the third party, and the information cannot be segregated;
● disclosure would reveal confidential commercial information of Sygnet;
● it would be too costly, in Sygnet’s determination, to retrieve it;
● the personal information is protected by solicitor-client privilege; or
● the information has been collected during the investigation of a legal matter or cannot be disclosed for other legal reasons, such as a non-disclosure agreement.
If Sygnet denies an individual request for access to his or her personal information, Sygnet will advise in writing of the reason for the refusal and the individual may then challenge Sygnet’s decision.
10. Providing Recourse: Respecting and Responding to Individual Privacy Concerns
An individual may send a challenge concerning Sygnet’s compliance with any of the privacy principles to our Chief Privacy Officer. The Chief Privacy Officer may be contacted by e-mail at email@example.com, by telephone at (416) 644-2780, by facsimile transmission at (416) 644-2781, or by registered mail addressed to Sygnet at:
Chief Privacy Officer
The Sygnet Group Inc.
130 Adelaide Street West
Toronto, Ontario M5H 3P5
Sygnet will review, consider, and investigate all written privacy complaints which it receives. The challenge should include the individual’s name, company name, company address, and/or email address if the individual contacts Sygnet by e-mail, by facsimile transmission, or by registered mail. If Sygnet finds the complaint to be justified, Sygnet will take such action as is appropriate to comply with the Privacy Principles.
If the issue is still not resolved satisfactorily, Sygnet will provide information on other complaint procedures that may be available to the individual.
Version Date: September 2019
 The Sygnet Group Inc. includes its affiliates, Sygnet Capital Inc. and Sygnet Advisory Inc.