At CU Financial Management, we know that our clients are concerned about their personal information. We are committed to protecting the confidentiality and security of the information entrusted to us. We have implemented the policies and practices that meet the standards set out in the Personal Information Protection and Electronic Documents Act (Canada) and other applicable laws. CU Financial Management has a designated Privacy Officer who is responsible for maintaining and implementing our Privacy Policy.
You are entitled to review the Code, access your personal information, or contact the Privacy Officer at any time. We have established procedures to protect personal information, respond to complaints and inquiries, and provide employee training.
Interpretation and Application
In this Privacy Policy:
- “CU Financial Management,” “CUFM,” “we,” or “us” refers to CU Financial Management and any other entities that may become part of CUFM from time to time;
- “Aviso” refers to Aviso Wealth Inc. and each of their subsidiaries, including Credential Qtrade Securities Inc., Credential Asset Management Inc., Northwest & Ethical Investments L.P., Credential Insurance Services Inc., Credential Financial Strategies Inc. and any other entities that may become part of Aviso from time to time;
- “personal information” includes any factual or subjective information about an identifiable individual; and
- “Referring Organization” means the Credit Union, Caisse Populaire, portfolio manager or other financial organization that you have a relationship with or that referred you to us and that we may work in partnership with to provide products and services.
CU Financial Management Code for the Protection of Personal Information
The following are the ten principles outlined in the Code concerning the collection, use and disclosure of personal information:
Accountability
We are responsible for protecting personal information in our control or is transferred to third parties for processing on our behalf. Our Privacy Officer is accountable for ensuring our compliance with the principles described in this Privacy Policy.
Identifying Purposes
The purposes for which personal information is being collected will be identified and explained before or at the time of collection.
Consent
We will obtain informed consent prior to collecting, using, and disclosing personal information, except as otherwise permitted or required by law.
Limited Collection
Personal information will be collected by fair and lawful means, and we will only collect the information needed for the specific purposes identified to our clients.
Limiting Use, Disclosure and Retention
We will use and disclose personal information only for the purposes we have identified to our clients, except as otherwise permitted or required by law. We retain personal information only for as long as reasonably required to serve those purposes.
Accuracy
We keep personal information as accurate, complete, and up-to-date as possible to properly satisfy the purposes for which it is to be used.
Safeguards
We safeguard personal information with appropriate protective and security measures relative to the sensitivity of the information.
Openness
After receiving a request, we will provide easily understandable, specific information on our personal information management policies and procedures within a reasonable time.
Access
Our clients have the right to review the personal information we have about them, except where we are required or permitted by law to deny access. We encourage our clients to verify the accuracy and completeness of the information and inform us of any necessary corrections.
Challenging Our Compliance
If an individual has any concerns about our collection, use or disclosure of their personal information, they may request that our Privacy Officer investigate the matter and respond within a reasonable time.
Collecting Your Personal Information
CU Financial Management is required to obtain certain information about you in the course of providing products and services to you. We will only collect your personal information fairly and lawfully. We receive most of the information directly from you through your interactions with us (whether in writing, verbally, electronically or otherwise). We may also collect information from other sources, including from your Referring Organization, other financial institutions, credit reporting agencies and other third parties, in each case as approved by you or permitted by law.
The decision to provide us with your personal information rests with you. However, we may be limited in our ability to provide certain products and services to you if you decline to provide us with any information essential to do so.
What We Collect and How We Use It
The information we collect will depend on the products and services that you ask us to provide. The types of information that we generally collect and a description of how we use such information are as follows
Name and Contact Information
This information allows us to identify you and send you statements and other important or required notices. It also allows us to communicate with you to obtain instructions and respond to your requests and inquiries.
Date of Birth
This information allows us to fulfill our legal obligation to ascertain your identity and also helps protect against error, identity theft and fraud. We may also use this information to determine your interest in other products and services that we offer.
Social Insurance Number
We obtain your social insurance number (SIN) for tax reporting purposes. We may also use your SIN for credit reporting or monitoring purposes and to distinguish you from other persons or clients.
Employment and Financial Information
We collect this information to better understand your unique financial situation and investment needs and to help us provide appropriate investment advice. We may also use this information to determine your interest in other products and services that we offer.
Health Information
This information is required for certain types of insurance products.
Other information
We may collect other information about you as required in connection with the products and services requested, such as citizenship or residency information, marital status and spousal information, which we use to comply with our legal and regulatory obligations.
We use your personal information to establish and operate your accounts with us, to determine your eligibility for, inform you about and provide you with products and services, and to fully understand and meet your needs. We may also use your personal information as necessary or appropriate for the following purposes
Conducting or responding to audits
In relation to our or your Referring Organization’s audit purposes, intended to assist in protecting you from illegal or fraudulent activity.
Investigating issues and settling claims
In connection with the investigation and resolution of issues, including disclosing your information to insurance providers, regulators, law enforcement, lawyers or other third parties involved.
Complying with legal and regulatory obligations
To comply with any applicable laws, including but not limited to the rules of securities regulators, anti-money laundering regulations, tax legislation and trustee requirements, and to cooperate with appropriate authorities.
Understanding client needs and business requirements
To help us better understand client habits and preferences, monitor customer needs and demands, review and improve products and services, and forecast future business requirements.
Sharing Your Personal Information
We use your personal information exclusively for the purposes described in this Privacy Policy and for no other reason unless expressly agreed to by you or required by law. We do not rent or sell your personal information to any third parties.
To provide you with products and services and operate your account, we may share our personal information with certain other parties.
Across Aviso and their Employees
Aviso has centralized operations for some administrative, operational, marketing and other functions. Accordingly, we may share information between the companies that are part of the Aviso organization from time to time. In performing their duties, their authorized employees or representatives may have access to personal information. They may only access the information strictly necessary to perform their duties.
Your Referring Organization and other Financial Organizations
We work in close partnership with your Referring Organization and other financial organizations, which are separate legal entities, to provide you with a range of products and services. Allowing us to share your personal information with these entities helps us fulfill our commitment to provide you with the best possible service and ensures you benefit from our full range of available products and services.
Service Providers
We may disclose information to third party service providers retained by us to perform specialized services from time to time. In these cases, we only disclose the specific information required to perform the services. Our service providers must undertake to use client information solely to carry out the services they have been retained to provide and must agree to implement and maintain appropriate safeguards and security measures. Some of our service providers may be located outside of Canada and may store and process your information outside of Canada or access your information from a location outside of Canada.
Securities Regulators, Government Agencies and Law Enforcement
We are required to share your information with securities authorities that oversee our business (such as the Investment Industry Regulatory Organization of Canada, the Mutual Fund Dealers Association of Canada and other regulators). These organizations require access to personal information of clients, employees, agents, directors, officers, partners and other individuals for regulatory purposes, including surveillance of trading-related activity, sales, financial compliance, trade desk review and audit, investigation of potential regulatory and statutory violations, regulatory databases, enforcement or disciplinary proceedings, reporting and information-sharing with applicable authorities, regulated marketplaces, and law enforcement agencies in any jurisdiction.
We may also be compelled to disclose information in response to a legally valid demand, inquiry, proceeding or other order. In these cases, we ensure the request is reasonable and only disclose the specific information necessary to satisfy the inquiry or order. We may be ordered by a court to disclose personal information to a third party or to the court, or to preserve confidential information pending the outcome of a legal hearing. In such circumstances, we will verify the legitimacy of the court order. We will take reasonable steps to limit the amount of personal information that is disclosed to that which is necessary to satisfy the court order. We may also be legally required to disclose information in connection with the collection or repayment of a debt, to assist in the prevention of fraud or other criminal activity, when we obtain legal advice from a lawyer, or in an emergency that affects the health or safety of an individual.
In the instances described above, we may be required to share your personal information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.
Withdrawing your consent
Subject to legal, regulatory and contractual requirements, you may contact us at any time to withdraw your consent. We will explain your options and any consequences of withdrawing your consent. If you do not consent to specific uses or sharing of your personal information, we may be unable, or limited in our ability, to provide you with certain products or services.
If you have any questions about your personal information or your dealings with us in this regard, we encourage you to contact us. In most cases, your concern can be resolved by discussing it with your advisor. If they are unable to address your concern to your satisfaction, you may contact our Privacy Officer.
CU Financial Management
ATTN: Privacy Officer
4 – 36 Brookshire Court
Bedford, NS B4A 4E9
Our Privacy Officer will investigate your question or concern and respond within thirty (30) days. If your concern remains unresolved after contacting our Privacy Officer, you may contact the applicable federal or provincial Privacy Commissioner.
Updating This Policy
We may update or modify our Privacy Policy from time to time as we deem appropriate or necessary to reflect any changes in our business, applicable regulations or industry practices. The current version of our Privacy Policy can be found on our website at cufm.ca/privacy-policy