- For details on the personal information that Dixon Mitchell collects, please see the section below called “How Dixon Mitchell collects personal information”.
- For details on how Dixon Mitchell uses personal information, please see the section below called “How Dixon Mitchell uses personal information”.
- For details on how Dixon Mitchell discloses your personal information, please see the section below called “How Dixon Mitchell discloses personal information”.
- To change your privacy choices, please see the section below called “Opting out”.
How Dixon Mitchell collects personal information
We may ask you to provide personal information when we interact with you, including when you request information or use a product or service provided by us. For example, we may collect your name, address, date of birth, social insurance number, family circumstances, employer information and investment experience.
Occasionally, we may collect personal information about you from third parties. We will only collect your personal information from a third party if we have obtained your consent to do so, if you have provided your consent to the third party, or if we are legally required or permitted to do so.
How Dixon Mitchell uses personal information
Dixon Mitchell uses your personal information for the following purposes, and as otherwise permitted by law:
- to provide our portfolio management and investment advisory services to you, including by understanding your objectives and risk tolerances, and to otherwise facilitate your interactions and transactions with us;
- to verify your identity and protect against fraud;
- to process and respond to your inquiries, requests and other communications; and
- to comply with legal and regulatory requirements.
- to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you;
- to administer and facilitate your participation in promotions related to Dixon Mitchell; and
- to conduct surveys on the quality of our products and services.
How Dixon Mitchell discloses personal information
Dixon Mitchell does not sell your personal information to third parties. Dixon Mitchell does not disclose your personal information to third parties other than in the following circumstances and as otherwise permitted by law:
- Disclosure for Normal Business Operations – Dixon Mitchell may disclose your personal information to third parties in connection with normal business operations to open, maintain, administer or service your investment account, including without limitation for purpose of facilitating the account opening process (including the mailing of account opening materials and the scanning of account documentation, cheques and related materials 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 the mailing of transaction confirmations and account statements, and record-keeping services), for audit or statistical purposes, or for the collection of any debt owed by you in respect of your investment or account.
- Disclosure to Authorizing Persons – If you use our services on behalf of another person or organization (such as your employer), Dixon Mitchell may provide your personal information to that authorizing person or organization.
- Law Enforcement and Legal Disclosure – Dixon Mitchell may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where Dixon Mitchell has reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to its legal counsel.
- Specific Consents – Dixon Mitchell may disclose your personal information to other persons in accordance with express or implied consents that you give during your interactions and transactions with us.
Accessing your personal information
You may request access to your personal information and information about Dixon Mitchell’s collection, use and disclosure of that information by sending your request to Dixon Mitchell’s Privacy Officer at the address noted below. Subject to certain exceptions and limitations prescribed by law, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. You can help Dixon Mitchell maintain the accuracy of your information by notifying us of any changes to your personal information.
We take reasonable organizational, technological and physical measures to protect your personal information against unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks.
Location of your personal information
Retention of personal information
If you ask Dixon Mitchell to delete your information, we will do so within a reasonable period of time. Please note that Dixon Mitchell may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of your information may remain in back-up storage even if you ask Dixon Mitchell to delete it.
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Withdrawing your consent for integral purposes. You may withdraw your consent for purposes that are integral to the provision of our products and services, subject to legal or contractual restrictions and on reasonable notice to Dixon Mitchell, but then you might not be able to proceed with your intended interactions or transactions with Dixon Mitchell or otherwise receive the full benefit of Dixon Mitchell’s products and services.
Withdrawing your consent for additional purposes. Withdrawing your consent for additional purposes that are not integral to the provision of our products and services will not impact the provision of our products and services to you.
You may withdraw your consent to your personal information being used or shared to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you. You can always limit the electronic communications that Dixon Mitchell sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, we may still need to contact you with important information about your product or service.
To withdraw your consent, you may contact Dixon Mitchell’s Privacy Officer at the address noted below.
Tjerk (TJ) de Gruijter
Dixon Mitchell Investment Counsel Inc.
Suite 1680, 1055 West Hastings Street
Vancouver BC V6E 2E9