Ninepoint Partners LP complies with the requirements of Part 1 and Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") and all applicable provincial personal information laws. Below is an overview of the privacy principles set out in Schedule 1 of PIPEDA.
Definitions you need to know
Dealer means an individual or entity acting or representing you in connection with your investments as your investment advisor, broker, or dealer, or on behalf of your investment advisor, broker, or dealer. By applying for one of our products or services, you acknowledge and agree that your Dealer is your agent and not our agent. We are entitled to accept and act on any notice, authorization, or other communication that we believe in good faith to be given by you or your Dealer on your behalf. We are under no obligation to verify that your Dealer is properly authorized to act as your agent or is otherwise authorized to act on your behalf.
Service means any brokerage or financial product or service offered by us.
You and your means each person, whether an individual, corporation, your Dealer or trust, who has made and investment, or an application or provided instructions to us for or signed an application in respect of any Service offered by us, including any co-applicants, guarantors or personal or corporate representatives such as directors.
SROs refers to self-regulatory organizations, including the New Self-Regulatory Organization of Canada (New SRO), the exchanges and other regulated marketplaces and the Canadian Investor Protection Fund.
We have strict policies and procedures governing how we deal with your Personal Information. Each and every one of our employees is responsible for respecting and protecting the Personal Information to which the employee has access to.
Kirstin McTaggart, our Chief Privacy Ofﬁcer, oversees privacy governance including policy, dispute resolution, education, communications activities and reporting to our Board of Directors on privacy matters. Please see Contact Us for information on how to reach our Chief Privacy Officer.
What personal information do we collect?
The term "personal information" refers to any information that specifically identifies you, including information such as your home address, telephone numbers, social insurance number (“SIN”), birth date, assets and/or income information, employment history and credit history. We will be collecting personal information from you that includes the following:
For legal entities such as businesses, partnerships, trusts, estates or investment clubs, we may collect the information referred to above from each authorized person, partner, trustee, executor and club member, as appropriate.
How do we collect your information?
We collect your personal or business information directly from you or through your financial advisor and/or dealer in order to provide you with Services, to meet legal and regulatory requirements and for any other purposes to which you consent. Your information may be collected from a variety of sources, including:
We may monitor or record any telephone call we have with you. The content of the call may also be retained. We may inform you prior to proceeding with the call of this possibility. This is to establish a record of the information you provide, to ensure that your instructions are followed properly and to ensure customer service levels are maintained.
How do we use your information?
We collect and use your personal or business information in order to give you the best possible service and for the purposes set out in your agreement(s) with us, such as:
We collect, use and disclose your SIN, social security number or other government-issued personal or business identification number for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.
How do we obtain your consent?
Who do we share your information with?
We may share your personal or business information within the Ninepoint Partners LP for the purposes set out above. We do not provide directly all the services related to your relationship with us. As such, we may transfer your personal information, when necessary, to our third party service providers and to our agents in connection with the Services, however, please note that these third party service providers and agents will not share this information with others. Such information is only used for the purposes identified above. We may use third party service providers or agents such as:
Our service providers and our agents process or handle your information on our behalf and assist us with various services such as printing, imaging, document storage and shredding, mail distribution and marketing. Some of these third parties may be located outside of Canada. As a result, your information may be accessible to regulatory authorities in accordance with the laws of these jurisdictions. When information is provided to our service providers and to our agents, we will require them to protect the information in a manner that is consistent with Ninepoint Partners LP privacy policies and practices.
We may also be required by law to disclose information to government regulatory authorities. For example, we may be required to report your income to taxation authorities. We may also be required to disclose your personal and business information to SROs. SROs collect, maintain, and disclose such information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings. SROs may, in turn, disclose such information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.
How long do we keep your information?
We only keep your personal information as long as it is necessary to do so. The length of time we keep your information depends on the nature of the information as well as legal and regulatory requirements.
How do you withdraw your consent?
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact on our ability to provide you, or continue to provide you, with some Services or information that may be of value to you. We will inform you of the implications of your withdrawal of consent for the continued promises of service to you. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.
How do we safeguard personal information?
We carefully safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide Services to you. Our employees are responsible for ensuring the confidentiality of all personal information they may access. Annually, each of our employees are required to sign a code of conduct, which contains policies on the protection of personal information.
What are the risks?
Although we take steps to safeguard the information under our control, “perfect security” does not exist. In particular, we cannot guarantee the security of the information communicated to us via email. It is possible that third parties may unlawfully intercept or access such information.
How do you update your information?
As we make decisions based on the information we have, we encourage you to help us keep our information accurate and complete. Contact us at any time at in writing at Ninepoint Partners LP, Suite 2700, South Tower, Royal Bank Plaza, 200 Bay Street, Toronto, Ontario M5J 2J1 Attention: Corporate Secretary if you wish to update the information we have about you.
How can you access your information?
You may request access to the personal information we hold about you at any time to review its content and accuracy and to have it amended as appropriate. To request access to such information please contact us in writing at Ninepoint Partners LP, Suite 2700, South Tower, Royal Bank Plaza, 200 Bay Street, Toronto, Ontario M5J 2J1 Attention: Chief Privacy Officer.
We will respond to your written access request promptly. We may be unable to provide you with access to all or some of the information we hold about you. We will provide you with an explanation in the event that we are unable to fulfill your access request.
Reporting privacy breaches
In the event that a breach involving your personal information in our possession has occurred, Ninepoint will immediately take the measures necessary to reduce the risk of harm. A risk assessment is completed to identify the sensitivity of the breached information and the likelihood that the information could be misused for harmful purposes. If the results of the analysis deem the risk to be of serious harm, Ninepoint will notify the Commission and to its discretion, the affected clients, unless otherwise ordered to do so. A privacy incident will be logged and maintained in our records for recordkeeping purposes.
Who do you contact if you have any questions, concerns or complaints?
If you have any questions about our privacy policies and practices and how they relate to you or if you wish to raise a complaint on how we handled your Personal Information, you can contact our Chief Privacy Officer who will then investigate the matter. You can contact our Chief Privacy Officer by telephone at 1-888-362-7172, by e-mail at firstname.lastname@example.org or by mail to Ninepoint Partners LP, Suite 2700, South Tower, Royal Bank Plaza, 200 Bay Street, Toronto, Ontario M5J 2J1 Attention: Chief Privacy Officer.
If you want to escalate, you can contact The Office of the Privacy Commissioner of Canada. Complaints to the Office of the Privacy Commissioner must be submitted in writing to 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3 Attention: The Privacy Commissioner of Canada.
Each time you use our online and electronic services, you are indicating your acknowledgement and consent to the collection, use and disclosure of your Personal Information as set forth in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online and electronic services.
Collection of personal information
We may collect personal information when you use our website, and other electronic services. For example, we may collect:
• Account/Contact Information, such as your name, email address, user ID, password and service preferences.
• Financial Information, such as that required in an online application for account opening.
• Location Information, such as the information about your device’s approximate physical location for purposes such as validating your identity, the prevention, suppression or detection of crime. The ability to access location information is controlled by your device. Please refer to the documentation for your device regarding how to allow or block the collection of location information. If you choose not to provide location information, some services may not operate effectively.
• Device Information such as information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk.
• Website Use Information, such as browsing behavior on Sightline WM’s website and links, location you click, form data and downloads as well as other data gathered from the use of web tools (for example, Cookies, Web Beacons, Tagging) to better understand your interests and needs so that we can serve you better.
• Other Information, such as any feedback you may provide to us.
We do not knowingly solicit data from, or market to, children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should Contact Us. We will delete such information from our files.
Purposes for the use and disclosure of personal information
We may use and disclose your information collected online to:
• Provide and manage the online products and services you have requested;
• Verify your identity and authenticate you;
• Protect against fraud, security threats and otherwise manage risks;
• Communicate with you regarding products and services that may be of interest;
• Evaluate and improve our websites and other electronic offerings;
• Tailor our services and otherwise enhance the customer experience, and
• Satisfy legal or regulatory requirements.
Use of web tools
We or our service providers may use various tracking tools, such as Cookies, Pixel Tags and Web Beacons, on our website and in our emails and advertisements. Pixel Tags, Web Beacons and similar technologies are tracking tools that may be used on our website and in our emails that monitor user activity. They help us capture user activity for analysis to better understand use and effectiveness of the website and emails, enhance user experience and provide additional security controls.
Ninepoint Partners LP is not aware of, nor responsible for, the cookie practices of any third party websites.
Use of third parties
Interest-based advertising allows us to deliver advertisements that are more relevant to you and your interests. It works by showing you advertisements that are based on your browsing patterns and the way you have interacted with this and other websites.
As you browse our website, some of the cookies placed on your computer will be advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser that is based on these perceived interests. These cookies do not contain personal or financial information about you, but may contain a unique identifier required by the retargeting process. If you access one of these ads, we may also track the response rate and the website activity associated with it.
We also work with third party advertising providers who collect and use information about your visits to this and other websites (but not your name, email address, postal address or phone number) to show you advertising that may be of interest to you. This includes the advertising displayed on our websites and the Ninepoint advertising you may be shown when you are on other third-party websites.
You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to require your permission each time a website attempts to set a cookie. However, our websites (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services available on our websites may not work properly.
Third party websites and links