Algar, Virtue & Associates Inc. and Your Privacy

Algar, Virtue & Associates Inc. (AVA) considers your personal privacy to be an important part of our service to you. We understand the need to safeguard information about you that you have entrusted to us. As part of our commitment to you, we have adopted principles designed to protect your privacy, prevent misuse of your personal information, and help you understand our commitment to your personal privacy.

References to “Algar, Virtue & Associates Inc.”, “AVA”, “we” or “our” are to Algar, Virtue & Associates Inc. Where we use the term “personal information” we are referring to any information that identifies you as an individual and includes information with respect to your name, address, age, gender, income, marital status, finances, employment, trading history and web site use information, together with your personal references and identification numbers (such as a social insurance number).
Our privacy policy applies to personal clients, including individuals carrying on business alone or in partnership with other individuals. The following sections will answer most of the important questions that you may have about how we gather, protect and use personal information, and how we will hold ourselves accessible and accountable to you.

AVA’s Principles on Privacy

We have incorporated certain principles for the protection of personal information in our privacy policy.

• Collecting and Using Personal Information – We will explain how we intend to use your personal information prior to or when we are collecting it and we will limit the personal information we collect to what we need for those purposes. We will use it only for those purposes we have explained to you and we will obtain your consent if we wish to use your personal information for any other purpose.

• Disclosing Personal Information to Others – We may provide your personal information to other persons not affiliated with AVA, such as regulators, service providers or credit reporting agencies, but only where we have your consent or where we are required or permitted to do so by law.

• Retaining and Protecting Personal Information – We will retain your personal information only for the time it is required for the purposes we explain or as otherwise required by law. We will protect the personal information we obtain about you with appropriate safeguards and security measures.

  Access and Accuracy – We will provide you with reasonable access to your personal information on record with AVA and information about AVA’s use and disclosure of that information. We will make every reasonable effort to keep your personal information accurate and up-to-date.

• Accountability and Openness to Your Privacy Concerns – We will hold ourselves accountable to you and we will investigate and respond to your concerns about any aspect of our handling of your personal information. We will explain the application of our privacy policy to your personal information and explain your options of refusing or withdrawing consent to the collection, use and release of your personal information, and we will record and respect your choices.

Why Does AVA Collect Personal Information?

We collect, retain, and use personal information about you only when we reasonably believe that it will help administer our business or provide products, services and other opportunities to you as our client. We collect and retain personal information about you only for specific business purposes, and we will tell you why we are collecting and retaining it on your request. The information we ask for depends on the products or services you request and in most cases are required by law or the policies of the regulatory bodies to which we are subject. Your social insurance number is required for products that earn investment income, in order to comply with the Canada Revenue Agency’s income reporting requirements. If you provide your social insurance number, we also use it to keep your personal information separate from that of other clients with a similar name.

With your consent, we may share your personal information, where not prohibited by law, to affiliated companies of AVA for the purposes of providing other services to you. AVA may use your personal information to provide you with information about AVA’s products and services and other matters. This consent is optional and you can decide to withdraw it at any time. Please refer to our section regarding your options below.

How Does AVA Collect Personal Information?

We obtain most of our information about you directly from you. With your consent, we may obtain personal information about you from third parties.

When Does AVA Release Personal Information?

AVA does not sell client lists or personal information to others. We do not reveal personal information about you to parties outside our affiliated companies for their independent use unless you request or authorize it or the information is provided in order to complete a transaction initiated by you or the disclosure otherwise is lawfully permitted or required. We may disclose information to the authorities to serve a clear public interest and fulfill our public duty — such as to protect against fraud, money laundering or other criminal activity. We may, from time to time, be asked to disclose information to regulators to which we are subject for the purposes of an audit or investigation relating to specific accounts or our business generally. In certain circumstances, AVA may disclose your personally identifiable information if it believes, in good faith, that disclosure is otherwise necessary or advisable to protect its interests. Sometimes it is necessary to provide personal information about you to a party outside our company, such as a vendor or service company that we hire to do our data processing, prepare your account statements, or provide support or services for one or more of our products.Sometimes it is necessary to provide personal information about you to a party outside our company, such as to a vendor or service company that we hire to do our data processing or prepare your account statements or to provide support or services for one or more of our products. These vendors and service companies agree to safeguard confidential information about you and your products and services with us and must abide by applicable law.

Does AVA Provide Options?

It is always your choice whether or not to provide personal information or to consent to our obtaining personal information about you from third parties. In many cases you are free to refuse or withdraw your consent at any time. If you choose not to provide requested personal information or consents, we may not be able to provide certain products and services to you or you may be ineligible for or be unable to use certain products and services we provide. AVA will explain your options of refusing or withdrawing consent to the collection, use or release of your personal information, and we will record and respect your choices. If you wish to discuss your options you may do so by contacting AVA’s designated privacy officer set out below, or contacting our Compliance Department. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.

How Long Does AVA Retain Personal Information?

We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information and may extend beyond the end of your relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed, we have procedures to destroy, delete, erase or convert it to an anonymous form.

How Does AVA Protect Personal Information?

AVA stores and processes your personal information in Calgary, Alberta, Canada. Certain personal information about you is retained by the AVA office that handles your account. We maintain security standards and procedures to help prevent unauthorized access to confidential information about you. Our security standards and procedures are updated and tested from time to time to improve the protection of our information about you and to assure the integrity of our personal information.

We have procedures that limit access to personally identifiable information to those employees with a business need to know. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs and our internal policies. We take appropriate measures to enforce employee privacy responsibilities.

All our suppliers and agents, as part of their contracts with AVA, are bound to maintain your confidentiality and may not use the information for any unauthorized purpose. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required — otherwise we will seek your consent prior to disclosing any information.

What About the Internet?

We share your concern about your privacy in the Internet world and are committed to its protection. The principles set out in this privacy policy apply equally to anything you might do at our website.

When you send us an email or when you ask us to respond to you by email, we learn your exact email address and any information you have included in the email. We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. Emails sent from the AVA office are protected by encryption to help keep your information secure. Remember, email over the Internet is generally unencrypted, and the device you send emails from may not encrypt these emails, or keep the encryption on received and/or stored emails.

We will not sell your email address. We may use your email address to send you information about our products or services that we believe may be of interest to you. If you don’t want us to contact you with product information by email, you may tell us so at any time.

Our website may contain links to other websites. When you click on one of those links, you are contacting another website for which AVA has no responsibility and over which AVA has no control.

How Do I Access My Personal Information?

You may request access to your personal information on record with AVA and information about AVA’s use and disclosure of that information by contacting your portfolio or relationship manager, or by contacting the AVA office directly. We will advise you in advance if a minimal charge will be required for conducting the search, and we will respond to your request promptly. In any case, we will respond within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to AVA, is too costly to retrieve, or cannot be disclosed for other legal reasons. Also, we do not maintain disclosure records for regular or routine actions.

How Do I Keep My Personal Information Accurate?

AVA attempts to keep its records as accurate and complete as possible. You can help us maintain the accuracy of your information by notifying us of any changes to your personal information. If you find any errors in our information about you, let us know and we will make the corrections immediately and make sure they are conveyed to anyone we may have misinformed. For information that remains in dispute, we will note your opinion in the file.

Who Should I Contact Regarding Privacy Issues?

AVA has designated a privacy officer, Angela Houghton, to respond to your concerns or questions about privacy and confidentiality, or any concerns about the way a request for personal information was handled. To reach our privacy officer, please refer to the following: in writing, at 920, 2424 4th St SW Calgary Alberta T2S 2T4; by telephone, at 403-245-3115; or by email, at ava@algarvirtue.com. Your concerns will be passed on to the appropriate Compliance personnel at AVA so that further action is taken to resolve the matter, if necessary.