Last updated: September 16, 2021
Protecting your privacy is very important to us. This Policy explains how Steadyhand Investment Funds Inc. and Steadyhand Investment Management Ltd. (collectively, “Steadyhand”) collects, uses, discloses and retains personal information, including personal information you may provide while using our services or our website at www.steadyhand.com (the “Website”). By providing Steadyhand with your personal information, you consent to the collection, use, disclosure and retention of your personal information in accordance with this Policy and as otherwise permitted by applicable law.
1. Personal Information
2. How Steadyhand Collects Personal Information
(a) Personal Information You Specifically Provide
You may be asked to voluntarily give your personal information to Steadyhand when you interact with Steadyhand, including when in the course of completing new Account Application forms and related documents, and during your use of our services or the Website.
For example, Steadyhand may collect:
In those circumstances, you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of the Website, or otherwise receive the full benefit of Steadyhand’s services.
If you give Steadyhand the personal information of another individual, then you are solely responsible for complying with all applicable laws, including obtaining the individual’s valid consent, regarding your collection and disclosure of the personal information to Steadyhand and to Steadyhand’s use, disclosure and retention of the personal information.
(b) Automated Collection
Steadyhand may use technologies to automatically collect certain information regarding your use of the Website or online services, such as the dates and times that you access the Website or online service, the browsers, operating systems, software, devices and networks that you use to access the Website or online service and details of your use of the Website or online service.
Steadyhand’s Website, online services, email messages, and advertisements may also use technologies (e.g. cookies, web beacons, tokens, pixels or tags) to automatically collect information that assists Steadyhand to improve its products, services, customer communications and advertising and to prevent fraud.
(c) Information from Other Sources
In some cases, and only with your express consent, we might also collect your personal information from third party sources, such as your accountant, financial planner or lawyer.
2. How Steadyhand Uses Personal Information
Steadyhand may combine your personal information collected by Steadyhand through various sources.
(b) Information Collected by Technological Means
Information provided by cookies may be collected and processed by Steadyhand or by its third party service providers, including Google and Facebook.
3. How Steadyhand Discloses Personal Information
(b) Specific Consents
Steadyhand may disclose your personal information in accordance with express or implied consents that you give during your interactions and transactions with Steadyhand.
(c) Suppliers and Service Providers
(d) Self-Regulatory Organizations
For regulatory purposes, self-regulatory organizations (“SROs”), including the Mutual Fund Dealers Association of Canada, may require access to personal information of current and former clients, directors, officers, employees, agents, partners and others that have been collected by Steadyhand. SROs collect, use or disclose such personal information for regulatory purposes, including surveillance of trading activity; sales, financial compliance, trade desk review and other regulatory audits; investigation of potential regulatory and statutory violations; regulatory databases; enforcement or disciplinary proceedings; reporting to securities regulators; and information-sharing with securities regulatory authorities, regulated marketplaces, other SROs and law enforcement agencies in any jurisdiction in connection with any of the foregoing.
(e) Business Partners and Other Third Parties
In some circumstances, Steadyhand may share your personal information with its business partners, such as strategic business partners who provide products and services that enhance your experience with Steadyhand or that may be of interest to you, and other third parties. For example, Steadyhand may disclose your personal information to your accountant or an external accountant or financial planner on your request. Steadyhand will only disclose your personal information to a third party if Steadyhand has your consent to do so, if you have provided your consent to the third party, or if Steadyhand is legally required or permitted to do so.
(f) Law Enforcement/Legal Disclosures
(g) Business Transactions
4. Your Right to Withdraw Consent
If you withdraw your consent to the collection, use, disclosure and retention of your personal information for purposes that are integral to the provision of Steadyhand’s products and services, then you might not be able to proceed with your intended interactions or transactions with Steadyhand or otherwise receive the full benefit of Steadyhand’s products and services.
If you withdraw your consent to the collection, use, disclosure and retention of your personal information for additional purposes that are not integral to the provision of Steadyhand’s products and services (e.g., to send advertising and marketing messages to you, to administer and facilitate your participation in contests and promotions, and to conduct surveys) then withdrawing your consent for those purposes will not affect the provision of Steadyhand’s products and services to you.
5. Advertising/Marketing Messages from Steadyhand
You may elect to receive advertising or marketing messages containing information about Steadyhand and related matters Steadyhand believes will interest you. At any time after electing to receive such messages, you may ask Steadyhand to stop sending them to you by sending your request to our Privacy Officer at one of the addresses noted below. Also, each advertising or marketing message Steadyhand sends to you will explain how you can withdraw your consent.
6. Audio and Video Recordings
Steadyhand may collect and retain audio recordings of phone calls made by you to Steadyhand or a Steadyhand representative to you. In some cases, to facilitate your interactions with Steadyhand, we may collect and retain video recordings of virtual meetings you have with a Steadyhand representative.
Steadyhand uses audio and video recordings to comply with our legal and regulatory obligations, to monitor quality control, to confirm investment decisions and other instructions you may give to Steadyhand and to protect and enforce Steadyhand’s legal rights, interests and remedies or to protect the rights, interests, business, operations or customers of Steadyhand or other persons (including to detect and prevent fraud and other illegal activities).
Steadyhand will never record a phone call or virtual meeting with you without your consent.
7. Location of Personal Information
Steadyhand will always store your financial information in Canada. Steadyhand and its service providers may process, store and use other personal information at facilities in Canada and the United States. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. By providing your personal information to Steadyhand, you consent to the transfer of the personal information to facilities located in other countries and the processing and storage of the personal information at those facilities.
8. Retention of Personal Information
9. Protection of Personal Information
10. Accuracy and Access to Personal Information
Steadyhand will rely on you to ensure that the personal information you provide to Steadyhand is as accurate, complete and up to date as necessary for the purposes for which Steadyhand uses the personal information. You will promptly notify Steadyhand of any changes to the personal information you provide to Steadyhand using the procedures made available for that purpose by Steadyhand or by contacting Steadyhand’s Privacy Officer using the contact information noted below.
You may request access to your personal information and information about Steadyhand’s collection, use and disclosure of that information by sending your request to our Privacy Officer at one of the addresses 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. Steadyhand may decline to process an access request that is unreasonably repetitive, frivolous, vexatious or impracticable, or if Steadyhand reasonably believes that the requested access would infringe or jeopardize the privacy of other persons, or violate any applicable law or legal requirement, or for other reasons permitted by applicable law.
11. Non-Personal Information
12. Other Websites and Businesses
13. Social Media
14. Children and Personal Information
15. Other Matters
(a) Disclaimers, Liability Exclusions/Limitations and Disputes
(c) Notices to You
16. Contacting Steadyhand
We welcome the opportunity to discuss our privacy practices further with you. Steadyhand’s Privacy Officer may be contacted by the following methods: (a) by telephone - 1.888.888.3147; (b) by email - firstname.lastname@example.org; or (c) by postal mail to “Privacy Officer”, 1747 West 3rd Avenue, Vancouver, BC, V6J 1K7.