Protecting your privacy is very important to us. This Policy explains how Steadyhand Investment Funds Inc. collects, uses and discloses the personal information you may provide while using our services or our website at www.steadyhand.com. By using our services or our website, you are indicating your consent to the collection, use, and disclosure of your personal information in accordance with this Policy.
1. Personal Information You Specifically Provide
In the course of completing the New Investment Account Application Form and related documents, and during your use of our services or website, you may be asked to voluntarily provide personal information, such as your name and address including your email address, your user name and password, your social insurance number, and information about your financial circumstances, investment knowledge, objectives and strategies. In the course of providing our services or using our website, Steadyhand also collects personal information related to your accounts and investment activities. Steadyhand uses your personal information for the following purposes and as otherwise permitted by law: (a) to contact and correspond with you; (b) to provide our services; and (c) to perform security and related investigations.
Steadyhand does not sell or disclose your personal information to any third parties for the purpose of selling, marketing or soliciting any products or services. Steadyhand may disclose your personal information only in the following circumstances and as otherwise permitted by law:
(a) Disclosure to SROs – For regulatory purposes, self-regulatory organizations (“SROs”), including the Mutual Fund Dealers Association of Canada, 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.
(b) Disclosure to Affiliates, Agents, Suppliers and Services Providers – Steadyhand may provide your personal information to our affiliates, agents, suppliers and service-providers, for the purposes only of providing our services. Steadyhand requires our affiliates, agents, suppliers and providers to agree to use your personal information only for the purposes for which it is provided to them, and to protect the privacy of your personal information in a manner consistent with applicable law.
(c) Law Enforcement and Legal Disclosure - Steadyhand may also disclose your personal information to a government institution or agency that has asserted its lawful authority to obtain the information; 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 our legal counsel.
2. Safeguarding Your Personal Information
Your personal information may be stored or accessed in Vancouver, British Columbia or Toronto, Ontario. Steadyhand employs reasonable security safeguards appropriate to the sensitivity of the personal information in our possession or under our control in order to protect that information from unauthorized access, collection, use, disclosure, modification or similar risks.
3. Accessing Your Personal Information
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. You can help Steadyhand maintain the accuracy of your information by notifying us of any changes.
4. Non-Personal Information Automatically Collected From Website Users
Our website automatically collects certain non-personal information regarding users, such as the date and time they access the website, the Internet Protocol address and geographic location of the computer they use to access the website, the website pages accessed, and the content accessed or downloaded. This non-personal information is used for system administration purposes and to improve the website.
Our website also may use “cookies”, a technology that installs a small amount of information on a website user’s computer to permit the website to recognize future visits using that computer. Cookies enhance the convenience of our website. For example, the information provided through cookies is used to recognize you as a previous user of the website, offer personalized content and information for your use, and otherwise facilitate your experience using the website. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of our website.
5. Emails and Other Communications from Steadyhand
You may elect to receive email or other communications containing information about Steadyhand and related matters Steadyhand believes will interest you. At any time after electing to receive such emails or other communications, 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 email Steadyhand sends to you will tell you how to decline further unsolicited communications.
6. Further Information
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.