Dixon Mitchell Investment Counsel Inc. (“Dixon Mitchell”) is committed to protecting your privacy. This Privacy Policy explains how Dixon Mitchell collects, uses and discloses your personal information, and the steps we take to maintain its confidentiality and security.
Key terms of our Privacy Policy:
Personal information
This Privacy Policy applies to “personal information” (i.e., information about an identifiable individual such as your social insurance number, date of birth, family circumstances, financial and net worth information, and banking information). To the extent permitted by law, this Privacy Policy does not apply to information (such as your personal name, position or title, business address, business telephone number, business fax number and business email address) which enables you to be contacted at a place of business. However, Dixon Mitchell treats all of the information in our possession and under our control with care and discretion.
Your consent
By using our services, submitting information to us in connection with our services or investing in securities of investment funds managed by us, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy. You may withdraw your consent at any time, 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 our products and services. Please refer to the section below called “Opting out” of this Privacy Policy to learn about your options with respect to the withdrawal of your consent.
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:
Subject to your right to withdraw consent as described in this Privacy Policy, Dixon Mitchell may also use your personal information collected by Dixon Mitchell for the following additional purposes that are not required for Dixon Mitchell to provide you with products and services:
Dixon Mitchell may use your personal information to create non-personal information, and Dixon Mitchell may then use, disclose, transfer and retain the non-personal information as set out below in this Privacy Policy.
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:
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.
Security
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
Dixon Mitchell stores and processes your personal information in Vancouver, British Columbia. The disclosure of your information in accordance with this Privacy Policy and applicable law may result in your personal information being transferred outside of Canada. For example, back-up copies of records that include your personal information are currently stored in electronic format with a third party located in the United States. The laws of other countries regarding the collection, use and disclosure of personal information may be different from the laws of Canada, and might permit courts, government, law enforcement agencies, regulatory agencies and security authorities to access your personal information without notice. Dixon Mitchell uses reasonable safeguards, including contractual requirements with our service providers, to protect your personal information wherever it is located.
Retention of personal information
Dixon Mitchell will retain your personal information for the period reasonably necessary for the purposes set out or referenced in this Privacy Policy and to comply with Dixon Mitchell’s legal obligations or enforce or protect Dixon Mitchell’s legal rights, or a longer period required or permitted by applicable law.
Dixon Mitchell will delete or dispose of your personal information, or depersonalize the information, when Dixon Mitchell is no longer required or permitted by applicable law to retain the information for the purposes set out or referenced in this Privacy Policy.
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.
Non-personal information
Dixon Mitchell may use your personal information to create and collect non-personal information (information that is not about an identifiable individual), including personal information that has been aggregated or otherwise depersonalized so that the information no longer relates to an identifiable individual. Dixon Mitchell may use, disclose, transfer and retain non-personal information for any purpose and in any manner whatsoever. If non-personal information is combined with your personal information, then Dixon Mitchell will treat the combined non-personal information as personal information for the purposes of this Privacy Policy for as long as the non-personal information is combined with your personal information.
Other websites and businesses
Dixon Mitchell’s website and correspondence (including emails) may include advertisements for products and services offered by independent businesses or links to websites operated by independent businesses. Dixon Mitchell has no responsibility or liability for, or control over, those other websites, online services or businesses, their products or services, or their collection, use, disclosure or retention of your personal information. This Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites, online services and independent businesses. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service or business.
Opting out
In general, when you interact with Dixon Mitchell, you consent to the collection, use, disclosure and retention of personal information as set out in this Privacy Policy. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
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.
Who to contact about our Privacy Policy
If you wish to obtain further information about our privacy practices, or to address any matter concerning this Privacy Policy, please contact our Privacy Officer by mail, email, facsimile or telephone:
Rob Mitchell
Privacy Officer
Dixon Mitchell Investment Counsel Inc.
Suite 1680, 1055 West Hastings Street
Vancouver BC V6E 2E9
604.669.3136
robmitchell@dixonmitchell.com