Your Privacy Is Important to Us
In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Clarus Securities may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately. This Policy describes the types of personal information we may collect about you, the purposes for which we use the information (including those with whom we may share it), and the steps that we take to safeguard the information to protect your privacy.
The Sources of Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Clarus Securities during the course of your relationship with us. We may also collect information about your transactions and experiences with Clarus Securities relating to the products and services Clarus Securities provides. In addition, depending on the products or services you require, Clarus Securities may obtain additional information about you, such as your credit history, from consumer reporting agencies. In the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g., recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis but it may be used for compliance or security purposes.
The Information We Have About You
If you deal with Clarus Securities in your individual capacity (e.g., as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:
- Your name, address and other contact details;
- Your age, occupation and marital status;
- Extensive financial information, including investment experience and objectives, risk tolerance, and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
- A photograph from your passport, national identity card or driver's license, as applicable; and
- A personal identifier such as your Social Insurance Number, or other similar information depending upon your country of residence.
If you are an employee, officer, director, principal, or otherwise of one of our corporate or institutional clients, the typical information we collect about you personally would include:
- Your name and contact details;
- Your role/position/title and area of responsibility; and
- Certain identifying information (e.g., passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.
You are not required to supply any of the personal information that we may request, however, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
Our Use of Your Personal Information
We may use your personal information to:
- Administer, operate, facilitate and manage your relationship and/or account with Clarus Securities. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
- Contact you or, if applicable, your designated representative(s) by mail, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
- Provide you with information (such as investment research), recommendations or advice concerning products and services offered by Clarus Securities; and
- Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
If your relationship with Clarus Securities ends, Clarus Securities will continue to treat your personal information, to the extent we retain it, as described in this Policy.
Disclosures of Your Personal Information Within Clarus Securities
In order to provide efficient and reliable services, and to improve product and service options available to you, more than one business function within Clarus Securities may be given, or given access to, your personal information. For example, one Clarus Securities business function might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts. When so sharing your personal information we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Clarus Securities is provided below under Information Security: How We Protect Your Privacy.
Disclosures of Your Personal Information to Third Parties
Clarus Securities does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Clarus Securities, including those that provide professional, legal, or accounting advice or services to Clarus Securities. Non-affiliated companies that assist Clarus Securities in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that Clarus Securities dictates.
We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.
Clarus Securities will not sell your personal information.
Information Security: How We Protect Your Privacy
Clarus Securities is committed to implementing the highest standards of information security to protect the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Clarus Securities employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:
- The use of specialized technology such as firewalls;
- Testing of the security and operability of products and services before they are introduced to the Internet, as well as on-going scanning for publicly-known vulnerabilities in the technology;
- Internal and external reviews of our Internet sites and services;
- Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
- Implementing controls to identify, authenticate and authorize access to various systems or sites;
- Protecting non-public communications through encryption or other means; and
- Providing Clarus Securities personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.
Privacy and the Internet
The following additional information will be of interest to you if you access or use our Web site:
- Users of private Clarus Securities Web sites are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.
- Information regarding which of our web pages you access, and the frequency of such access, may be collected and shared internally in order to assess the usage, value and performance of our web-site.
Other Privacy Policies or Statements
This Policy provides a general statement of the ways in which Clarus Securities protects your personal data. You may, however, in connection with specific products or services offered by Clarus Securities, be provided with privacy policies or statements that supplement this Policy.
You are entitled to access any personal data about you held by Clarus Securities by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law. You are also entitled to have Clarus Securities modify or delete any information that you believe is incorrect or out of date.
Clarus Securities may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of Clarus Securities products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices please contact:
Chief Compliance Officer
Clarus Securities Inc.
Exchange Tower, 130 King Street West
Suite 3640, P.O. Box 38
Toronto, ON M5X 1A9