Privacy Policy

AN IMPORTANT MESSAGE ABOUT PROTECTING YOUR PRIVACY

Gravitas Investments (“GI”), a division of Gravitas Securities Inc. (“GSI”), earn your trust by adhering to privacy principles in protecting your personal information. This notice is provided on behalf of GI, GSI and their related service providers.

DEFINITION OF PERSONAL INFORMATION

The term “personal information” refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, personal information records, identification numbers such as your social insurance number (SIN), and your employment information. For business clients, “information” includes the above data plus names of officers, directors, owners, shareholders, jurisdiction of incorporation, financial information, and ownership structure.

WHY WE ASK FOR YOUR PERSONAL INFORMATION

From time to time, GI and GSI may collect financial and other information about you. This information includes transaction-related details arising from your relationship with us and with third parties with whom you negotiate through us. We may obtain this information from a variety of sources, including from you, from our records, and from references you provide to us. Finally, we may also collect information from credit reporting agencies, other financial institutions or service providers. When you open an account with us, you authorize us to collect this information during the course of our relationship.

SHARING YOUR PERSONAL INFORMATION

The only occasions when we are permitted to disclose client information is when it is authorized by the client or required or permitted by law. We may use and share your personal information with our employees, third party service providers and other financial institutions, but they will not share this information with others. The information will only be used for the following purposes:

• to verify your identity and conduct background verification;
• to operate your account and provide you with products and services you may request;
• to better understand your financial situation;
• to set up, manage and offer products and services;
• if you provide us your social insurance number, we may share it with government authorities for tax purposes. We may share it with credit reporting agencies to ensure the accurate matching of credit history files; or
• if you select to disclose or specifically direct us to disclose your personal information to a third party (as in the case where you request a product, such as a mutual fund or a service from a third party, after receiving information or to securities issuers under National Instrument 54-101).

We may also use or share your personal information in order to meet the requirements of legal and securities regulatory authorities and self-regulatory organizations including, the Investment Industry Regulatory Organization of Canada, and the Canadian Investor Protection Fund (collectively, “SROs”). SROs collect, use or disclose such personal information obtained from registrants for regulatory purposes, including:

• surveillance of trading-related activity;
• sales, financial compliance, trade desk review and other regulatory audits;
• investigation of potential regulatory and statutory violations;
• regulatory databases;
• enforcement or disciplinary proceeding; and
• reporting to securities regulators.

GI and GSI have summarized the ten principles, which have been built upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

ACCOUNTABILITY

GI and GSI are responsible for maintaining and protecting client information under its control.

IDENTIFYING PURPOSES

The purposes for which customer information is collected shall be identified before or at the time the information is collected.

CONSENT

The knowledge and consent of the customer are required for the collection, use or disclosure of customer information except where required or permitted by law.

LIMITS TO THE COLLECTION OF PERSONAL INFORMATION

GI and GSI will limit the amount and type of personal information collected to which is necessary for its purpose. Personal information will be collected by fair and lawful means.

LIMITS TO THE USE AND DISCLOSURE OF PERSONAL INFORMATION

GI and GSI will not use or disclose personal information for purposes other than those for which it was collected except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

ACCURACY

GI will keep personal information as accurate, complete and up-to-date as necessary for its purposes.

SAFEGUARDING CUSTOMER INFORMATION

Customer information is protected by security safeguards that are appropriate to the sensitivity level of the information. Every GI and GSI employee, as a condition of employment, takes responsibility for protecting customer privacy, confidentiality and security. This obligation remains in effect even after an employee leaves GI or GSI. Suppliers of services to GI and GSI, such as data processing firms, are required to sign contracts obligating them to protect the privacy and confidentiality of personal information provided to them, to enable them to perform their function. Appropriate controls are in place over computer systems and these controls are reviewed on an ongoing basis to ensure compliance with our security and privacy policies.

OPENNESS

GI and GSI will make available its review policies and procedures regarding management of personal information. GI and GSI will ensure individuals are reasonably able to acquire information regarding GI’s and GSI’s policies and procedures and will make this information available in a form that is generally understandable.

INDIVIDUAL ACCESS

Upon request in writing, clients shall be informed of the existence, use and disclosure of their information and shall be given access to it. Clients may verify the accuracy and completeness of their information, and may request that it be amended if appropriate.

HANDLING CUSTOMER COMPLAINTS AND SUGGESTIONS

Questions and concerns regarding personal information held by GSI or about its compliance with the GI and GSI Privacy Code, can be answered by the Privacy Officer at Gravitas Securities Inc. For further information, please call (416) 367-0999 or email privacy@gravitassecurities.com