Privacy Policy

The TriCert Group is accountable for the protection of all personal information within its possession or control. Each of our employees must comply with our privacy practices and is responsible for respecting and protecting the personal information to which they have access. The TriCert Group has appointed TriCert Investment Counsel Inc.’s Chief Compliance Officer (CCO) as its Privacy Officer who is responsible for overall privacy governance.

Most of the personal information the TriCert Group collects is provided by you, the client, through completing an application, opening an account, completing a financial plan, or communicating with us.

We may also collect information about you from a variety of sources, including your own records with us, from transactions you have made with or through us, from credit reporting agencies and other financial institutions, and from references you have provided to us.

We collect and use your personal information for the following purposes:

• • to verify your identity and to authenticate you when you contact us;
  • to provide you with the products and services requested;
  • to communicate with you about products and services you have with us;
  • to better understand your financial situation and determine your eligibility for products and services we offer;
  • for marketing and research purposes to improve our products and services;
  • to manage our risks and operations; and
  • to meet regulatory and legal requirements.

We use technology to assist our professional staff in making decisions about you and your account(s). Examples of such uses are:

• • to determine the products that are most suitable for you;
  • to determine if your account(s) may be being used for fraud or money-laundering; and
  • to assist us in analyzing the attributes of all our clients to help us make decisions about products and services to make available to our client base.

We will obtain your consent before using your personal information for any new purposes.

We do not sell, lease, or trade client personal information to others, nor will the TriCert Group make its data set available for public use. Under certain circumstances, your personal information may be shared among the TriCert Group or with other third parties.

To support the TriCert Group’s integrated package of financial services

Our services are part of an integrated package of financial services provided to you by your Accountant, Financial Planner and the TriCert Group. Sharing your personal information among the TriCert Group, and your associated accounting firm and financial services entity, can allow us to help you achieve your financial goals. It is part of building and maintaining a positive advice-based relationship with you.   For greater clarity, below are some examples of circumstances in which your personal information may be shared:

• • with your Financial Planner: we may provide your Financial Planner with information about your accounts with the TriCert Group, including Know Your Client information to be used by the Financial Planner in the course of providing financial planning assistance to you.  We may receive personal information about you from your Financial Planner to assist with the development and maintenance of your overall investment management strategy. We may also request updates to such information and, as applicable, we will review and confirm such information with you as part of our Know Your Client process and obligations.
  • with your Accountant: information about your accounts is shared between us and your Accountant to assist both of us with the development and maintenance of your overall wealth management strategy. This includes information intended to assist with tax, estate, corporate and succession planning.
  • with the companies in the TriCert Group: the companies that comprise the TriCert Group, TriCert Financial Group Inc., TriCert Investment Counsel Inc. and TriCert Insurance Agency Inc., may share your personal information to better understand your financial needs and to provide relevant products and services.

 To Third-Party Service Providers

We have custodial services agreements with the custodian of your account(s) for the provision of trade settlement, record keeping, and tax reporting services and we share your personal information with the custodian to support these services.  We may also use other service providers to perform specialized services on our behalf such as mail/email distribution or data processing and these service providers may be responsible for processing or handling personal information. Our service providers are given only the information necessary to perform their services.

To joint account holders or legal representatives

With your consent, we share personal information with joint account holders or representatives (such as a legal guardian, power of attorney or lawyer). Joint account holders will each have access to all the account history and transaction details for the account(s). We may also share personal information with your (or your joint account holder’s) estate representatives or beneficiaries where reasonably necessary to administer the estate.

To insurance providers

We may exchange personal information with insurance companies for the provision of insurance products and services.

To other third parties to meet legal requirements where we are required to do so or are permitted by law

Personal Information (including tax and account information) may be released to third parties including legal or regulatory authorities in cases of suspected criminal activity, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments or regulatory authorities, to comply with a court order, or to establish or defend legal claims. If allowable under the regulations, and upon your request, we will provide you with the information in the reports filed with these third parties.

To withdraw your consent, please contact us either in person, by phone, or by email using the contact information provided below.

Please note that you cannot withdraw your consent to the collection, use, and disclosure of your personal information if we are legally required to collect, use, or disclose it. Withdrawing your consent may also mean that, in certain situations, we may not be able to provide you with the products or services you request.

You may also challenge the accuracy and completeness of the personal information we hold about you and have it amended, as appropriate, by contacting us using the contact information set out below.

We will only retain your data for as long as it is needed for the purposes described above, or otherwise to meet our legal obligations.

You may submit a written access request to TriCert Investment Counsel Inc.’s CCO using the contact information set out below. To avoid delays in obtaining your information, please provide sufficient detail to permit us to identify you and the specific information that you are requesting.

Please note that there may be instances where access may be restricted as permitted or required by law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations.

Any client of the TriCert Group may challenge our compliance with this Privacy Policy by contacting us directly using the contact information set out below.

If changes to our privacy practices are significant, we will obtain your consent. This includes uses for new purposes or disclosures to new third parties.