In this policy, the word “Information” means personal, financial and other details about you that you provide to us and we obtain from others outside our organization, including through the products and services you use.
You acknowledge, authorize and agree to allow Sprucegrove to obtain, verify, give, share and exchange Information about you, now and in the future, with any individuals, financial institutions, business corporations or other parties with whom you have or may have financial personal dealings, or who hold information about such dealings, such as credit bureaus. You also authorize any person that Sprucegrove contacts under this authorization to provide such Information.
You acknowledge that we may amend this policy from time to time to take into consideration changes in legislation or other issues that may arise.
Collecting, Using and Disclosing your Information
The Information that you provide to Sprucegrove (or Sprucegrove collects with your consent) with respect to your investor onboarding documentation will be protected and maintained in a client investment file with us.
We may collect, use and disclose your Information to:
- Confirm your identity and the accuracy of the Information provided by you, or collected with your consent;
- Conduct searches to locate you and update your contact information in your file;
- Properly administer and service any financial services and products that Sprucegrove provides to you;
- Keep records of instructions given by you over the telephone;
- Provide you with details of other financial service offered by Sprucegrove; and
- Comply with applicable legal and regulatory requirements.
Before Sprucegrove collects, uses and discloses your Information for any other purpose, we will explain the purpose to you and seek your consent.
Who May Access Your Information
Access to your Information will be limited to:
- Sprucegrove’s employees, representatives and their respective delegates, in the performance of their duties for Sprucegrove;
- Sprucegrove’s employees when resolving your concerns about any related product offerings;
- Affiliated companies or other issuers of investments named in any forms completed for your benefit;
- Service providers used by Sprucegrove, in the performance of their duties for Sprucegrove;
- Those to whom you gave permission; and
- Those authorized by law.
Additional Collections, Uses and Disclosures
We may also use your Information for marketing purposes, including to
- Better understand your financial needs and activities so that we may tell you about other products and services that may be of interest to you;
- Conduct research and surveys to assess your satisfaction with us as a client, and to develop products and services to meet your needs; and
- Contact you by telephone, email, mail, and other methods.
With respect to these marketing purposes, you may choose not to have us:
- Contact you occasionally either by telephone, email, mail, or all of these methods, with offers that may be of interest to you; and
- Contact you to participate in client research and surveys.
Sprucegrove may use external and related service providers for printing services, mail services, distribution services, information technology services, administrative services, and marketing services. Some of our service providers may be located outside of Canada.
As a result, your Information may be accessible to regulatory authorities in accordance with the law of these jurisdictions. We may change service providers or enter into agreements with new service providers. Where Information is provided to our service providers to perform the various services they provide, we will contractually require them to protect the Information in a manner that is consistent with Sprucegrove’s privacy policies and practices.
Withdrawing Your Consent
Subject to any legal and contractual restrictions described above, you may withdraw your consent to Sprucegrove’s collection, use and disclosure of your Information at any time.
Depending on the circumstances; however, withdrawal of your consent may impact our ability to continue to provide you with certain services or information that may be of value to you.
You understand that the withdrawal of certain kinds of consent may delay or preclude our ability to provide contracted services. We will act on your instructions as quickly as possible, but there may be certain uses of your Information that we may not be able to stop immediately.
You cannot refuse our collection, use and disclosure of Information required by third-party service providers essential for the provision of the services or required by regulators.
Reporting Privacy Breaches
A privacy breach is the loss of, unauthorized access to, or disclosure of, Personal Information resulting from a breach of an organization’s security safeguards. Upon the occurrence of a privacy breach or a potential privacy breach, Sprucegrove will investigate and evaluate the implications of the breach of security safeguards. Sprucegrove will report the breach to the appropriate regulatory body and/or applicable organization as soon as feasible after we have determined the breach occurred and such reporting will occur within the prescribed timelines for certain jurisdictions. We will also notify affected individuals if the breach creates a real risk of significant harm to an individual as soon as feasible after the organization determines that the breach has occurred, unless giving notice is otherwise prohibited by law. Sprucegrove will take immediate steps to prevent future breaches after taking all necessary steps to mitigate the risks associated with a breach of security safeguards.
Your Right to Access Your Information or Receive Additional Information
You may request additional information or request access to your Information in your file at any time, subject to the restrictions provided by law, and ask that any inaccurate or incomplete Information be corrected. To do so, you may send a written request with details to the Chief Privacy Officer at the following address:
Sprucegrove Investment Management Ltd.
181 University Ave, Suite 1300
Attention: Chief Privacy Officer
Additional Information for California Residents
Please view our additional information for California residents. This additional information is provided for purposes related to the California Consumer Privacy Act of 2018, as amended (the “CCPA”) and applies to Information which is subject to CCPA.
Additional information for California residents