The privacy of our clients is very important to us. Set forth below are our policies with respect to personal information of current and former clients that we collect, use and disclose.
We collect and maintain personal information about clients in connection with our management of client accounts. We may collect personal information to enable us to provide clients with investment management services, to meet legal and regulatory requirements, and for any other purpose to which clients may consent in the future. Personal information is collected from the following sources:
(a) investment management agreements,
(b) subscription agreements or other forms that clients submit to us, including our Client Information Form;
(b) client transactions with us and our affiliates, if applicable; and
(c) meetings and telephone conversations with clients.
Unless a client otherwise advises, by providing us with their personal information, our clients are consenting to our collection, use and disclosure of their information as provided herein. We collect and maintain personal information on our clients in order to give them the best possible service and allow us to establish their identity, protect us from error and fraud, comply with the law and access their eligibility in our products.
We may disclose personal information to third parties, when necessary, and to our affiliates in connection with the services we provide, including:
(a) financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, your account;
(b) other service providers, such as accounting, legal, or tax preparation services;
(c) taxation and regulatory authorities and agencies;
(d) CRM Providers.
We seek to carefully safeguard your private information and, to that end, restrict access to personal information about clients to those LSWM employees and other persons who need to know the information. Each LSWM employee is responsible for ensuring the confidentiality of all personal information they may access.
A client may access their personal information to verify its accuracy, to withdraw their consent to any of the foregoing collections, uses and/or disclosures being made of their personal information and may update their information by contacting Geoffrey Smith LSWM’s Privacy Officer at (514) 876-9888. Clients should note that our ability to maintain their account may be impacted should they withdraw their consent to the collection, use and disclosure of their personal information as outlined above.
Clients who are investors in the Steinberg Funds and who are resident in Ontario should be aware that the Steinberg Funds are required to file with the Ontario Securities Commission a report setting out the client’s name and address, the class and series of securities issued, the date of issuance and the purchase price of the securities issued. Such information is collected indirectly by the Ontario Securities Commission from us under the authority granted to it in Section 3.11 of the Securities Act (Ontario), for the purposes of the administration and enforcement of the securities legislation of Ontario.
We are also required to file similar information with the Autorité des marchés financiers in Québec or the relevant securities commission in other provinces, as applicable, with respect to investors in those other provinces.
By subscribing for units in the Steinberg Funds, the client authorizes our disclosure and such indirect collection of the information by the Ontario Securities Commission and other securities and regulatory bodies. The following official can answer questions about the Ontario Securities Commission’s indirect collection of the information:
Administrative Support Clerk
Suite 1903, Box 55, 20 Queen Street West
Toronto, Ontario M5H 3S8
Telephone: (416) 593-3684
Facsimile: (416) 593-8122
LSWM reserves the right to modify or supplement its Privacy Policy at any time. If we make a change to the Privacy Policy, we will advise you.