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Privacy Policy

What is PIPEDA?

Personal Information Protection and Electronic Documents Act (PIPEDA) is the privacy legislation introduced by the Federal Government. It is based on ten principles that form the ground rules for the collection, use and disclosure of personal information. Its purpose is to give individuals greater control over how their personal information is handled by the private sector. PIPEDA is implemented in three stages with the final stage slated to become effective on January 1, 2004. After this final stage is implemented PIPEDA, or an equivalent form of provincial legislation, will cover virtually all commercial activities within Canada. In accordance with PIPEDA, we are committed to protecting the privacy of investors' information and regard this as an integral part of our service. Our Clients collect an investor's personal information and obtain the necessary consent for using that personal information. Arrow keeps all personal information in strict confidence and controls access to, and use of, such information, based on practices and procedures described in this statement.

At PanFinancial Group we recognize that all personal information is private and confidential. PanFinancial Group's Privacy Policy ("Privacy Policy") governs PanFinancial Group's collection, use and disclosure of personal information. It is the intention of PanFinancial Group, by way of this Privacy Policy, to comply with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Document Act (PIPEDA).

PanFinancial Group recognizes the following key principles of PIPEDA:

Accountability:

PanFinancial Group acknowledges the importance and necessity of safeguarding the private and confidential information belonging to our clients. As such, we have appointed a Privacy Officer to ensure compliance with privacy legislation and to inform all PanFinancial Group staff of the need to use the utmost discretion when dealing with client information. PanFinancial Group's Privacy Officer has the responsibility to carefully analyze and alter collection procedures both on a preliminary and ongoing basis to assure maximum privacy protection.

Purpose:

PanFinancial Group will only use client information for the purposes identified either before or at the time of collection. It is our policy that we will not sell your information.

Consent:

PanFinancial Group will only use client information for identified purposes and if the information is required for any new use, PanFinancial Group will take the necessary steps in order to seek additional consent. Consent may be expressed in writing, orally or may be implied directly by yourself or your authorized representative.

Collection:

PanFinancial Group will only collect personal information as needed in order to complete necessary documentation, determine eligibility and/or to comply with regulations, policies, laws and legislation such as, the Money Laundering (Terrorist Financing) Act. PanFinancial Group's staff will do their best to explain why collection of information is necessary in a clear and informative fashion.

Use, Disclosure and Retention:

PanFinancial Group will only retain personal information for as long as needed in order to satisfy the stated purposes identified when the information was collected. If it is deemed that an individual's personal information is no longer required, PanFinancial Group will take the necessary measures to destroy, dispose, or erase the information in a manner that will ensure that information cannot be found or used by an unauthorized party.

Accuracy:

PanFinancial Group strives to maintain accurate client information which not only help us provide better customer service but also minimizes the potential misuse of personal information.

Safeguards:

PanFinancial Group understands the importance of protecting personal information and therefore, implements a number of safeguards against unauthorized access or improper disclosure. For example, PanFinancial Group's computer network, employee computers, laptops, and phone message centres are all password protected. In addition, filing cabinet units and storage rooms containing personal information are locked and can only be accessed by designated individuals. General entry to our offices is secured and cannot be accessed by unauthorized personnel without permission.

Our safeguards are supported by ongoing communication to our employees about the importance of secure client information and continual maintenance and periodic review of our Privacy Policy and procedures. PanFinancial Group employees are subject to a strict code of conduct when it comes to your personal information.

Directness:

At PanFinancial Group we make our best effort to inform clients of our policies and procedures and to explain how we manage personal information. Our Privacy Policy can be found on our website or can be requested via email or phone. If you have additional questions or concerns, our Privacy Officer will do her best to help you understand our procedures and policies.

Access:

When requested and supported by sufficient identity information, PanFinancial Group will provide you with your personal information as maintained in your client files. We recognize your right to your own information, how it is used and to whom it is disclosed.

If an error or discrepancy is found in your personal information, we will act efficiently (in less than thirty days) to correct the mistake. An extension will only be applied if the request will unreasonably interfere with our business affairs.

Complaints and Recourse:

PanFinancial Group's Privacy Officer will deal with any complaints or conflicts arising in regards to the collection, use and disclosure of personal information. In order to adequately address the complaint, all details will be recorded and a file will be created. All individuals involved will be notified of an enquiry into the complaint. Once a decision of recourse has been determined, all parties involved will be informed of the outcome. PanFinancial Group's Privacy Officer can provide you with a more complete description of the recourse process. Individuals who are not satisfied with PanFinancial Group's recourse procedure can bring the complaint to the attention of the federal Privacy Commissioner.

The measures outlined in this Privacy Policy in order to abide by PIPEDA's key principles are intended to provide clients with comfort that PanFinancial Group's staff regards personal information with the utmost importance. The Privacy Policy is also created to provide the right of access to personal information and an avenue to address any concerns individuals may have about the use of their information.

Website:

Personal information collected by PanFinancial Group may be used to determine how many people visit the website and which sections of the website are visited the most frequently. When you visit the website, move from page to page, read pages, or download its content onto your computer, the following information may be recorded:

  • The address you are connecting from
  • Which pages are visited
  • What content is downloaded
  • The website addresses that you visited immediately before coming to the PanFinancial Group website

Certain PanFinancial Group employees will be provided with information about the website visitor in order to serve that visitor's needs and provide the visitor with information regarding specific products. PanFinancial Group employees are instructed to use strict standards of care in handling the personal, confidential information.

Information obtained by registering on this website or attending an PanFinancial Group event will reside in an internal database at PanFinancial Group. If you wish to have your information removed from the PanFinancial Group database at any time, please e-mail your request to info@panfinancial.com.

Direct any other questions/concerns you may have to:

PanFinancial Group
265 Yorkland Blvd.
Suite 401
Toronto, Ontario
M2J 1S5

Tel: 416.499.4222
Fax: 416.499.6540
Email: info@panfinancial.com

A complete version of Personal Information Protection and Electronic Document Act (PIPEDA) can be found on the Department of Justice website at: http://laws.justice.gc.ca/en/P-8.6/text.html