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At ASG Financial Corp (ASG) we recognize the importance of respecting
and maintaining the privacy of identifiable information about individuals
(“Personal Information”). ASG is committed to protecting
Personal Information that is collected through all of our business
processes, in accordance with the Personal Information Protection
and Electronic Documents Act (“PIPEDA”), and other applicable
laws and regulations governing collection, use and disclosure of
Personal Information (together “Privacy Laws”).
ASG’s Privacy Policy and Procedures (“Policy”)
have been established in accordance with the 10 guiding privacy
principles incorporated into PIPEDA.
Accountability
ASG has appointed a Privacy Officer who is responsible for the implementation
and ongoing compliance with this Policy. Every employee of ASG is
also required to abide by the Policy and maintain the confidentiality
of Personal Information that is collected and used by ASG.
Personal Information Collected:
ASG does not collect Personal Information on its own behalf.
However, by virtue of its operation as a financial intermediary,
ASG will come into possession of Personal Information about individual
investors. Where ASG collects such Personal Information, it may
collect such Personal Information as an individual investor’s
name, date of birth, Social Insurance Number, personal income information,
investment information and profile and other financial or beneficiary
information that will allow it to service its accounts and meet
its regulatory obligations.
Identifying Purposes:
ASG will collect and use
Personal Information in the course of its provision of services
as a third party administrator and transfer agent. In this capacity,
ASG does not collect any Personal Information on its own behalf,
but only acts on Personal Information that is provided by its clients.
Such information is collected and provided to ASG to administer
individual investor’s transactions.
Consent:
The provision of Personal Information
to ASG means that individual investors have agreed and consented
and that the parties involved have obtained the required consent
that ASG may collect, use and disclose Personal Information in accordance
with this Policy.
Limited Disclosure of Personal Information:
At
ASG we are committed to safeguarding Personal Information and maintaining
privacy. Except as provided in this Policy or as permitted by law,
ASG does not sell or disclose Personal Information to third parties
unless we have prior written consent or are required to do so by
law.
Personal Information collected by ASG may be subject to transfer
to another company n the event of a change of ownership of all or
part of the organization. This will only occur where the parties
have entered into an agreement under which the collection, use and
disclosure of Personal Information is restricted to those purposes
that relate to the business transaction, including a determination
of whether or not to proceed with the business transaction.
ASG also shares Personal Information with necessary third party
service providers including printers and secure server providers.
ASG requires that these service providers confirm that they have
appropriate procedures to protect Personal Information.
How ASG Protects Personal Information:
ASG will
only retain Personal Information in its possession for as long as
is necessary to fulfill the purpose for which it was collected or
to meet legal or business requirements. ASG utilizes physical, electronic
and procedural safeguards in order to protect the Personal Information
it has under its control against accidental or intentional manipulation,
loss, destruction or against access by unauthorized persons.
ASG’s commitment to maintaining the privacy of Personal Information
security involves monitoring new advances in security technology
and enhancing our security architecture cannot guarantee that the
information submitted to, maintained on, or transmitted by electronic
means to ASG will be completely secure.
Individual Access to Personal Information:
ASG
is committed to protecting Personal Information and ensuring that
it is kept up to date, accurate and complete as necessary for the
purposes for which ASG uses the data. In circumstances where ASG
receives Personal Information form third parties, individual requests
for information regarding Personal Information collected about them
will be redirected to the third parties.
Resolution of Complaints:
If you are dissatisfied with ASG’s
Policy or with the result of your request to access or correct your
Personal Information, you should make a written complaint to ASG’s
Privacy Officer. The Privacy Officer will then investigate the matter.
The Privacy Officer will report back to you and advise of any steps
taken to correct the problem.
ASG’s Privacy Officer can be contacted at:
ASG Financial Corp.
162 Cumberland Street, Suite 300
Toronto, Ontario
M5R 3N5
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