All personal information of clients is private and confidential. Flow Capital Corp. (“Flow Capital” and “Flow”) has adopted a comprehensive privacy policy and implemented practices to protect such information and to ensure compliance with privacy legislation and, in particular, with the requirements of the federal Personal Information Protection and Electronic Documents Act (PIPEDA).
PIPEDA is the privacy legislation of the Canadian federal government, which covers virtually all commercial activity in Canada, effective January 1, 2004. Under this Act no business may collect, use or disclose personal information about an identifiable individual (“client information”) without first clearly defining the purpose of such collection, use or disclosure and obtaining the individual’s informed consent. The collection, use or disclosure is limited to purposes that a reasonable person would consider appropriate in the circumstances. The privacy law also regulates the protection, retention and destruction of personal information and provides individuals with the right to access and challenge information, and establishes complaint procedures and avenues for redress.
Flow Capital 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 of our staff of the need to use the utmost discretion when dealing with client information. Flow’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.
Client information is any information that identifies an individual. This includes such items as an individual’s name, address, age, financial information, social insurance number, personal email address and telephone numbers. Information is collected in order to determine a client’s identity, establish a client’s eligibility for a product or service, to protect all parties against errors or fraud (e.g. money laundering), to comply with legal requirements (e.g. anti-terrorism legislation) and to communicate with the client. Flow Capital will only use client information for the purposes identified either before or at the time of collection. We will not sell your information.
Flow Capital will only use client information for identified purposes. If the information is required for any new use, Flow 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. Consent to use personal information may be withdrawn by a client at any time by contacting Flow. Note however that legal or other requirements may prevent clients from withholding consent and a decision to withhold personal information may limit the services or products that Flow can provide to the client.
Flow Capital will only collect client information as needed at the time in compliance with this policy. In most cases consent is obtained via the subscription agreement process for client investments in funds advised by Flow. We will do our best to explain why the collection of information is necessary in a clear and informative fashion. Flow Capital does not collect any personal information from visitors browsing our website although personal information may be requested if a visitor chooses to send Flow an email message.
Client information will only be used for the purposes for which it was collected. Flow Capital may share client information with other parties as required by law (e.g. for tax reporting purposes to the government) and with third parties who provide services to Flow (e.g. unitholder registration, client statement preparation and mailing). Flow has agreements with such third parties service providers to ensure the proper handling and protection of personal information. We may also be required to provide client information when responding to a search warrant, court order or other legally valid request. Flow will only retain client information for as long as needed in order to satisfy the stated purposes at the time of collection. When the information is no longer required we will take the necessary measures to destroy, dispose of, or erase the information.
Flow Capital strives to ensure that client information is accurate at all times.
Flow Capital has put in place various policies to safeguard your personal information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable us to provide services to you. Flow’s employees are responsible for ensuring the confidentiality of all personal information they may access.
For more information, please contact Flow Capital’s Privacy Officer.
Email: info@flowcap.com
