CBI Investment Group Ltd. is committed to safeguarding the personal information that is entrusted to us. This policy outlines the principles and practices we follow in protecting your personal information. We manage your personal information in accordance with applicable laws and this policy.
This policy applies to all CBI directors, employees, any other person providing services on our behalf and any of our affiliates. We also ensure that any of our service providers that obtain your personal information in the course of providing services to CBI comply with applicable laws and also treat the personal information in a manner consistent with this policy and our commitment to privacy.
A copy of this policy is available on request and can be accessed on our website: http://cbigroupinvestments.com and may be amended from time to time. We encourage you to often review this policy so that you may be apprised of any amendments, which take effect on the date of posting.
Personal information means any information that identifies an individual (including but not limited to name, address, age, gender, marital or family status, employment history, financial history, opinions, evaluations and comments). Personal information does not include business contact information (name, title or position, email address, business address or phone number) that was provided to us to contact individuals in relation to their business responsibilities or for business communications. It also does not include information that is derived from personal information that was aggregated by us, where individuals’ identities are unascertainable or where we have rendered the personal information non-identifiable.
Personal Information Collected
We collect only the personal information that we need for the purposes of providing services, including personal information needed to:
- open and manage an account
- deliver requested products and services
- enrol a client in a program
- provide you with financial products and services requested
- manage our risks and operations
- meet regulatory and legal requirements
- respond to any special needs or inquiries you may have
- send out association membership information
- provide warranties for products and services
- contact clients about appointments
- follow up with clients to determine satisfaction with products and services
- notify clients of upcoming events of interest
We normally collect personal information directly from you. By providing us with your personal information, you consent to our collection, use and disclosure under the terms of this policy. We request that you refrain from sending your personal information to CBI without prior notice. We may also collect your personal information from others with your consent or as authorized by law. At any time, you may withdraw your consent and we will return or destroy the personal information we have in our possession, however please note that this withdrawal could compromise or discontinue our ability to provide services to you.
We will inform you, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we do not provide this notification when information is volunteered for an obvious purpose.
Unless you have provided your personal information voluntarily and for an obvious purpose, we will inform you of the purposes for which we are collecting the information either before or at the time of collection, use or disclosure and obtain your consent where required by law. We will only collect your personal information for purposes that are reasonable. You may withdraw your consent at any time and inform us accordingly. In some instances we will require your express consent however in other instances your consent will be deemed. We may collect, use or disclose personal information without consent only as authorized by law. For example, when you request financial information for investment purposes, we will assume your consent to the collection, use or disclosure of your personal information for purposes related to that request for information or for other purposes identified by you at the time.
We may not seek your consent in certain circumstances as authorized by law. For instance, we may not seek your consent for the collection, use or disclosure of your personal information when it is reasonable for an investigation or legal proceeding, to collect a debt owed to CBI, in certain emergency situations or when the information is in a public directory.
Use and Disclosure of Personal Information
We use and disclose personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use contact information to deliver goods. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary. If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
We may provide personal information to service providers that will in turn collect, use or disclose this personal information during the provision of services to CBI. Service providers include any organization including our affiliates, contractors, subcontractors or any other entity that directly or indirectly provides services on our behalf. CBI will ensure that our service providers will treat the personal information in a manner consistent with the purpose for which the information was initially collected, this policy and applicable laws.
We may use service providers to perform specialized services on our behalf such as research, marketing, mail distribution, data processing or storing back-up data. Our service providers may at times be responsible for processing or handling personal information. They are provided only the information necessary to perform the services. In addition, we require them to protect the information in a manner that is consistent with our privacy policies and security practices.
We use a service provider in the U.S.A. for the purpose of storing back up data. All of our other service providers are located in Canada. For more information on our use of service providers in or outside of Canada, please contact our Privacy Officer.
Personal Information Safeguards and Requests for Correction
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on you to notify us if there is a change to your personal information that may affect your relationship with our organization. You may also make a request for a correction to your personal information. If you are aware of an error in our information about you, please contact our Privacy Officer who will respond to your request within a reasonable time or as prescribed by law, unless an extension is granted. Our Privacy Officer will ensure that we make the correction wherever possible. In some cases we may ask for a written request for correction. If your request is not granted, we will annotate the personal information accordingly.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes. We render personal information nonidentifiable, or destroy records containing personal information once the information is no longer needed.
We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records and otherwise rendering personal information non-identifiable. We will ensure that any loss of or unauthorized access to personal information is addressed appropriately, without delay and in accordance with applicable laws.
CBI has also ensured that appropriate security measures are in place to protect the organization and its property from external security threats and continually monitors the security policies and procedures that are in place. Mainly out of convenience for you and efficiency of services, CBI does not use encryption for emails however we do have measures in place to maintain privacy and confidentiality. These measures include direct contact to ensure email addresses can receive personal or confidential information, ongoing communication, and secondary review of the addressees of email correspondence before emails are sent. Any contact lists created within CBI are monitored to ensure accuracy and appropriateness for the contact purposes. No group emails are sent exposing addresses or other identifiable information belonging to individuals in the group.
Access to Records Containing Personal Information
You have a right of access to your own personal information record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the applicable privacy laws in Alberta to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the law to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing our Privacy Officer at the contact information listed below. You must provide sufficient information in your request to allow us to identify the information you are seeking. You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred. We will respond to your request within a reasonable time and in accordance with applicable laws, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Our Access to your Information
Access to your information is restricted to authorized employees who have a legitimate business purpose for accessing it. For example, when you call, email or visit us in person, designated employees will access your information to verify that you are the account-holder and to assist you in fulfilling your requests.
Unauthorized access to and/or disclosure of client information by an employee of CBI is strictly prohibited. All employees are required to maintain the confidentiality of client information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
Questions and complaints
We have listed many but not all of the considerations relating to collection, use and disclosure of personal information and we recognize that we have not covered every scenario, situation or example for our handling policy and practices. If you have a question or concern about any collection, use or disclosure of personal information by CBI, our use of service providers, or about a request for access to or correction of your own personal information, please contact our Privacy Officer in the first instance:
CBI Group Investments
1716 10th Avenue SW
Calgary, AB T3C 0J8
ATTN: Privacy Officer
If you are not satisfied with the response you receive, you may choose to contact the privacy office in your province.
We truly value your business at CBI and we hope to impress upon you that we hold all information, personal or otherwise, entrusted with us up to the highest standards of confidentiality, in keeping with this policy and in accordance with the applicable laws in Alberta and any other applicable provincial or Federal laws. We would not sell, trade or otherwise improperly use or disclose any information you have provided to us and we will always use best efforts to maintain security and accuracy. If you have any questions related to the handling of your information, please contact us immediately.