Privacy Policy 2 - Brown Financial

PRIVACY POLICY

WORLDSOURCE FINANCIAL MANAGEMENT INC. PRIVACY INFORMATION

Your privacy is important to Worldsource Wealth Management Inc. and its subsidiaries and affiliates (collectively “Worldsource”). To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected, used and disclosed.

Collection, Use and Disclosure of Personal Information

The purpose for which Worldsource Financial Management Inc. (“Worldsource”) will collect, use and disclose your personal information is central to our providing you with our services. We believe that we cannot continue to provide you with those services if you object to our collecting, using and disclosing your information for those purposes. Worldsource will therefore consider that your continuing to maintain your account with us constitutes your consent to our continuing to collect, use and disclose your personal information as described above. In future, if Worldsource identifies a new purpose for collecting, using or disclosing your information, we will seek your consent before doing so.

The Necessity for Personal Information

Throughout the course of our relationship with you, Worldsource and your advisor (on our behalf) collect personal information from you. This information typically includes “know your client” information about your personal circumstances, including your financial situation and your investment objectives, as well as information about your investments, banking information and social insurance number. Worldsource uses such personal information only for the purposes of administering your account with us (including but not limited to buying and selling securities on your behalf, and reporting to you), and complying with legal and regulatory requirements.

Disclosing Personal Information

We may provide information to companies that perform services on our behalf (such as preparing and mailing statements or processing trades and payments). We may also provide personal information to mutual fund issuers in which you invest, and receive information from them about your investments. Worldsource is a member of several self-regulatory organizations, such as the Mutual Fund Dealers Association of Canada, who may at times require access to personal information for regulatory purposes (such as trading surveillance, regulatory audits, investigation of potential violations, enforcement or disciplinary proceedings and regulatory reporting). Such organizations may in turn share such information with other self-regulatory organizations (such as the Ontario Securities Commission and other provincial regulatory bodies), stock exchanges and law enforcement agencies.

Worldsource does not disclose your information to any other organizations to use for their own purposes, and in particular never sells or trades your personal information.

Protecting Personal Information

We apply the necessary and appropriate security measures to protect your personal information against unauthorized access and misuse. We use a variety of security measures including:
• physical measures, such as locked fireproof cabinets, restricted access to offices and document shredding;
• organizational measures, such as restricted access to files and data centers;
• technological measures, such as network security, strong authentication and data encryption, password protection; and
• ongoing employee privacy and data security training.

Administering Personal Information

In representing us, your advisor is acting on our behalf. Many of our advisors are also licensed to sell other products, and may wish to provide advice and services to you in that capacity. If they do so, they are not acting on our behalf, and they will communicate with you themselves with respect to any other use or disclosure of the personal information they have collected on our behalf.

Quebec Residents

In the Province of Quebec, for the “object” of administering your account and complying with legal and regulatory requirements, Worldsource creates a file containing your personal information. Only those employees whose job functions involve matters related to the “object” of the file will have access to this information. If you wish to review or make changes to your file, you may do so by making a written request to 625 Cochrane Dr., Suite 700, Markham, Ontario, L3R 9R9.

Privacy Officer

If you have any comments, inquiries or complaints about our handling of your personal information, we encourage you to contact your advisor at his/her branch office. Alternatively, you may contact our Privacy Officer at:

Worldsource Financial Management Inc.
625 Cochrane Dr., Suite 700
Markham, Ontario L3R 9R9
Fax: (905) 415-0184
E-mail: Privacy@worldsourcewealth.com

WORLDSOURCE FINANCIAL MANAGEMENT INC. – INVESTOR PRIVACY POLICY

BROWN FINANCIAL CARES ABOUT YOUR PRIVACY.

This privacy policy outlines the type of personal Information that is collected by Brown Financial from consumers and how we use and protect it. This policy also tells you what to do if you do not want your personal Information used for marketing purposes, and how you can change information you have already provided to us. This policy applies to consumer-directed web sites which link to this policy, including the ones listed here, and to Brown Financial collection of data through printed promotional materials such as sweepstakes entry forms, coupons or other mail-in offers and telephone calls to Brown Financial.

Your Consent to This Privacy Policy
Collection of Personal Information
How We Use Your Information
Other Information We May Collect
Privacy of Children
Security of Information
Changes in Our Policy
Who to Contact
Your Consent To This Privacy Policy

By providing Brown Financial with Personal Information, you signify that you agree with the terms of our current Privacy Policy as posted here. If you do not agree with any term in this Policy, please do not provide any Personal Information.

If you choose not to provide Personal Information, you may not be able to do certain things, like access particular areas of our web sites, enter sweepstakes or contests, request samples, or send us e-mail.

COLLECTION OF PERSONAL INFORMATION

As used in this Privacy Policy, “Personal Information” means personally identifiable information such as your name, street address, telephone number, credit card information, screen name and email address.

When you provide us with Personal Information, you are authorizing us to use that information in accordance with the terms of this Privacy Policy, which includes your right to limit our use of your Personal Information (see Who to Contact).

We may also collect Personal Information from you about a third party (e.g., a web site might allow you to send an electronic “post card” to a friend, in which case we will need that person’s name and e-mail address). Please note that we use such information only for the specified purpose (e.g., to mail the post card) and we will not contact the third party again unless and until the third party contacts us.

HOW WE USE YOUR INFORMATION

When you supply us with your Personal Information we will use it for the express purpose for which it was collected. At any time, however, you may opt out of such contact. (See Who to Contact)

At times we may retain third parties to analyze data we collect, including Personal Information, to help us improve our products and our web sites. In addition, if you order a product or service from us, we may provide Personal Information to suppliers and other third parties to enable delivery of such product or service. These third parties, including suppliers, are not authorized by us to use your Personal Information in any other way.

We may supplement the information that you provide to us with other information that we receive from third parties. We do this for marketing purposes in order to provide the most appropriate products and services to meet your needs.

We may also transfer or assign your Personal Information to any entity to which we divest all or a portion of our business, to the extent that you provided such information to the specific portion of our business that is being divested, or otherwise in connection with a merger, consolidation, change in control, reorganization or liquidation of all or a portion of our business.

Finally, please note that we will release your Personal Information if required to do so by law, or by search warrant, subpoena or court order.

OTHER INFORMATION WE MAY COLLECT ONLINE

Other information that we may collect online, via Brown Financial web sites, e-mail promotions and banners, for example, is described in this section.

You may have heard of “cookies,” which are files or pieces of information that are stored by your browser on your computer’s hard drive. Brown Financial may use cookies to collect other information during your visit to our web site, such as the particular site areas you visit and the products or services you buy through our web site. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities at our sites. For example, a site can recognize that you have provided Personal Information to us and refrain from requesting the same information a second time.

Most browsers are initially set to accept cookies. If you’d prefer, you can set yours to refuse cookies or to alert you when cookies are being sent. Refusal of cookies at the site you entered may result in an inability to visit certain areas of the site or to receive personalized information when you visit the site.

In addition, we are constantly trying to improve how we promote our web sites. To help us do this, we may measure the effectiveness of our web presence by determining what you clicked on to get to our site.

Site measurement statistics may be used to personalize your web site experience, as well as to evaluate – anonymously and in the aggregate – statistics about usage of the web site. Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of computer operating system you are using may also be collected and linked to your Personal Information. This is to ensure that our web sites present the best web experience for visitors, and that they are an effective information resource.

Finally, some of the pages you visit may use pixel tags (also called clear gifs) to collect information about your navigation on our web sites. This information is used to evaluate and enhance how the web sites function.

SECURITY OF INFORMATION

We take reasonable precautions to keep your Personal Information secure. All personally identifiable information is subject to restricted access to prevent unauthorized access, modification or misuse.

CHANGES IN OUR POLICY

We reserves the right to change or remove this Privacy Policy at our discretion. We will post any new policy here and we encourage you to visit this area frequently to stay informed.

WHO TO CONTACT

Please write to us at Brown Financial, 25 Mill St. N., P.O. Box 530, Waterdown, ON L0R 2H0, if you have any comments or questions about this Privacy Policy or to report any violations of the Privacy Policy. We will respond to you within 48 hours in most cases. For other requests, please choose among the following options:

Again, Brown Financial is committed to protecting your privacy. Please do not hesitate to contact us if you have any questions, comments or concerns about this Privacy Policy.