Privacy Policy

THE INVESTMENT FUNDS INSTITUTE OF CANADA

INTRODUCTION

The Investment Funds Institute of Canada (referred to as “IFIC,” “we,” “us,” or “our” in this Privacy Policy) is the leading association representing Canada’s investment funds industry. IFIC brings together fund managers, distributors and industry service organizations to foster a strong and stable investment sector.

Please read this Privacy Policy carefully and contact us if you have any questions about our practices regarding the handling and protection of personal information or your personal information choices.

1. IMPORTANT INFORMATION ABOUT THIS PRIVACY POLICY

Purpose

This Privacy Policy sets out how IFIC collects and processes your personal information as you interact with us, including through your use of our website and any data you may provide through our website, in connection with membership, affiliate membership, our operations, activities and events (such as conferences and webinars) and IFIC publications, including IFIC’s Weekly Update newsletter.

It is important that you read this Privacy Policy together with any other privacy notice or notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data.

Changes to the Privacy Policy

This version is effective as of September 18, 2019.

If we make changes we consider important, we will place a notice on our website. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website by clicking on a link for a third party website, we encourage you to read the privacy notice of that website.

2. WHAT is PERSONAL INFORMATION?

Personal information means any information relating to an identified or identifiable natural person.  In general, under Canadian privacy legislation, personal information does not include business contact information (such as an employee’s name, title, business address, telephone number or email addresses) that is collected, used or disclosed in order to communicate with that person in relation to their employment or profession.

3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We generally limit the information we collect and use to your business contact information and your preferences regarding our communication with you so that we can properly manage our relationship with you.  If you apply to join one of our committees, we also collect information about your work experience.  This helps us create committees that are representative of our membership and comprised of individuals with the necessary knowledge and skills.  We only retain this information for the current committee year.

We may collect the following information about you:

• name (first name and last name)
• address
• telephone number
• email address
• job title
• employer name
• work experience

When you visit our website, we also collect:

• information about your computer, including your IP address, the type of operating system and browser you use and your computer’s location;
• what pages you visit on our site and what links you click on; and
• what other sites you have visited recently.

4. ACCOUNTABILITY

IFIC is committed to the responsible handling and protection of personal information. This Privacy Policy provides information about how IFIC handles and protects personal information and how we look after personal information when you visit the ific.ca website (regardless of your location) and otherwise interact with us.

IFIC’s General Counsel is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights regarding the processing of your personal information, please contact IFIC’s General Counsel using the details set out below.

Our full details are:

Full name of legal entity: The Investment Funds Institute of Canada
Name or title: General Counsel
Postal address: 333 Bay Street, Suite 2601, Toronto, Ontario M5H 2R2
E-Mail: privacy@ific.ca

5. HOW DO WE COLLECT INFORMATION ABOUT YOU?

We collect this information in a number of different ways, including from individuals who:

• use our website or who apply for user accounts through them
• are associated with potential or current IFIC member or affiliate organizations or subscribers, including through participation in one of our committees
• a re associated with potential or current suppliers and vendors
• provide us with personal information by interacting and corresponding with us by telephone, email, or otherwise, speakers, attendees, and exhibitors who attend our events, webinars, and conferences.

6. HOW WE USE INFORMATION ABOUT YOU

We collect information about you for the primary purpose of providing our member and affiliate organizations and their employees with our services, including for the following purposes:

• to establish and manage our relationships with our members;
• where we need to perform the contract we are about to enter into or have entered into with you or your employer, including to issue invoices, administer accounts, collect and process payments and otherwise fulfil our contractual obligations;
• to contact and communicate with members and other individuals for the purpose of conducting market research;
• to distribute our publications and invitations to conferences and events to members, affiliate organizations and other individuals;
• to consider the hiring of individuals as employees of IFIC;
• to develop and manage our business and operations, including participation in one of our committees; and
• as permitted by, and to comply with, applicable legal or regulatory obligation.

If it is a necessary part of our relationship with you, we may disclose your information to another company.  For example, we may pass on your name and address to a courier company to complete a delivery.  We will only disclose that information which is necessary to provide our services to you.

IFIC Events and News

We use the contact information of individuals who subscribe through our website or by invitation from IFIC employees.  Distribution of our publications and event marketing draws on a contact database of primarily business contacts that may also include individuals.  If you have subscribed or attended an event in the past, we may combine the information you provided with information submitted on our website.

We may send email communications to individuals in our database to advise of industry developments, distribute our publications or to advise of upcoming IFIC events.  Each email contains an opt-out feature and instructions on how to unsubscribe or manage your email preferences.

We also provide an opportunity to unsubscribe from our publications or opt-out of contact for our event or marketing purposes on an ongoing basis through our website.

Cookies

Cookies are data that is placed on your device when you visit a website in order to track use of the site and improve your user experience.  IFIC may, from time to time, collect personal information about you and your use of our website with cookies as set out in section 2 above.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Service Providers

If we enter into arrangements with service providers or contractors to store, handle or process personal information on our behalf, such as for processing, storage, software support and office services, we will require such third parties by contract or otherwise to provide privacy protection that is substantially similar while the information is being processed or handled by them.

Consent

We obtain consent to the collection, use and disclosure of personal information where required by applicable privacy legislation.  We assume consent to our collection and use of personal information for the purposes for which the information is given when you initiate contact with us or voluntarily provide personal information to us, including by providing your business card to IFIC employees.

We obtain the oral or electronic consent of individuals who subscribe to our publications or who indicate an interest to IFIC employees in receiving such materials.  As set out under IFIC Events and News above, we provide an opt-out opportunity.

7. DISCLOSURES OF YOUR INFORMATION

IFIC shares or discloses information we collect about you when necessary for the purposes set out in Section 6 above. When we share personal information, we do so in accordance with applicable law. Below are the parties with whom we may share personal information and why we share it:

• We may share your personal information with our other members or third parties in the context of the management of IFIC or its operations.
• From time to time we may collaborate with other organizations (including, for example, sponsors, exhibitors, and other businesses that attend our events, webinars, and conferences) in order to carry out our business activities. Occasionally, these arrangements may involve us sharing your personal information with the organization in question.
• We engage third-party service providers who provide various services including IT, administration, consultancy, banking, legal, insurance, and accounting services.
• We will share personal information when we believe it is required, such as:
  • to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
  • in the event of a disposal of our assets or our business (or any part thereof) (including in connection with any bankruptcy or similar proceedings);
  • to protect our rights, privacy, safety, or property, or those of other persons.

8. INFORMATION SECURITY

We have put in place appropriate security measures to prevent information about you from being used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your information to those employees, agents, contractors, and other third parties who have a business need to know.

Our security policies include:

• measures to protect against unauthorized access, use, destruction, or disclosure of personal information;
• appropriate measures and controls, including monitoring and physical measures, to store personal information securely;
• training and informing staff: We train our staff on their privacy and information security obligations so that they are informed about their responsibilities; and
• third-party risk management: We require any third-party service providers with whom we share personal information to protect such personal information in accordance with our security policies and procedures.

We have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. HOW LONG WILL IFIC USE INFORMATION ABOUT ME?

IFIC will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal requirements.

When we no longer need personal information, we seek to securely delete or destroy it.

10. ACCESS TO YOUR INFORMATION

We will give you access to your information upon request, subject to any relevant legal requirements and exemptions.

To maintain appropriate contact information and preferences, we may ask you to update your information, contact information or preferences from time to time.  We encourage you to contact us to correct or amend your personal information if it is inaccurate or requires updating.

If you have any questions about how IFIC manages information about you, please contact us at the contact information set out in Section 4 above.