Introduction
Tall Oak Capital Advisors Inc. (“we”, “us”, “our”, the “firm” or “Tall Oak”) is committed to protecting your privacy and the confidentiality of personal information that is provided by you to us.
This Privacy Policy sets out the information practices of the firm, including what kind of information is collected, how the information is used and with whom this information might be shared.
Accountability
We are responsible for all personal information provided to us by clients under our control. Employees involved in collecting, disseminating and maintaining personal information are trained in all aspects of this Privacy Policy. Tall Oak’s Chief Compliance Officer, in his capacity as the firm’s privacy officer, is responsible for the implementation of this policy. If you have any questions or concerns regarding our Privacy Policy, you may address them to:
Tall Oak Capital Advisors Inc.
140 Fullarton Street, Suite 1001
London, Ontario N6A 5P2
Phone: 519.601.9150
Email: compliance.team@talloakcapital.ca
Accuracy
We take effort to verify that your personal information is as accurate and complete as necessary for the purposes for which it is collected, used and disclosed. From time-to-time, you may be asked to verify the accuracy of the information we have collected in respect to you.
Personal Information
Personal Information includes factual or subjective information, recorded or not, about an identifiable individual. This includes information such as: age, name, ID numbers, income, financial information, ethnicity, social status, etc. A variety of other personal information pertaining to the operation of an investment account (security purchases and sales, deposits, withdrawals and security transfers) may also develop over time.
For legal entities such as businesses, trusts, partnerships or estates, we will also collect information about the legal structure of the entity and information about those individuals authorized to act on the entity’s behalf. Where necessary, we will collect information in regard to the beneficial owners and authorized signatories of these legal entities.
Personal information has to be protected regardless of its characteristics or its form, whether written, graphic, audio, visual, computerized or any other form.
When you apply to open an account with us, we may collect various personal information about you, including, without limitation:
- your legal name, address, occupation, telephone numbers and e-mail addresses;
- your date of birth;
- your Social Insurance Number;
- your identification in the form of a passport or valid driver’s license or a recent utility bill to verify your address;
- details of your financial circumstances, including your income, your assets and liabilities, any legal undertakings and guarantees, your dependents, residency, citizenship and tax status;
- details of your investment experience, your goals and financial planning objectives;
- whether you may be a domestic or foreign politically exposed person or the head of an international organization (or fall under any other relevant categorization) for purposes of applicable anti-money laundering and anti-terrorist financing legislation; and
- your insider status, if any, in respect of publicly-listed entities.
Purpose of Information Collection
We collect personal information for various purposes, including to:
- meet the account opening requirements of the custodian(s) of your account, as well as any relevant financial institution;
- establish the basis of developing an investment policy statement with you further to which your designated assets will be managed by the firm;
- document which other persons, entities or professional advisors, if any, may have access to your account information and/or may be authorized to provide investment instructions to us on your behalf;
- provide our services to you, which in addition to investment management, may include the delivery of other services as agreed to between us from time-to-time, as well as preparation and delivery of documentation to you, including account statements and other reporting, as the case may be;
- allow the firm to satisfy itself about the information it reports on to governmental or regulatory agencies, including under securities, tax and/or anti-money laundering and anti-terrorist financing legislation;
- allow the firm to prepare and distribute any information that may be required to be provided to Canadian federal and other local or foreign tax authorities, as the case may be;
- report to securities regulators, as may be required, about the investment practices and operating procedures of the firm and to allow such regulatory agencies to conduct periodic compliance audits of the firm; and
- manage and assess the risks posed to the firm.
Consent
By retaining our services, you will have consented to our collection of your personal information and to our disclosure of this personal information to certain third parties as outlined in this Privacy Policy and for the purposes set out in it.
You may withdraw your consent at any time, subject to legal or contractual restrictions. We will inform you of the consequences of such withdrawal, including the possibility that we may not be able to provide a product or continued services to you. If you choose not to consent, we will record the decision in our file.
We will typically collect personal information from you as part of the process by which accounts are opened or investment policy statements are developed and reviewed. We may also collect additional personal information from you throughout the course of our relationship. Information may be collected through personal meetings, telephone discussions, e-mail and/or facsimile transmissions and also from third party service providers involved in supporting our services.
Tall Oak may use your e-mail address to communicate with you about privacy issues you raise and may send you information about services it offers or may offer in the future based upon an analysis of the personal information you provided. E-mails we send over the internet are generally not encrypted.
In limited circumstances, we have the right (or obligation) to collect, use or disclose personal information without your knowledge and consent. These circumstances include: (i) when we have reasonable grounds to believe the information might be useful when investigating a contravention of a federal, provincial or foreign law, (ii) during an emergency which threatens an individual’s life, health or security, or (iii) when mandated to provide such information by any federal, provincial or foreign law or regulation.
When information is being collected for the investigation of a potential breach of contract, the prevention or detection of fraud, or for law enforcement purposes, seeking consent might defeat the purpose of the information collection. Similarly, seeking consent may be impossible or inappropriate when you are a minor, seriously ill or otherwise incapacitated.
Limits to Collection, Use and Disclosure
We limit the collection of your personal information to what we need in relation to the purposes identified to you.
We limit the use of your personal information to the purposes we have identified to you. This means that we cannot use your personal information for other purposes without your consent, except as required by law. We cannot disclose your personal information to anyone except with your consent or as required by law.
Your personal information is only accessible to certain authorized persons, and only to the extent necessary to perform their duties. Tall Oak does not sell, rent or lease its customer lists to any third party.
Tall Oak may disclose and share your personal information with its affiliates, as well as with certain service providers or agents, certain of whom may be located outside of Canada, the whole to ensure the proper administration of your accounts with us or to provide you with the products or services you require. This may include, without limitation: (i) custodians (including Raymond James), our portfolio management systems providers (including Croesus), transfer agents and brokers, (ii) financial service providers used to finance or facilitate transactions, including banks, and (iii) other service providers to the firm, such as fund administrators or record-keepers, transfer agents, as well as accounting, audit, account statement, tax and legal service providers.
We also may disclose and share your personal information with governmental or regulatory authorities and/or agencies when so required including under applicable laws or regulation.
If we sell the firm or enter into an acquisition or merger agreement with another company, we may release the information we have about you to prospective purchasers. We will require any prospective purchaser to protect the information provided consistent with the firm’s privacy policies and practices.
You have the right to know, on request, to whom your personal information was disclosed. Only in rare instances are we prevented by law from making such disclosure. We maintain accurate records, recording to whom we disclose personal information and in what circumstances it was disclosed.
Safeguards
Your personal information is maintained on our secure computer networks and office files. Your information may also be stored on a secure off-site storage facility. A variety of security measures are in place to reduce the possibility of theft of personal information or accidental disclosure.
Request for Access to Information and Amendments
You have the right to be informed whether we hold personal information about you and to see that information. You also have the right to enquire as to how we collected your information, how we used it and to whom it may have been disclosed. You also may enquire as to the accuracy and completeness of your personal information. You may also request that we update any personal information we have on file in your regard. You may also express any concerns at no additional cost to you. We will respond to any request made by you within a reasonable time. All client concerns shall be documented and maintained in a written (and electronic) file. We will use commercially reasonable efforts to promptly determine and rectify the problem.
We have the right to refuse access to personal information by you if: (i) the information is protected by legal privilege, (ii) the information was collected for purposes related to the detection and prevention of fraud, (iii) the information was generated in the course of a formal dispute resolution process, (iv) granting access might reveal confidential commercial information, or (v) it is reasonably expected that such personal information might lead to the threatening of the life or security of another individual.
In cases where we hold medical information about you, we may refuse to provide you with direct access to this information and may instead request that a health care professional be designated to provide the information to you.
Any request for access to information or request for amendment must be sent to the following address:
Tall Oak Capital Advisors Inc.
140 Fullarton Street, Suite 1001
London, Ontario N6A 5P2
Phone: 519.601.9150
Email: compliance.team@talloakcapital.ca
Tall Oak reserves the right to revise or amend this Privacy Policy from time-to-time.