PRIVACY POLICY

To comply with the federal Personal Information Protection and Electronic Documents Act ("PIPEDA") enacted on January 1, 2004, Aston Hill Financial Inc. (Aston Hill) has adopted this Privacy Policy, which contains policies and procedures to effectively safeguard any confidential information that it has on file or collects in the future, as well as to protect customer information and maximize the experience of all visitors to its website. Aston Hill is committed to protecting the privacy of its clients and customers, and regards this as central to its value proposition. Aston Hill is accountable for compliance with the terms and procedures of this Privacy Policy.

Aston Hill only collects the information it needs to provide and service financial products and services that it believes is essential. Aston Hill will not sell any personal information. Personal information refers to information that identifies clients. It may include information such as a signature, age, marital status, employment history, social insurance number, credit history, home address, personal e-mail address and home telephone number. From time to time, if may also include a financial advisor’s information, beneficiary(ies) name(s), banking information, and investment instructions.

Personal information is obtained primarily from the client, although Aston Hill may also obtain information from other sources with appropriate consent. These other sources may include, but are not limited to, financial advisors or investment dealers, affiliates or subsidiaries, credit bureaus, other financial institutions, contracted third-party service providers, Canadian governments, government agencies and regulators, and any other legally required institutions.

Except as permitted or required by law, Aston Hill limits its collection, use, retention and disclosure of personal information to that which is reasonable and necessary to administer and maintain client accounts, including the processing of transactions, providing transaction confirmations, communicating with clients, issuing account statements, contacting financial advisors and brokers, issuing tax receipts and for tax reporting purposes, understanding client needs, determining eligibility, as well as ensuring that Aston Hill’s records are accurate, protecting all parties from error and fraud, meeting legal and regulatory requirements, meeting anti-money laundering and suppression of terrorism requirements, providing personal information in response to a search warrant, court order or other legally valid request and otherwise complying with the law. Aston Hill may also disclose your personal information to help us collect a debt owed by you.

Aston Hill will identify the purposes for which it is collecting personal information before or when it asks for the information. Aston Hill will also make sure that clients understand why it needs the information by using clear, understandable language. Aston Hill will not use or disclose this information for any other purpose other than those for which it was collected.

Aston Hill is responsible for all personal information in its possession, including information transferred to a third party service provider or agent, so that Aston Hill can provide clients with a product or service. All employees, agents and authorized service providers of Aston Hill are required to protect the confidentiality of personal information.

Aston Hill will keep personal information as long as it is necessary, including updating the product or service or as required by law. Client information on file will be kept for the standard period of seven years from the final closing of the client file, or the date the last service was provided to the client. Clients may, in writing, request that their personal information be amended as appropriate.

Aston Hill maintains physical, procedural and electronic controls appropriate to the sensitivity of personal information, to protect it against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. These safeguards include secure office premises for authorized employees only, passwords, encrypted files, secure networks, and secure databases. Aston Hill also maintains controls for the destruction of personal information that is no longer necessary or relevant for the identified purposes, or required by law to be retained. When documents containing such information are destroyed, erased, or made anonymous, Aston Hill makes sure that any personal information contained in the documents is protected.

Before conducting business with Aston Hill, by investing in or using one of the firm’s products or services, respectively, clients may be required to give verbal, written, electronic, or authorized consent through a representative when giving personal information. Aston Hill will not use this information without first obtaining consent, and will only use it for the purposes stated at the time of collection. Please note that Aston Hill may only alter that personal information required to fulfill the stated purposes. Prior knowledge and client permission are required for the collection, use, or disclosure of personal information.

When Clients agree to use Aston Hill’s services or submit personal information to Aston Hill, either directly or through an authorized representative, clients thereby consent to the firm’s collection from, verification with, and communication to, any third party for the purposes described above. Clients also consent to the collection, use, disclosure, and processing of personal information by Aston Hill’s agents and service providers for the purposes set out in the Privacy Policy.

Clients may withdraw their consent for the collection, use, or disclosure of personal information by contacting Aston Hill’s Corporate Secretary at (403) 770-4811 or via e-mail tdevost@astonhill.ca, at any time. Legal and other requirements may prevent clients from withdrawing consent and the withdrawal of consent is subject to the requirement of a reasonable notice period. The decision to withdraw personal information may limit the ability of Aston Hill to provide its products and services.

Clients have the right to ask about any personal information being held and to see that information, as provided by law. Clients have the right to know how Aston Hill collects personal information, how the firm is using it, and to whom the personal information may have been disclosed. In addition, Aston Hill may provide clients with a list of third parties to whom their personal information was provided.

Clients may access the personal information held about them at any time by contacting Aston Hill with a written request. This information is made available in a variety of formats so it is readily available and easy to understand. Personal information may be kept in electronic or paper format in the offices of Aston Hill, its affiliates, or its third-party service providers. Personal information may also be kept in secure off-site storage facilities. Aston Hill may be unable to provide clients with some information in certain circumstances, including but not limited to situations in which the personal information also refers to other individuals, is subject to legal privilege, contains confidential information, cannot be retrieved using a client’s name or account number, is too costly to retrieve, or is otherwise permitted or restricted by law.

If clients would like to obtain more information regarding the implications of a withdrawal of consent or desire to notify Aston Hill of any changes to their personal information, or if a client believes that any information held about them is inaccurate or incomplete, please contact Aston Hill’s Corporate Secretary at (403) 770-4811 or via e-mail at tdevost@astonhill.ca. If clients feel that Aston Hill has not dealt with their request adequately, clients can follow Aston Hill’s complaint resolution procedures stated below.

Aston Hill is committed to treating everyone with respect and consideration in all dealings. From time to time however, a misunderstanding or error may occur regarding matters of privacy. Accordingly, Aston Hill will act diligently to resolve the problem. Every complaint will be investigated and where a complaint is found to be justified, Aston Hill will take specific measures, including amending its policies and practices, when necessary. Aston Hill will do its best to respond to client complaints, integrate useful suggestions, or resolve client conflicts, as appropriate, in a timely fashion.

If clients would like to make an inquiry, suggestion or complaint regarding Aston Hill’s personal information practices, please contact Aston Hill’s Corporate Secretary at (403) 770-4811 or by e-mail at tdevost@astonhill.ca.

Should clients find that the dialogue, level of respect, attention, service, or proposed solution is unacceptable, clients may contact the following institutions:

Investment Funds Institute of Canada
151 Yonge Street, 5th Floor
Toronto, Ontario M5C 2W7
Phone: (416) 363-2158

 

The Privacy Commission of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3
Phone: (613) 995-8210 or 1-800-282-1376

 

Or in Québec:

The Commission d'accès à l'information
575, rue St. Amable, Bureau 1.10
Québec, Québec G1R 2G4
Phone: (418) 528-7741 or 1-888-528-7741

 

Aston Hill reserves the right to modify or supplement this Policy at anytime. If Aston Hill makes any material change to the Policy, it will update its website to include such changes and post a notice with a link to the updated Privacy Policy. Please read any such notice and the new Policy. Continued client use of Aston Hill’s services will constitute acceptance of the new terms and conditions and grant Aston Hill the right to use the information previously supplied, and any new information, to service client accounts. However, Aston Hill will seek client consent if it desires to use personal information for purposes other than those to which clients have previously agreed.