Genbridge Family Offices Inc. (“Genbridge”, “we”, ”us”, “our”) is committed to maintaining and protecting the personal information that we collect, use and disclose in the course of providing our services and operating our business. We have created this privacy policy in order to better serve our clients and others by making them aware of their rights regarding the handling of their personal information and to fulfill the requirements of the Personal Information Protection and Electronic Documents Act.

This policy governs our dealing with “personal information”. Generally speaking, personal information means any information that can identify an individual such as age, gender, home or cell telephone number, address, date of birth, education, family status, purchasing and spending habits, investments, tax returns, financial information, religion or ethnic background. In general, personal information does not include business contact information such as your name, title or position, business or business e-mail address, telephone or facsimile number and information available from public records.

ACCOUNTABILITY: We are responsible for all personal information in our possession and control. This includes personal information we receive directly, such as from individual clients or other individuals and personal information we receive indirectly from clients or others. We have designated a privacy officer who is accountable for our compliance with our privacy policy. We are also responsible to ensure that third parties who provide services to our firm and who may have access to personal information are also in compliance with our privacy policy.

NATURE OF INFORMATION COLLECTED: The nature of the personal information we collect and use is dependent upon the information and services requested. Subject to applicable law, it may include:

• name, address, e-mail address, contact details, nature of the client or potential client’s issues, family situation, financial and account information and other incidental information relating to the services we provide
• information relevant to your assets and the use thereof, sources of income and expenditures, including details of property and asset ownership, employment, benefit or tax information and any other information you give to us when consulting with us
• information about you contained in communications within Genbridge and between us and you, whether online or offline
• information we may collect with your consent or as permitted or required by law

PURPOSES OF COLLECTING INFORMATION: We primarily collect, use and disclose personal information to serve our clients. Common purposes for which we collect personal information include:

• evaluating client needs and advising on financial and business matters
• sharing personal information with third parties for the purpose of providing our services. Such third parties may include investment, insurance, legal or accounting advisors provided we have your consent to do so
• helping to prepare investment account open/close/transfer forms and related documents on behalf of our clients
• preparing investment plans and investment performance reports
• communicating with clients concerning the work we do for them or concerning matters that we feel would be of interest to them
• distributing newsletters and other materials to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers
• considering the admission of individuals as employees of Genbridge
• invoicing clients, processing and collecting accounts
• reporting to regulatory authorities or government agencies as required
• providing information to various parties on your behalf including custodians, money managers, bankers, lawyers, government agencies and spouses provided we have your consent to do so

When personal information has been collected and is to be used or disclosed for a purpose not previously identified, the new purpose will be identified and consent obtained prior to its use.

INFORMATION ABOUT SERVICE PROVIDERS: We may collect information about third-party agents, vendors and suppliers who provide goods, services and information to Genbridge. This information would include name and contact information as well as any information (such as banking information) that we need to pay you for your services and other relevant information, such as experience and qualifications. This information is used to assess suitability for particular tasks, to contact them and to pay them for their services.

THIRD PARTY SERVICE PROVIDERS: To the extent we enter into arrangements with service providers to store, handle or process personal information on our behalf, such as for data processing, document storage, software support and offices and financial back room support, our policy will require such parties to provide comparable privacy protection while the information is processed or handled by them.

PRIVACY AND OUR WEBSITE:

Cookies – We may use a browser feature called a ‘cookie’ to collect information when an individual visitor accesses our website. Such information would include non-personal information about you and your use of the site. We would not match or correlate this information with any personal information that you submit on the website. We may use cookies to analyze website usage and for no other purpose. We may use this website information and share it with other organizations with which we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies.

Online Communications – You may choose to voluntarily submit personal information to us for the purpose of asking a question, obtaining information, reviewing or downloading a publication or attending an event. We use such personal information you provide only for the purpose for which you have provided it. If you have provided us with contact information in the past, we may combine the information with information submitted on the website. We provide an on-going opportunity to unsubscribe to contact from Genbridge by contacting us.

E-mail Communications – We may periodically send out e-mail communications to businesses and individuals in our contact database. If you do not wish to receive further materials from us you may ask us not to contact you for this purpose by contacting us.

Links – Our website may contain links to other websites. Operators of such sites may also collect personal information. Please consult the privacy policies for such third party websites. Genbridge is not responsible for the manner in which such third parties collect, use or disclose personal information.

CONSENT: We will obtain consent for the use, collection and disclosure of personal information, either express or implied. We assume that an individual has consented to our reasonable collection and use of personal information consistent with purposes for which the information was given when the individual initiates contact with us or voluntarily provides personal information to us. We also assume that clients who retain us consent to the reasonable collection, use and disclosure of their personal information to our staff for the purposes for which we were retained. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given. If you provide personal information about another person to us, we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this policy. We will only provide information to third parties when we have authorization to do so or where legislation requires that we do so. All personal information is held in strict confidence. We do not make personal information available in any manner to third parties for any purpose such as advertising or other solicitation.

RETENTION: Personal information will be retained for as long as we consider necessary to ensure the accuracy of client records, to enable us to provide quality service and advice to clients and to account to regulatory authorities. When personal information is no longer required, it will be destroyed.

SAFEGUARDS: Personal information is protected with appropriate security precautions against loss, theft or unauthorized use whether on paper or electronically stored. Staff are trained to be aware of the importance of maintaining the confidentiality of personal information. Care is used in the disposal and shredding of personal information. Third party contractors who have access to personal information will be required to confirm that they follow appropriate privacy practices.

ACCURACY: We will make every effort to ensure that personal information is accurate, complete and up-to-date. It is your right to review the information we have on file and the use that has been made of that information. You may challenge the accuracy and completeness of the information and have it amended as appropriate.

YOUR ACCESS TO YOUR PERSONAL INFORMATION: You can ask to view your personal information by contacting our Privacy Information Officer (see below under Challenging Compliance). You can request that corrections be made where you can show that the information we possess is inaccurate.

CHANGES TO THIS POLICY: We reserve the right to change this privacy policy at any time and we will take reasonable steps to advise affected persons of any material changes, if necessary. You should review this privacy policy from time to time to ensure that you are aware of and accept any changes made. The most up-to-date version of our Privacy Policy is available in its entirety on our website. You may contact us at the address, e-mail address or telephone number below to obtain a current copy of this privacy policy.

CHALLENGING COMPLIANCE: Copies of our privacy policy will be made available to all clients and others as requested. The Privacy Information Officer for the office is Cathy Wild. Should you feel we are not in compliance with the above principles, our Privacy Officer will investigate. If a complaint is found to be justified, we will take appropriate measures including, if necessary, amending office policies and practices.

Questions and concerns may be directed to:

Catharine Wild JD
PRESIDENT
direct (905) 331-3743
protectmailcathrine(); email contact

toll free 1-866-611-6637
fax (905) 331-3739

5500 North Service Road, Suite 1002
Burlington, Ontario   L7L 6W6