Canada - FR
U.S. - ENPrivacy Policy
Subject
Letko, Brosseau & Associates Inc. (“Letko Brosseau”, the “firm”, “we”) is an investment management firm that values your privacy and cares about the way your personal information is handled.
As an investment management firm, we collect, use and share information on a daily basis for the purpose of delivering our portfolio management and financial planning services. Privacy is important to us and at the heart of our client relationship. We handle all information, especially personal information, in accordance with the highest ethical standards.
Purpose and Consent
The purpose of this Privacy Policy (the “Policy”) is to help you understand our personal information collection, use, disclosure, and retention practices. By providing personal information to us (whether via our website or client portal, by email, in person or over the phone), you agree to the processing set out in this Policy as well as authorize Letko Brosseau, its third parties and service providers to process your personal information for purposes set out below. This Policy does not apply to, and Letko Brosseau is not responsible for, any third-party websites which may be accessible through links from our website. If you follow a link to any of these third-party websites, they will have their own privacy policies, which you will need to check before submitting any personal information.
Responsibilities and Contact Information
Letko Brosseau is responsible for all personal information under its control and has designated an individual to ensure compliance with this Policy. This Privacy Officer may also designate one or more other persons from the firm to act on his/her behalf.
Contact information for the Privacy Officer:
Isabelle Godin
Letko, Brosseau & Associates Inc.
1800 McGill College Avenue, Suite 2510
Montreal, Quebec H3A 3J6
[email protected]
Principles of this Policy
When you visit our website or use our client portal, and when you contact us, we collect a certain amount of personal information about you.
i. When you visit our website and client portal, we collect information on the use of the website and client portal along with other technical information, such as details on visits to our sites and our online content, or information collected through cookies. For more details, please refer to our Cookie Policy.
ii. When you subscribe to the Letko Brosseau newsletter and our other publications at the bottom of our website, we collect your email address to be able to send you these documents. By providing your email address, you agree to receive our newsletter and other publications.
Your data will be stored on our servers located in Quebec until such time as you remove your email address from our mailing list by clicking on the link at the bottom of the emails you receive or in accordance with applicable legislation or regulations.
iii. When you contact us via the web form on our site, we collect:
- Your surname and first name
- Your email address
- Your province
- Your message
This information is required for us to follow up on your request. Please avoid disclosing any personal information in the free-form text field.
Your data will be stored on our servers located in Quebec and on our CRM software provider servers located outside Quebec. Your data could also be transferred outside Canada under certain circumstances. If you do not become a client, your data will be kept for a period of 24 months following our last contact or in accordance with applicable legislation or regulations.
iv. When you call us, we will ask you for your surname and first name and your province in order to connect you with the person best suited to answer your questions. Depending on your request, we could ask for additional personal information.
v. When you email us a request, we will collect your email address and your message. Please avoid disclosing any personal information in the free-form text field of the email.
Your request will be stored on our servers located in Quebec and on our CRM software provider servers located outside Quebec. It could also be transferred outside Canada under certain circumstances. If you do not become a client, your request will be kept for a period of 24 months following our last contact or in accordance with applicable legislation or regulations. If you become a client, this information will be stored only on our servers located in Quebec.
vi. When you visit our offices, we collect:
- Your surname and first name
- The name of your organization (if applicable)
- The date and time of your visit
This data will be stored on our servers located in Quebec for a period of 24 months, or in accordance with applicable legislation or regulations.
vii. When you become a client, we collect and process various types of personal information in the course of our activities and service delivery, including:
Information to identify you
- Surname and first name
- Date of birth
- Marital status
- Contact information, such as a physical address, phone number and email address
- Information shown on an ID card (such as a driver’s licence or a passport)
- Social insurance number or foreign tax identification number
- Tax residency
- Citizenship
- Occupation, job title, employer’s name and contact information
- Account number
Information to confirm your identity
- Identifier
- Signatures
- Information on your accounts
Financial and other information collected as part of our client relationship acceptance and ongoing monitoring procedures, in keeping with our obligations under the securities legislation and the anti-money laundering legislation
- Income
- Net assets
- Net financial assets
- Investment knowledge
- Risk profile
- Investment horizon
- Purpose and contemplated nature of the business relationship
- Planned use of the account
- Source of funds
- Professional and financial background
- Investment statements from other financial institutions
Financial information required to perform our financial planning services
- Income tax returns
- Notices of assessment
- Insurance policies
Information related to the billing and administration of your accounts under management
- Billing address
- Bank account information
- Payment data
Other information
- Reason for doing business with us;
- Language and communication preferences;
- Information about persons other than yourself: power of attorney, your spouse or common law partner, authorized representatives on your account, designated trusted contact persons, beneficiaries, politically exposed persons or heads of international organizations;
- In the event where the client is a trust or entity, information about the settlors, trustees, beneficiaries, directors, officers and shareholders.
Please note that if you provide personal information on other persons, you must have duly notified these individuals that you are providing their information to us and have obtained their consent to that disclosure.
We may collect this information directly from you. We may also collect your information indirectly through publicly available sources or records. All this information is stored on our servers located in Quebec for a period of 7 years subsequent to the closing of your account or in accordance with applicable legislation or regulations. The physical documents are mainly kept in our premises or in the premises of our providers in Quebec, but could also be kept in our offices in Ontario and Alberta in particular situations.
viii. When you apply for employment, we collect information related to recruiting, such as a resume, information on your education and employment history, details of professional memberships and other information relevant to potential hiring.
This information is stored on the servers of our human resources software provider located outside Quebec for a period of 3 years following their receipt.
We do not knowingly collect information from children under 16 years of age. If you are a minor under 16, please do not provide personal information without the express consent of a parent or guardian. If you are a parent or guardian and you are aware that your children provided us with personal information, please contact us. If we learn that we have collected personal information from minor children under 16 without verification of parental consent, we will take steps to remove that information from our servers.
We use your personal information to provide and improve our services to you. We also use it to meet our legal and regulatory obligations.
We may use personal information in any of the following ways, with your consent or, if applicable, according to a legal basis:
- To understand and assess the needs of our clients and develop appropriate investment strategies;
- To manage and administer our clients’ portfolios;
- To communicate information or reports to our clients, perform billing and accounting;
- To meet our legal and regulatory obligations;
- To make our website more user-friendly;
- To respond to enquiries or other requests from visitors to our website;
- For marketing and business development purposes; and
- For recruitment purposes.
Please note that we do not use automated decision-making processes.
The authorized Letko Brosseau employees have access to personal information only when their duties require such information.
We may also share your personal information with third parties, such as:
- Third-party service providers and/or partners who provide website, application development, maintenance and other services to us. These third parties may have access to, or process personal information as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
- Government authorities and law enforcement agencies when required under applicable legislation. For greater clarity, we may disclose personal information or other information if required to do so by law or in the good faith belief that such action is necessary to comply with applicable legislation, in response to a court order, subpoena or warrant from the government, or to otherwise cooperate with such government authorities and law enforcement agencies.
We will only use personal information to fulfill the primary purpose and applicable legitimate purpose it was collected for, or for a purpose compatible with that primary purpose.
As stated in Section 1 of this Policy, some personal information may be stored outside Quebec and thus be subject to the legislation of other countries and/or States and be accessible to the authorities of such other countries and/or States pursuant to applicable legislation. However, our practices regarding personal information will at all times be governed by our privacy policies and in accordance with applicable rules.
We follow generally accepted industry standards to protect the information submitted to us. We maintain physical, technical or administrative safeguards to protect personal information against accidental destruction, accidental loss, alteration, unauthorized disclosure or access, misuse, or any other form of unlawful processing of the personal information in our possession.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. We also cannot guarantee that such information may not be read, accessed, disclosed, altered or destroyed by breach of any of our physical, technical or administrative safeguards.
Under certain circumstances and in accordance with applicable data protection laws, you have the following rights:
- Right to access your personal information;
- Right to have your personal information corrected;
- Right to have your personal information deleted;
- Right to withdraw your consent to the collection of personal information.
To exercise any of these rights, please contact the Privacy Officer by email at [email protected] or by mail at the address shown at the beginning of this Policy.
Finally, you also have the right to file a complaint concerning our personal information protection by contacting our Privacy Officer. Letko Brosseau will investigate all complaints. If a complaint is well-founded, we will take appropriate action, including the amendment of our policies and practices, if necessary.
For more information on the personal information protection legislation and regulations, please contact the Commission d’accès à l’information:
Quebec City
Bureau 2.36
525, Boul. René-Lévesque Est
Québec, QC G1R 5S9
Telephone: 418-528-7741
Fax: 418-529-3102
Montreal
Bureau 900
2045, rue Stanley
Montréal, QC H3A 2V4
Telephone: 514-873-4196
Fax: 514-844-6170
Toll-free number: 1-888-528-7741
We may change the content of our website and our client portal and how we use cookies without notice and consequently, our Privacy Policy and Cookie Policy may change from time to time in the future. We therefore encourage you to review them whenever you visit our website and our client portal to say informed of how we are processing personal information.
This Policy was last updated September 2023.