We consider the protection of personal information to be a foundation of investor trust and a sound business practice. We will always treat your personal information with the upmost care and the highest degree of respect. The purpose of this Policy is to inform our business contacts investors dealer representatives and other individuals we deal with (“you” or “your”) how we collect use disclose and protect your personal information. Personal information is information about an identifiable individual as more particularly described under applicable privacy legislation. This Policy applies to our collection use and disclosure of personal information in Canada.
Collection use and disclosure of personal information
From time to time we receive use and retain personal information from and about individuals including our business contacts our investors and our dealer representatives for the purpose of:
- meeting legal regulatory insurance security processing and statutory requirements
- managing and developing our business and operations including maintaining business records for reasonable periods and defending and bringing legal actions
- managing administering collecting or otherwise enforcing accounts;
- developing new and enhancing existing services and product offerings
- building relationships
- otherwise with consent or as permitted or required by law
Unless you opt-out we may send you information about products and services that may be of interest to you.
The type of personal information we may collect includes:
- name address email address telephone number and other contact information;
- website usage history
- such other information we may collect with your consent or as permitted or required by law.
We may disclose personal information to third parties with your consent where permitted or required by law or as outlined below.
We may disclose personal information as described above in the following circumstances:
- With our associated companies for the purpose of product development and marketing.
- As necessary to meet legal regulatory industry self-regulatory insurance audit and security requirements.
Unless you opt out Bloom may disclose personal information to third parties for marketing purposes.
Service Providers. We may transfer personal information to outside agents or service providers (including to our affiliates acting in this capacity) that perform services on our behalf including mailing billing marketing information technology and/or data hosting or processing services or similar services or otherwise to collect use disclose store or process personal information on our behalf for the purposes described in this Policy. Some of these service providers or affiliates may be located outside of Canada including in the United States and your personal information may be collected used disclosed stored and processed outside of Canada including in the United States for the purposes described in this Policy. Reasonable contractual other measures we may take to protect your personal information while processed or handled by these service providers are subject to applicable foreign legal requirements including lawful requirements to disclose personal information to government authorities in certain circumstances.
Business Transactions. We may use and disclose personal information in connection with the proposed or actual financing securitization insuring sale assignment or other disposal of all or part of our business or assets for the purposes of evaluating and/or performing the proposed transaction. Successors or assigns of our business or assets may use and disclose your personal information for similar purposes as those described in this Policy.
Bloom collects uses and discloses your personal information with your consent except as permitted or required by law. Consent to the collection use and disclosure of personal information may be given in various ways. Consent can be express or implied. You may provide your consent in some circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose such as by using an “opt out” option provided if any. Generally by providing us with personal information we will assume that you consent to our collection use and disclosure of such information for the purposes identified or described in this Policy if applicable or otherwise at the time of collection.
You may withdraw all or part of your consent for us to collect use and disclose your personal information within certain contractual and legal restrictions and subject to reasonable notice. If you withdraw consent however we may be limited in the services or products that we can provide to you.
Security measures for the protection of personal information
We maintain security policies procedures and controls to protect the personal information we receive against loss or theft. We have safeguards in place to prevent unauthorized access disclosure copying use and modification for both hard copy information and electronically stored information.
Such safeguards and controls include but are not limited to the following:
- Physical site access control
- Network security
- Virus protection & intrusion detection
- Regular backup
- Procedural safeguards/controls
We test and update our safeguards and controls as appropriate.
Our employees agents and authorized service providers are required to protect the confidentiality of personal information. Access to personal information is restricted to those employees agents and authorized service providers who require it to do their job.
Access To and Accuracy of Personal Information
Bloom may establish and maintain a file of your personal information for the purposes described above which will be accessible at our offices. Except in limited circumstances where legal reasons prevent us from so doing access to your personal information that we hold may be provided. If you wish to request access to or correction of your personal information in our custody or control you may write to the below address attention Privacy Officer. We may take reasonable steps to verify your identity before granting access or making corrections.
Questions and Complaints
Privacy-related inquiries and complaints may be registered by contacting our Privacy Officer:
by phone at: 416-861-9941;
or by regular mail addressed as follows:
Bloom Investment Counsel Inc.
150 York Street
Toronto Ontario M5H 3S5
Attention: Privacy Officer
We may occasionally update this Policy including in order to reflect changes in company policy or changes to privacy legislation. If we intend to use or disclose personal information for purposes materially different than those described in this Policy we will make reasonable efforts to notify affected individuals if necessary including by revising this Policy. It is important for you to periodically review this Policy by visiting our website at: bloomfunds.ca Your continued provision of personal information or use of our services following any changes to this Policy constitutes your acceptance of any such changes. This Policy is effective as of March 2019.