This policy describes CC&L Financial Group’s (and its affiliates’) practices concerning the collection, use, and disclosure of personal information in the course of our business, including when you visit our website (the “Site”) or otherwise interact with us online or offline, whether as a client, employee or otherwise. “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to you.
This policy (“Policy”) applies to the operations of CC&L Financial Group and its affiliates (including your asset manager) and to all of the services and products we offer our clients. Reference throughout this policy to “we”, “our”, “us” and “CC&L Financial Group” means Connor, Clark & Lunn Financial Group Ltd. and its affiliates.
What Personal Information We Collect – We collect information about you in various ways, including when you:
- visit and interact with our Site;
- request information about our products or services;
- provide us with information (a) so that we can deliver our products and services to you, (b) through your managed account agreement or investment management agreement with us, or (c) through subscription documents;
- submit an employment application;
- share your information with us at a conference or other event; or
- when you voluntarily provide information to us through another means.
We also collect personal information about you from third party sources and publicly-available sources. We will continue to collect personal information from the same sources. Such information includes, in addition to unstructured personal information you may voluntarily provide to us, without limitation:
- Information establishing your identity, such as your name, address, phone number, work position, employer, email address, date of birth, nationality, social insurance or passport or other identification number (for tax purposes), account numbers, account name and password, and other similar information we use to establish your identity when we provide services to you or when you apply for a job with us;
- Protected class information, including age, familial composition, military or veteran status;
- For individuals, information about your employment, income, risk tolerance, financial and investment qualifications, assets, tax-related information and the intended nature of your investment (as applicable);
- For entities, information about your business name, address, phone number, email address, industry type, entity type, date and jurisdiction of formation, tax identification number, details on the beneficial owners, authorized persons and directors (as applicable);
- For trusts, information including settlors, trustees and beneficial owners, address, phone number, email address, industry type, details on authorized persons;
- Technical information such as IP address, device and browser identifiers, operating system, your browsing and search history on our Site, and information regarding your interaction with our Site and our advertisements;
- Geolocation data and other similar information;
- Commercial information such as records of products purchased or considered, consuming histories or tendencies;
- Transactional information on transactions within a private investment fund (each a “Fund”) or managed account, including account balances, investments, redemptions and management fees and performance allocations;
- Information about your educational history, degrees and credentials;
- Name and location of current or past employers, positions and titles held;
- Recordings of client service or account management calls; and
- Additional information to meet our legal and regulatory obligations.
How We Use Your Personal Information – We use your personal information for a variety of purposes, including to: (a) verify your identity; (b) manage your investments and generally provide you with financial advisory and investment management services; (c) communicate with you; (d) understand your financial situation and goals; (e) manage our risks and operations; (f) advertise and market our services to you, including by providing you with information about our company and our affiliates; (g) facilitate your investment in a Fund or managed account (as applicable) and the management and administration of your investment on an ongoing basis which are necessary to fulfill all contractual and regulatory obligations related to your investment, including without limitation the acceptance and processing of subscription documents and redemption and transfer requests; (g) meet our regulatory and legal requirements, including satisfying information requests from regulators and other organizations or individuals who are legally entitled to make such requests; (h) assist in reviewing and processing employment applications and (i) assist in our business, such as for statistical analysis and research or to inform our investment strategies.
Additionally, we use personal information, including about your use of our Site, to monitor or improve our Site; for internal business analysis; to prevent fraud or activities that are illegal; and to protect our rights and the rights and safety of our users or others.
We also use log file information for functionality, security, account management and usage analytics. Most browsers automatically collect information like your IP address, device type, screen resolution, operating system version, internet browser type and version, and time of visit or log-in and store it in log files.
Sharing Your Information – We are part of CC&L Financial Group, which combines a number of different investment teams with unique and diverse investment management expertise. CC&L Financial Group provides accounting, marketing, legal, compliance and other back-office support functions to its affiliated investment teams. Your personal information may be shared with CC&L Financial Group. This information sharing allows us to more efficiently provide: (a) investment management and client relationship services; (b) investment and tax reporting; and (c) crime and fraud prevention, suppression and detection. It also allows us to meet our legal, financial and reporting obligations and facilitate the employment and recruitment process.
We may also use and may disclose personal information to outside or affiliated service providers, administrators or agents to perform services on our behalf, including custodial, trustee, legal, accounting, customer relationship management (CRM), marketing, website operation and analysis, IT services providers, background check providers, recruiting agencies, analytics, mail distribution, data processing or data security services and cloud-based data storage services. These service providers may at times be responsible for processing or handling personal information, and are only provided the information necessary to perform the services they have been engaged to provide. Our service providers may process or store personal information outside of your jurisdiction, and may disclose information in response to demands from regulatory or law enforcement authorities in those jurisdictions.
We may also share your personal information:
- To respond to valid and authorized information requests;
- As permitted or required by law;
- To help prevent crime, fraud, data security vulnerabilities, money laundering and terrorist financing;
- When we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities and ombudsmen;
- In the event of an actual or contemplated sale, merger, reorganization of our entity or other restructuring; or
- In situations where we have your consent.
When we provide information in response to a legal inquiry or order that we believe to be valid, we disclose only the information that is legally required.
Keeping Your Information Accurate – We make reasonable efforts to ensure the information we have about you is accurate, up-to-date and complete. Given that we make decisions based on the information we have, we encourage you to help us keep your information current.
Having accurate information about you enables us to give you better service and minimizes the possibility that out-of-date information may be used to make a decision which impacts you. While we have procedures and practices in place to help us maintain the accuracy of your information and we rely on you for such information, no system is perfect and we may not be able to identify all inaccuracies. You can help by keeping us informed of any changes such as a change of address or phone number. Please let us know if any of your information on file is inaccurate, incomplete or out of date.
We will retain your personal information in accordance with our data retention policies. We will generally retain your personal information for as long as required for the purposes described above, or for such longer period if required under applicable law. This period of time extends beyond the end of our relationship but only for as long as is necessary for us to meet our legal and regulatory requirements and for as long as it is necessary for us to respond to any outstanding matters. Some non-specific information may be retained for statistical analysis and other internal purposes. When your information is no longer needed we have procedures to destroy, delete or convert it to an anonymous form.
How We Keep Your Personal Information Secure – We implement and maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include appropriate administrative, physical and technical safeguards to protect the security, confidentiality and integrity of personal information. We intend for these commercially reasonable steps to protect personal information against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, however, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.
International Transfers of Personal Information – We may store your personal information on servers located in Canada, the UK or elsewhere, or on cloud-based servers. In order to provide you with the services described above, we may disclose your personal information to recipients located in countries outside Canada and the UK which may not have data protection laws equivalent to those in Canada and the UK. In such cases, any transfers shall be made in accordance with the requirements of applicable data protection laws, including putting in place standard contractual clauses with recipients if applicable. You can request a copy of such safeguards by contacting [email protected].
Your Consent and Your Choices – By establishing an account with us, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described in this policy. Your decision to withhold information or withdraw consent with respect to our use or disclosure of your personal information may prevent us from taking you on as a client or employee, or continuing to work with you as a client or employee (as applicable). You can withdraw your consent at any time, subject to the requirement of reasonable notice and any legal or contractual restrictions, by writing to us.
Changes to This Policy – We will review and update this Policy periodically. We will notify you of material changes to it as required by law by posting a notice on our Site that the Policy has been updated and by updating the date of the Policy.
Personal Information of Minors – Our products and services are not directed to minors under the age of 13 and we do not have actual knowledge that we collect personal information from such minors. We do not knowingly sell personal information of minors under age 16.
Third Party Websites and Social Media Buttons – Our Sites may contain social media buttons or links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on those social media platforms or third-party websites. We recommend that you review the privacy policies posted on any platform or website that you may access through our Sites.
California Privacy Rights
The California Consumer Privacy Act (CCPA) gives California residents certain rights described below with respect to their personal information. This section of the policy includes disclosures required under CCPA for California residents.
Please note that CCPA rights do not apply to personal information of our individual investor customers subject to the Gramm-Leach-Bliley Act (a federal privacy law that applies to financial institutions).
Your Right to Request Disclosure of Information We Collect and Share About You – We are committed to ensuring that you know what personal information we collect. To that end, you can ask us for any or all of the following types of information regarding the personal information we have collected about you in the 12 months prior to our receipt of your request:
- Specific pieces of personal information we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which such personal information was collected;
- Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
- Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
- The business or commercial purpose for collecting or selling your personal information.
Your Right To Request Deletion of Personal Information We Have Collected About You – Upon your request, we will delete the personal information we have collected about you, except for situations where the CCPA authorizes us to retain specific information, including when it is necessary for us to provide you with a good or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; or comply with or exercise rights provided by the law. The law also permits us to retain specific information for our exclusively internal use, but only in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with us. We will act on your deletion request within the timeframes set forth below.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Allowing You to Exercise Your Rights – Non-Discrimination: If you exercise any of the rights explained in this policy, we will continue to treat you fairly. If you exercise your rights under this policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Verification of Identity – Access or Deletion Requests: We will ask you for identifying information and attempt to match it to information that we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to your request. We will notify you to explain the basis of the denial.
Authorized Agents – You may designate an agent to submit requests on your behalf. The agent must be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:
- Requests to Know or Delete Personal Information: If the agent submits requests to access, know or delete your personal information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
- Requests to Opt Out of Sale: If the agent submits a request to opt out of the sale of your personal information, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
California Do Not Track – Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browsers’ do not track signals.
European Economic Area and United Kingdom Privacy Rights (“GDPR Policy”)
This GDPR Policy will apply, in addition to the Policy above, to (a) individuals located in the European Economic Area (“EEA”)/United Kingdom (“UK”) whose personal information is processed by CC&L Financial Group affiliates and (b) individuals whose personal information is processed by CC&L Financial Group affiliates located in the EEA / UK. For the purposes of EEA/UK data protection laws, we are the controller of your personal information. There are also times when an administrator will act as a data controller.
The types of personal information collected, the purposes of processing and the recipients of personal information are set out in the Policy above. The legal basis for the processing of your personal information, for the purposes of EEA and UK data protection laws, is (a) when it is necessary for the performance of any contractual relationship with us, (b) when it is necessary in order for us to comply with our legal or regulatory obligations, and (c) where in our legitimate interests for the purposes described in this Policy.
Your Rights – You have the right to:
- be informed about your personal information that we and/or an administrator collects from you, uses, and retains, which this Policy seeks to do;
- obtain confirmation from us that your personal information is being collected, used, and retained as described above and to access your personal information held by us;
- have your personal information corrected if it is inaccurate or incomplete at any time;
- erasure, or the right to be forgotten, which means you can request deletion or removal of any of your personal information we hold about you at any time, subject to our or an administrator’s rights to retain your personal information for legitimate business purposes;
- restrict us collecting and using your personal information, which means we can continue to store your personal information but cannot further collect or use it in any way;
- request the transfer of your personal information to a third party (also known as data portability);
- object to us collecting, using or retaining your personal information where this is based on your legitimate interest or the performance of a task in the public interest, or to direct marketing even if otherwise legally permitted; and
- withdraw your consent to the use of your personal information at any time, as described below.
We will respond to your request in writing, or orally if requested, as soon as practicable and within the time frame prescribed under applicable data protection laws. We may request proof of identification to verify your request.
Withdrawal of Your Consent – You have a right to withdraw your consent to the processing of your personal information where such processing is based on your consent. Such withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.
Consequences of Not Providing Personal Information – Where we require your personal information to comply with anti-money laundering or other legal requirements or to perform a contract with an investor, failure to provide this information will mean that you will be unable to be accepted as an investor and/or may be mandatorily redeemed from a Fund if you are already an investor.
You have the right to lodge a complaint with your local supervisory authority if you consider that the processing of personal information relating to you carried out by us infringes the GDPR.