CO-OPERATORS FINANCIAL INVESTMENT SERVICES INC. PRIVACY POLICY

Updated July 4, 2024: We recently reviewed and updated our privacy policy. Changes clarify how we operate your accounts and reflect new privacy requirements in Québec.

In this privacy policy, "Co-operators", “we”, "our", "us" and “CFIS” means Co-operators Financial Investment Services Inc. This policy governs in general terms how we collect, use, retain, and disclose your personal information and that of any other person(s) whose personal information is collected by us or that is disclosed to us as part of your relationship with us, in accordance with the requirements of applicable legislation and our continuing commitment to privacy.

Overview

At Co-operators, we recognize and respect the importance of privacy. When you do business with us, we will ask you for your consent to collect, use and disclose your personal information. We will explain the purpose for which we will collect, use and disclose your personal information, and we will not share your personal information except with your consent or as required or permitted by law.

You can withdraw your consent at any time. You may access and correct, if needed, the personal information we have about you by sending us a request in writing to privacy@cooperators.ca or the mailing address below.

Your personal information may be accessed by our employees and other authorized personnel who need to use it to perform their duties. This may include third-party service providers, including those that are located outside of Canada. If your personal information was collected, used or disclosed within the province of Québec, it may be communicated outside Québec. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with our third-party service providers.

With your permission, we may tell you about products and services that may be of interest to you. You can tell us what information you want to receive from us, and you can change your preferences at any time.

Our commitment

Our client relationships are based on a foundation of trust. We are committed to protecting the privacy, confidentiality, accuracy, and security of the personal information collected, used, retained, and disclosed while doing business with you. We are responsible for all personal information under our control, whether supplied to us directly by you or by a third party or that we have provided to our third-party service providers for processing. We take our privacy obligations seriously and strive to implement privacy practices guided by the highest standards of ethical conduct.

We do not sell your personal information.

Your consent

We will obtain your consent prior to collecting, using, retaining, or disclosing your personal information for specific purposes, except where we are specifically permitted by law to collect, use, retain or disclose your personal information without your consent such as when we are required by law to disclose your personal information to a government institution. If we wish to collect, use, retain or disclose your personal information for a new purpose, we will seek your consent before doing so.

Your consent can be implied or express. Implied consent refers to consent that is inferred from your actions. For example, when you provide personal information to transfer your investments to Co-operators, we would infer that you are consenting to our collection and use of the personal information you provide to action that transfer. Express consent is consent that is given specifically, either verbally or in writing. When we ask for your express consent, we will explain what personal information we need, what we will use and disclose it for, and who we will share it with.

Personal information we may collect

We may collect personal information directly from you, and from third parties as described in this privacy policy. When you provide us with personal information about any other persons, it is your responsibility to ensure that you have the approval from these persons to provide their personal information to us and to allow us to collect, use and disclose their personal information for the identified purposes.

We only collect personal information that we need for the specific purposes described in the consent provided by you.

Depending on the type of products or services we provide to you, and the consent that you have provided, we may collect the following personal information:

Name, Mailing Address, E-mail Address, Telephone Number

This information helps us identify you and allows us to send you statements and other important notices. It also allows us to communicate with you to obtain instructions and respond to your requests and enquires.

Date of Birth & Identification numbers (e.g. drivers’ licence)

This helps us to fulfill our legal obligation to ascertain your identity and helps protect you and us from error, identity theft and fraud. We may also use this information to determine your likely interest in other products and services that we offer.

Social Insurance Number

Under the Income Tax Act (Canada) we are required to obtain your social insurance number if there are tax implications to your financial transactions.

Employment and Financial Information

We collect this information to better understand your unique financial situation and investment needs and to help us provide appropriate investment advice.

Other Information

We may collect other information about you as required in connection with the products and services requested, such as citizenship or residency information, marital status, spousal information, beneficiaries, trusted contact, legal documents (death certificates, court orders, powers of attorney etc.) which we use to comply with our legal and regulatory obligations. Co-operators does not collect credit file information for the purposes of administering our mutual fund products and services.

Purposes for which we may collect, use, or disclose your personal information

The following are some of the purposes for which we may, with your prior consent, collect, use, or disclose your personal information:

1. To conduct a needs analysis, including:
   • determining and evaluating your investment needs
   • conducting financial planning
   • determining the suitability of and recommending investment products and services tailored for you


2. To establish and operate your accounts
   • opening and approving of new accounts
   • recording of the information and instructions you provide, including audio recording
   • processing your purchase and sale instructions
   • communicating notices, demands, reports, confirmations, periodic account statements and annual tax statements to you


3. Detecting, investigating, suppressing, and preventing errors and omissions and/or fraud


4. To administer your account, including:
   • confirming your identity
   • communicating with you regarding products and services you have with us
   • ensuring quality customer service
   • resolving complaints and disputes
   • training and development of staff
   • processing of digital signature
   • issuing surveys
   • periodically reviewing your investment needs and determining the suitability of our products and services for you
   • performing monitoring and audit activities


5. To comply with regulatory obligations set out in applicable federal and provincial laws. In certain instances, we may be compelled to disclose information in response to a legally valid demand, enquiry, proceeding or other order. In these cases, we take steps to ensure the request is valid and we only disclose the specific information necessary to satisfy the enquiry or order


6. To conduct business analysis and data analytics, including:
   • using your personal information in conjunction with advanced analytics and artificial intelligence techniques to perform business analysis and data analytics, for example to enable us to detect patterns of fraud to reduce its impact
   • to use insights from your interactions with us to be proactive in our service and to resolve complaints


7. To communicate with you across multiple channels, including by email, SMS messages and telephone calls, including:
   with your consent, advertising and marketing our products, services, offers, contests, or community events that may be of interest to you, or to conduct market research or surveys


8. To test and troubleshoot our internal systems, and assess and enhance our security safeguards, business planning, and management, including assessing resource needs

Those we may disclose personal information to

We may disclose your personal information to others where necessary and appropriate, but only if we need to for the purposes that you have consented to. We may disclose your personal information to the following:

• third parties who provide services to us or perform services on our behalf, including, but not limited to, payment processors, marketing agencies, electronic signature processors, data processors, electronic storage providers, voice verification services, investigators, engineers, and disaster recovery services providers


• our independent financial advisors and their staff


• third parties as needed to provide you with the product or service you have requested from us


• fraud detection & prevention organizations


• other companies within the Co-operators group of companies


• parties involved in the sale, acquisition, disposition, merger, or amalgamation of companies or as part of other business arrangements, such as joint ventures


• securities authorities (such as the Canadian Investment Regulatory Organization, and the Canadian Investor Protection Fund). These organizations require access to personal information of current and former clients, employees, agents, directors, officers, partners and others for regulatory purposes including surveillance of trading-related activity, sales, financial compliance, trade-desk review and other regulatory audits, investigation of potential regulatory and statutory violations, regulatory databases, enforcement or disciplinary proceedings, reporting to securities regulators, and information- sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing


• government agencies, as required by law (for example for periodic regulatory filing, reporting in accordance with anti-money laundering or unclaimed property requirements or under other lawful authorities, and for income tax purposes)


• external auditors, legal counsel and other professionals


• any other parties you authorize

Automated Decision Making (Québec Only)

To achieve our business purpose of providing financial security for Canadians and our communities, we may use technologies that incorporate automated decision making, while keeping your personal information safe.

We will inform you if we make a decision based exclusively on automated processing of your personal information, no later than at the time we inform you of such decision.

Where we are making a decision based exclusively on automated decision making, at your request, we will explain the personal information used in such automated decision making process to make such decision, and the reasons, principal factors and parameters that led to the automated decision.

Where we are making a decision based exclusively on automated decision making, you can contact us by e-mail at privacy@cooperators.ca to correct any personal information used to render such decision.

Profiling and Cookies

We may use technology that includes functionality that, if activated, would allow us to identify, locate or profile you. If we do so, and you are located in the Province of Québec, we will provide you with the means to activate such functionality.

Find out how we use cookies, web analytical tools and similar technologies.

You have a choice

We want you to know that you can always:


• decline to provide us with some of your personal information. If you do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so


• withdraw your consent at any time by contacting us, and, subject to any applicable legal or contractual restrictions which we must fulfill, we will cease to collect, use, retain and disclose your personal information after the withdrawal of your consent. If you withdraw your consent, or do not provide us with all necessary personal information, we will still do our best to provide you with our products or services, however it may not be possible to do so.


• update your marketing permissions and contact preferences at any time by contacting us. You can also use the unsubscribe link included in our commercial electronic messages.

Retention of Information

We retain personal information only as long as is necessary to fulfill the purposes for which it was collected, unless authorized or obligated by applicable laws to retain personal information for a longer period.

Safeguards

We are committed to protecting your personal information. We take the security and confidentiality of your information very seriously. Find out more about our security practices.

All our employees and financial advisors must abide by our Code of Ethics and Business Conduct and annually attest to doing so. In addition, we have developed and implemented privacy guidelines and practices which are reviewed, monitored and audited periodically.

Your personal information may be accessed by our employees and other authorized personnel who need to use it to perform their duties. This may include third party service providers, including those that are located outside of Canada. If your personal information was collected, used or disclosed within the province of Québec, it may be communicated outside Québec. In all cases, our employees and other authorized personnel, whether or not they are in Canada, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy policy and practices, as well as with Canada’s privacy laws and regulations. They could also be required by law to give your personal information to courts, governments or regulators, both inside and outside of Canada. If your personal information is transferred outside of Canada, your personal information may be subject to the laws of other countries. To protect your personal information, we ensure that appropriate privacy and security requirements are included in our contracts with third party service providers.

Accuracy

We make every effort to ensure that the personal information we collect is accurate, complete, and as up to date as possible to properly satisfy the purposes for which it is to be used. It is important that you promptly notify us of any change to your contact information. If we are unable to verify your personal information or contact you, we may be limited in our ability to provide you with our products and services.

Your Rights

Access to and Correction of Personal Information

Upon written request, and confirmation of your identity, we will provide you access to the personal information that we have obtained about you while doing business with you. However, there may be instances where we may, in accordance with applicable privacy laws, restrict access to your personal information, including where such information is subject to legal privilege, contains confidential commercial information, or relates to other individuals. If applicable, we will advise of the reasons for restricting access and inform you of any recourse that you may have. A response to your request will be provided within 30 days after we receive a written request, and we have sufficient information to permit us to identify the existence of the personal information. In Alberta, a response will be provided within 45 days after receipt of a written request, and sufficient information to permit us to identify the existence of the personal information. Where permitted by applicable law, if we need more time to fulfill your request, we will notify you of such delay.

Effective September 22, 2024 for individuals living in the province of Québec: You can request a copy of your computerized personal information that we have collected about you. This computerized information will be transferred in a structured and commonly used technological format either to you or to a person or organization designated by you and who is authorized by law to collect such information.

If you exercise these access rights, we may charge you a reasonable fee for the transcription, reproduction or for the transmission of the personal information.

If you believe that the information in our files is inaccurate or incomplete, you have the right to ask us to correct it. We will review your request and, if we agree, will promptly make the necessary corrections.

To request access to or rectify your information contained in our file, contact us at privacy@cooperators.ca. If you authorize a third party to make a request on your behalf, we need your written consent to release your personal information to the third party.

Register a privacy concern

Our goal is to help you meet your needs and provide the best service we possibly can. If you ever have a privacy-related concern, do not hesitate to contact us to discuss it. We take your privacy concerns seriously and we will investigate all privacy-related complaints, and where necessary we will take appropriate measures to address your complaint. Should you remain unsatisfied with our complaint process, we will inform you of what other complaint procedures are available to you.

Updates to this Privacy Policy

We may review this Privacy Policy periodically to reflect changes in privacy regulations and in our practices. We will post a notice of any relevant and material changes to this Privacy Policy when they occur.

Contact Us

For any questions about our privacy policy or our privacy practices, or if you want to access or rectify your personal information contained in our files, or if you have a privacy-related complaint, contact our Privacy Officer at:

Co-operators Privacy Office
101 Cooper Drive
Guelph, ON, N1C 0A4

privacy@cooperators.ca
1-888-887-7773