Collection & Use of Personal Information
PearTree collects and uses personal information of its participants in transactions promoted by it (“Transactions”) to enable PearTree to provide you and your advisers with the assistance you may require to evaluate whether a transaction structured by PearTree is appropriate for you, and to allow Transactions in which you participate to be completed and reported on so that you can achieve the objectives of the Transaction, or to meet other legal and regulatory requirements. This includes personal client information collected by PearTree Securities Inc. to comply with its regulatory obligations as a securities dealer including, “Know Your Client” and anti-money laundering documentation requirements. This information comes either directly from you, or from your advisers. Information may also be shared with us by other parties to a Transaction, or their agents or advisors.
Pursuant to rules and regulations issued by FINTRAC or other regulatory authorities or governmental agencies, PearTree may, for the purpose of identifying you or performing other compliance screening, verify information you provide us by referring to an independent and reliable identification product held at a credit reporting agency. Specifically, PearTree may utilize due diligence screening service providers such as CanChek for compliance screening, and Equifax Canada Co’s eIDCompare identification solution to confirm your identity if you are not physically present to open your account.
The personal information we collect includes your name, address and telephone number, social insurance number, birth date, occupation, spousal and employment information, information related to your financial institution(s), and your estimated family income and net worth. During the course of providing services to you, other types of information such as tax records and other documentation necessary to support claims or requests for various types of payments and benefits will be collected.
Finally, PearTree collects and uses personal information for the purposes of sending you communications regarding general market information, business updates, invitations and opportunities to participate in Peartree offerings by internet, mail, e-mail or other methods.
PearTree will not use your personal information for any other purpose without your consent.
Security of Personal Information
We will maintain your personal information in secure data storage to safeguard it from unauthorized access, use or disclosure.
Retention of Personal Information
We will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Even after you use Peartree’s services, we keep some information about you on file in order to look up past transactions.
Disclosure of Personal Information
We will maintain the confidentiality of all personal information collected, and will only disclose such information to employees and contractors of PearTree who require such information for the purposes set out above. Certain personal information may be shared with other parties to a Transaction as well as yours and their agents and professional service providers such as securities dealers, legal and tax advisors. We also disclose personal information to Canada Revenue Agency, provincial tax authorities and any other government body which is reasonably necessary for you to obtain the benefits of a Transaction in which you participate and to otherwise comply with legal and regulatory requirements. In addition, disclosure may be made to third party service providers for purposes such as data processing and document storage, to enable them to provide their services to us. If customer information is provided to a third party with whom we have a business relationship, we will seek to require that third party to adhere to adequate privacy policies to maintain the confidentiality of customer information and to ensure the reliability and accuracy of the information.
Finally, for certain Transactions we may deliver to the Ontario Securities Commission and/or the British Columbia Securities Commission, if applicable, certain personal information pertaining to you, including your full name, residential address and telephone number, the number of securities you purchased and the total purchase price paid for such securities, the prospectus exemption relied on by the issuer of the securities and the date of distribution of the securities. Such personal information is being collected indirectly by the Ontario Securities Commission and/or British Columbia Securities Commission under the authority granted to them in their respective securities legislation. Such personal information is being collected for the purposes of the administration and enforcement of the securities legislation of Ontario and/or British Columbia, as applicable. Certain personal information pertaining to you will be available for public inspection at the Ontario Securities Commission and/or the British Columbia Securities Commission during normal business hours, including your full name, whether you are an insider of the issuer or a registrant, the number of securities you purchased, and the total subscription price paid for such securities.
You may contact the following public officials in their respective provinces with questions about the Ontario Securities Commission and/or British Columbia Securities Commission’s indirect collection of your personal information at the following addresses and telephone numbers:
Ontario Securities Commission
Suite 1903, Box 55
20 Queen Street West
Toronto, Ontario M5H 3S8
Telephone: (416) 593-8314
British Columbia Securities Commission
P.O. Box 10142, Pacific Centre
701 West Georgia Street
Vancouver, British Columbia V7Y 1L2
Telephone: (604) 899-6854
Except as set out above, we will not otherwise sell, transfer or disclose any of your personal information to any third party without your knowledge and consent.
How to Contact Us About Privacy Matters
By completing and delivering a New Client Application Form or other client documentation, you are providing consent to PearTree’s collection, use and disclosure of your personal information as set out in this disclosure.