Personal information means information that: (i) can identify an individual directly; or (ii) is information about an identifiable information. Personal information does not include publicly available information (for example, names, addresses and telephone numbers, which are published in directories) or any information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work email address.
How we collect personal information
Wherever possible, we try to collect personal information directly from you. With your consent, we may also obtain personal information about you from third parties such as investment advisors and dealers whom you have authorized to disclose personal information to us.
How we use personal information
Jesselton may collect and use personal information for the following purposes:
- To understand your needs.
- To analyze the suitability of Jesselton’s products and services for you.
- To determine their eligibility for Jesselton’s products and services.
- To set up, manage and offer products and services that meet your needs.
- To provide you with ongoing service.
- To comply with legal and regulatory requirements, including disclosure requirements connected with tax, auditing, and securities legislation, and to otherwise administer and provide products and services to our clients.
When we disclose personal information
Jesselton may share your information with third parties. Jesselton will do so to support with providing our services, administering our business, and for such other purposes as set forth below, including:
Financial service providers, such as banks and others used to finance or facilitate transactions and operations of our funds.
Other service providers and affiliates, such as accounting, legal, or tax preparation services.
Securities and tax regulators: including applicable governmental and regulatory entities required as part of securities and tax law compliance such as submitting exempt trade reports to securities regulators.
We may also disclose personal information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk. We may be ordered by a court to disclose personal information to a third party or to the court, or to preserve personal information pending the outcome of a legal hearing. We may also be legally required to disclose information in connection with the collection or repayment of a debt, to assist in the prevention of fraud or other criminal activity, when we obtain legal advice from a lawyer, or in an emergency that affects the health or safety of an individual.
In the instances described above we may be required to share your personal information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.
If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let the Chief Privacy Officer know immediately.
How we protect personal information
In order to protect your personal information, we will not collect, use or disclose your personal information for any purpose other than those identified above. When we provide information in response to a legal or regulatory inquiry or order, we ensure that the order is valid and we disclose only the information that is required, otherwise we will seek your consent prior to disclosing any information.
All information collected will be kept in a secure environment and will be subject to restricted access by Jesselton employees or Jesselton’s agents. We maintain security standards and procedures to help prevent unauthorized access to personal information.
Despite all the foregoing security measures, online storage and online communications are not entirely secure. We encourage all individuals to provide only the information they are comfortable with providing a third party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible. As a community, we can all help keep it safe.
We retain your personal information only as long as it is required for the reasons it was collected or as required by law. The length of time we retain information varies depending on the product or service and the nature of the information. This period may extend beyond the end of your relationship with us, but only for so long as it is necessary for us to have sufficient information to respond to any issue that may arise at a later date. When your personal information is no longer needed for the purposes explained to you, we have procedures to destroy, delete, erase or convert it to an anonymous form.
We make every reasonable effort to keep your personal information as accurate, complete, and up to date as necessary. We encourage you to verify the accuracy and completeness of your personal information in our records.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
When visiting our website the only information which is collected by us is that which is voluntarily supplied by the visitor. However, our web server does track general information about visitors, such as their domain name and time of visit. This information is collected and used to diagnose any problems with our server, to administer our website and to gather demographic information to permit us to evaluate and improve our website. We do not disclose or sell this information to others.
By communicating with us by email, we may collect, use and disclose that information for the purposes for which it was communicated to us or for purposes otherwise required or permitted by law. That information, like all personal information we gather, will be held only for so long as is necessary for us to provide that service and in compliance with the laws which govern us. We cannot guarantee that links on our website to other websites are secure or the information contained on those sites is accurate. Those sites may have different privacy policies than ours. Visitors should read the linked sites’ policies before using them.
Subject to legal and contractual requirements, existing clients may refuse to consent to Jesselton’s collection, use or disclosure of information about them, or withdraw their consent to Jesselton’s further collection, use or disclosure of information at any time in the future by giving Jesselton reasonable notice. However, this may limit our ability to provide services or products to you, if applicable. Such notice should be provided in writing to the designated Privacy Officer of Jesselton. Any withdrawal of consent will apply thereafter and not to information handling practice that have been previously undertaken based on prior consent.
Addressing Your Inquiries and Concerns
Attention: Chief Compliance Officer
Jesselton Capital Management Inc.
3080 Yonge Street, Suite 3032
Toronto, Ontario M4N 3N1
Last revised: July 2023