Registrations
Heward is registered in the category of Portfolio Manager with the Autorité des marchés financiers (AMF) in Quebec, the Ontario Securities Commission (OSC) in Ontario, the BC Securities Commission (BCSC) in British Columbia, the Alberta Securities Commission (ASC) in Alberta and the Financial & Consumer Services Commission (FCNB) in New Brunswick.
Privacy Policy
As our client, you are entitled to know how we protect your personal information and how we limit its disclosure.
Accountability
The collection, use and disclosure of data or information about individuals is subject to provincial and federal laws on the privacy of information. To this effect, Heward Investment Management Inc. (Heward) has designated the Chief Compliance Officer as Privacy Officer to ensure adherence with the Heward Privacy Policy, which applies to all current and former clients of our firm, including all those who invest in our Pooled funds. This privacy policy describes our policies and practices for collecting, disclosing, and safeguarding “personal information,” which may include financial or other information about you.
Consent
The knowledge and consent of the individual are required for the collection, use and disclosure of personal information, except where legally inappropriate. You provided this consent at the time you opened your account(s) with us.
We collect personal information about you from the following sources:
- Information we receive from you on our client Memorandum of Agreement form, the Schedule 3 Form (know your client “KYC” form) and Investment Policy Statement (IPS), agreement letters and other forms.
- We also collect personal information during both formal and informal meetings, as well as during our telephone conversations with you.
- This personal identifying information includes, but is not limited to, your name, address, date of birth, driver’s license or passport number, assets, income and any changes in your personal situation; as well as information about your transactions with us, your custodian and others, such as account balances and parties to transactions.
Heward will be vigilant with respect to the initial and ongoing accuracy of the personal information we collect and asks that you keep us up to date by promptly notifying us of any changes such as your mailing or email address or phone number, employment status or income needs.
Identifying Purposes
- To understand and assess your ongoing needs and to adjust your portfolio if warranted;
- For client communication, service and administration including invoicing and accounting purposes;
- For internal, external and regulatory audit purposes;
- To comply with legal and regulatory requirements;
- To facilitate investment transactions with other financial intermediaries;
- In compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act.
Limiting Use, Disclosure, and Retention
- To complete certain transactions or account changes that you request, it may be necessary to provide identifying information to non-affiliated third parties, such as trustees or custodians and broker-dealers.
- We will release your personal information if we are required by law to do so or in other limited circumstances permitted by law for example, to protect your account from fraud, or if you give us the permission to do so.
- Should you wish us to share your personal information with a third party such as your accountant, auditor or consulting firm, we require written instructions describing the type of personal information you wish us to share as well as the name, address, phone, fax number and email address of the third party.
Legislation and Regulations
The Personal Information Protection and Electronic Documents Act (PIPEDA) and An Act Respecting the Protection of Personal Information in the Private Sector (Quebec) require organizations to obtain your consent to collect, use or disclose information about you.
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires Heward to comply with certain client identification, recordkeeping, reporting and internal compliance
measures. This includes reporting suspicious transactions to Canada’s financial intelligence unit, the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).
What happens if you close Your Account?
Who has Access to Your Personal Information?
Disclosure of your personal information is restricted to individuals who need access in order to provide services to you.
Safeguards
We maintain physical, electronic and procedural safeguards that comply with Canadian regulations to protect your personal information.
Openness, Access, Recourse
Heward will make available information about its policies and practices relating to the management of personal information upon request.
You may obtain access to the personal information we hold about you at any time to review its content and accuracy. Please provide us with specific information in writing, to permit a comprehensive search through our files. Heward will respond to written requests within 30 days.
If you require more information, or have concerns, please contact our Privacy Officer at info@heward.com.
Heward may update this policy from time to time. When we change the policy in a material way, an updated Policy will be available on the website.