Privacy Policy
Revised October 2023
This policy has been developed to communicate how Brompton may collect, use and disclose the personal information of clients, potential clients and website visitors. Any time you communicate with us, attend one of our events, subscribe to one of our funds, or otherwise do business with us, your personal information will be handled and protected in accordance with this privacy policy (the “Policy”).
Website – Consent
By using the Brompton website, you consent to the collection, use and disclosure of your personal information as outlined in this Policy. If you do not find this Policy acceptable, do not transmit your personal information. This Policy may be updated from time to time, and you are responsible for reviewing the most recent Policy on the website. Your continued use of the website or submission of information will be deemed to be your acceptance of the updated Policy.
What personal information does Brompton collect?
For the purpose of this Policy, personal information is any information about an identifiable individual, including any information that, alone or in combination with other information, could be used to identify an individual. Personal information does not include aggregated or de-identified information, or the business contact details of the employee or representative of an organization, when acting in their business capacity.
This information may include items such as your name, address, telephone number, email address and unit holdings and may be in paper or electronic form.
We collect personal information that you, or your financial advisor on your behalf, provide to us, personal information that we receive in connection with the administration of the entity in which you hold units or shares, and some information that we collect automatically when you visit and interact with our website. For example, we may collect personal information when you subscribe to or sign-up for certain services, tools or features that we provide, when you register for seminars or other events that we offer, when you fill out forms on the website, when you email us with general inquiries or otherwise in connection with the use of our website, as discussed below.
We also contact holders of Brompton funds on an annual basis to ask if they wish to receive interim and annual financial statements. Address and email information provided on an annual basis will be used to send these statements to holders by Brompton and/or a third party service provider.
How do we use your personal information?
We only use your personal information to: (i) provide you with any services or assistance you may request; (ii) respond to your inquiries and other needs; (iii) better understand our client needs and preferences; (iv) as otherwise required or permitted by law; and (iv) to provide you with information regarding products and services which we believe may interest you. If you receive information regarding products and services and do not wish to continue receiving such information you may use the unsubscribe feature in emails you may receive from us, or alternatively, please contact us at info@bromptongroup.com to have your address removed from our distribution list.
How do we share or disclose your personal information?
From time to time, we may share your personal information with third party service providers (a “Service Provider”) that we have engaged to perform services on our behalf, based on our instructions, such as to our professional advisors, to data hosting and storage companies, to mail processors and email distribution platforms or to organizations that provide administrative and support services to Brompton. We will limit our disclosure of your personal information to such third parties to that which is reasonably necessary for the purpose or service for which the Service Provider is engaged. We will use contractual and other means to provide a comparable level of protection while the information is being processed by such third parties, and to ensure it is only used to provide Brompton with the service in question.
Your personal information may be disclosed (i) to third parties at your request which can include your financial advisor; (ii) to government bodies and law enforcement agencies, pursuant to warrant, order or statutory requirement; (iii) in connection with any legal proceedings or prospective legal proceedings involving Brompton, (iv) to otherwise establish, exercise or defend our legal rights or (v) as may otherwise be permitted or required by law.
Your personal information may also be provided to an actual or potential successor or an acquiror of all or a portion of the business, including the management of Brompton funds and companies. Any such entity that obtains your personal information in these circumstances shall be bound by the obligations and protections described in this Policy.
Your personal information will not be otherwise provided to third parties to use for their own purposes.
How is your personal information protected?
We are dedicated to the protection and safeguarding of your personal information. We maintain physical, electronic and procedural safeguards designed to protect the confidentiality of your personal information. Employees must handle personal information in accordance with this Policy and are required to use standards of care in handling personal information. Technology is constantly evolving, and we cannot provide assurance that the personal information that we collect will remain free from loss, interception, misuse or alteration by third parties and we will have no liability for any loss, interception, misuse or alteration.
Links to other websites
Our website may contain links to other websites. These other websites are not governed by this Policy. Please read the privacy policies of these other websites.
How can you update your personal information?
You may update your personal information at any time by contacting the privacy officer as described below.
You may opt out of any communications or change your information at any time.
Automatic Collection of Information
When you visit and use our website or open or respond to email messages from us, we and/or our Service Providers may automatically collect certain technical information such as your Internet protocol (IP) address, the type of Internet browser you are using, the type of computer operating system you are using, and the domain name of the website from which you linked to our website.
Cookies, Analytics and Advertising
Some pages on our website may use a technology called “cookies”. A cookie is a token that a server gives to your browser when you access a website. Cookies are capable of storing many types of information. Cookies may be placed by Brompton or a third party. Cookies help provide additional functionality to the website or help provide and analyse website traffic and usage information. For instance, our server may set a cookie that keeps you from having to enter a password more than once. With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions.
We may also use tools like web beacons to allow us to understand which pages you visit on our website and which email communications have been opened. A web beacon is a small transparent graphic image that allows us to record simple user actions related to our website and to email communications received from us, to help us determine the usage and effectiveness of our site and communications.
Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the convenience of the website. For more information or to opt-out, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
Interest-based Advertising: On other websites you visit, we and our partners may display interest-based advertising about Brompton and its funds, based on inferences made using information gathered from your online activity over time across multiple websites or devices. Interest-based advertising includes ads served to you after you leave our website, encouraging you to return. It also includes ads that may be relevant based on your online activities. These ads, which are targeted and served by third parties acting on our behalf, might be served on websites or on apps.
For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the DAAC, please visit the Digital Advertising Alliance of Canada website at http://youradchoices.ca/choices. Please note that, in order to opt-out successfully, you must have cookies enabled in your browser.
Retention
Brompton will only retain personal information to the extent necessary for the purposes identified in this Policy, or to which you might otherwise consent, after which your personal information will be securely destroyed or irreversibly erased or de-identified.
Personal information may be stored “in the cloud” or otherwise outside of Canada, including by Service Providers that we have engaged, where it may be subject to the legal regime of the jurisdiction in which it is stored.
Changes to this Policy
Brompton may revise this Policy from time to time as our business evolves, in response to legal developments, as new technologies become available, or as we introduce new features, products or services. When we make changes to this Policy, we will update the “revised” date at the top of the Policy, so you will know when changes are made. Continuing to use our services, including our website, after we post or communicate a change signifies that you consent to the revised terms of the Policy.
Access and Correction
Upon request, you may examine the personal information about you that Brompton holds, except as provided by law. You may request access to your personal information by making a request, in writing, to Brompton’s Privacy Officer, at the addresses provided below.
You may also make a subsequent request to the Privacy Officer to correct any personal information that you feel is inaccurate or incomplete. You may also request the deletion of your personal information, subject to legal and contractual restrictions; however, please note that deletion of some information may impact our ability to continue to provide you with certain services. Note that if you have unsubscribed from receiving product and service information by email, we will continue to retain your email address so as to avoid sending you such correspondence in the future.
Our Commitment to Children’s Privacy
We do not knowingly collect or maintain information directly from persons under 13 years of age (“children”), and no part of the services or information contained on our website is directed to children. If you are under 13 years of age, then please do not use or access the services or information contained on our website at any time or in any manner. If we learn that information has been collected through the website from children and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child has provided us with personal information without your consent, please contact us using the contact information below to request that we delete the information from our systems.
Where should you direct questions or access requests?
If you wish to:
- unsubscribe to any mailings, electronic or otherwise
- access or request correction of your personal information, or
- have any questions about this Policy or our practices with respect to your personal information
Please feel free to contact the Privacy Officer, at 416-642-6000, toll free at 1-866-642-6001 or info@bromptongroup.com.
You may also contact us vial mail at:
Brompton Group, Attn: Privacy Officer
Suite 2930, 181 Bay Street
Toronto, ON M5J 2T3
