Privacy Policy

The following policy is dated June 2022.

At Odlum Brown USA Investment Management Limited (OB USA), your privacy is our priority. We collect personal information to open your accounts, to manage your portfolios and to help us provide a better level of service. We protect the security and confidentiality of the personal information that we collect.

We may amend our Privacy Policy from time to time to accommodate changes in our services, technology or as a result of a legal development. Each time you submit personal information or use our services, you agree to be bound by the current terms of our Privacy Policy.

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information and we will do everything we can to maintain that trust. The following are details of our approach to privacy.

1. We do not sell your personal information to anyone.
   
   
2. OB USA only shares personal information with third parties and affiliate companies that help us process transactions or service your account (for example executing your trades, acting as your custodian, or mailing your account statements).
   
   OB USA only shares personal information with third parties and affiliate companies that help us process transactions or service your account (for example executing your trades, acting as your custodian, or mailing your account statements).
   
   We may also disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required by law (for example, to cooperate with regulators or law enforcement authorities, resolve client disputes, perform credit/authentication checks, or for risk control).
   
   We may use third party providers of information technology and data processing services that may store and/or process your personal information outside of Canada. Your personal information may be disclosed in response to valid demands or requests from government agencies under applicable law in those jurisdictions.
   
   Outside of these exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so.
   
   
3. We collect personal information in the normal course of business in order to administer your accounts and serve you better.
   
   Application and registration information: We collect information that you provide to us when you open an account, make application to or through OB USA for the purchase of a securities product or service.
   
   The information we collect may include name, address, phone number, e-mail address, Social Security number, financial information and information about your investment desires and experience. We also may collect information from consumer reporting agencies to verify your identity in the account opening process.
   
   Transaction information: Once you have an account with us, to administer your account and better serve you, we collect and maintain personal information about your transactions, including balances, positions, and history, and may include your name or other data in an internal client list that reflects your activities at OB USA and with outside contracted providers.
   
   
4. We use your personal information to fulfill our regulatory obligations and to help us deliver the best possible service to you.
   
   OB USA is required by its various regulatory authorities such as the SEC and state jurisdictions to collect, review and maintain certain personal information such as investment history or financial data. Also, the USA PATRIOT Act requires that OB USA collect and verify certain personal information to assist it in verifying the identity of its clients and the sources of funds in an effort to prevent money laundering and terrorism.
   
   
5. We protect the confidentiality and security of your personal information.
   
   Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested. We restrict access to personal information to select employees and agents who have a need to know such information for business purposes only. All such employees are trained and required to safeguard such information. We also maintain physical, electronic, and procedural safeguards to guard your personal information.
   
   
6. We continue to evaluate our efforts to protect personal information and make every effort to keep your personal information accurate and up to date.
   
   If you identify any inaccuracy in your personal information, or you wish to make a change to that information, please contact us so that we may promptly update our records.
   
   
7. We will provide notice of changes in our information-sharing practices. If, at any time in the future, it is necessary to disclose any of your personal information in a manner that is inconsistent with this policy, we will give you advance notice of the proposed change so that you have an opportunity to opt out of such disclosure.

If you have any questions or concerns, please contact us by e-mail at [email protected] or call us at 1-866-636-8222.