Privacy Policy

Protecting your privacy at Tower Asset Management

Protecting our client’s privacy and the confidentiality of their personal information has always been fundamental to the way we do business at Tower Asset Management. Our goal is to meet or exceed the privacy standards established by Personal Information Protection and Electronic Documents Act (PIPEDA) legislation introduced by the federal government. For Tower purposes this personal information is any information, recorded or not, that identifies you as an individual. This may include name, address, email address, age, gender, marital status, occupation, finances as well as trading history and social insurance number. It will also include new account opening forms, account statements, financial records relating to your holdings of Tower funds and federal tax slips.

Personal information does not include the name, title, business address or telephone number of an employee of an organization.

Why we use your Personal Information

We obtain most of our information about you directly from you. The information we ask for depends on which product or service you need. For every product or service, we need your name, address and some identification. Noted below are reasons why we need some of the other information we ask you to provide.

Birth Date: This helps us identify you and ensure that no one is trying to impersonate you. We may also use it to determine your eligibility for products and services that may be of benefit to a particular age group.

Social Insurance Number (SIN): Your SIN is required for products which earn investment income, in order to comply with the Canada Customs and Revenue Agency’s Income reporting requirements.

Financial Information: This is used to ensure that the advice we give you or the investments you purchase are appropriate for you. We only collect the information we need and only use it for the purposes explained to you.

When you apply for a new product or service, we will indicate in the application or agreement how we intend to use your information. If we wish in the future to use it for another purpose, we will ask you for your consent at that time. We will only ask for the information we need for that particular product or service. We will indicate clearly which information would help us to serve you but is optional for you to provide.

Disclosing your Personal Information

When you complete our account opening forms, you are expressly consenting to the collection, use and, where appropriate, disclosure of your personal information. Your consent can be written or verbal, expressed (e.g. providing your personal information on a subscription agreement or "know your client"paperwork) or implied (e.g. not withdrawing your consent to a certain use of your personal information when given the opportunity to do so). You may withdraw your consent at any time subject to legal and contractual restrictions, however without your consent we may be unable to open or service your account.

Tower does not sell client lists or your personal information.

We may collect and share your information with affiliates of Tower Asset Management as well as third party service providers such as transfer agents and valuation firms who need your information to do their jobs.

For regulatory purposes, the Provincial Securities Commissions as well as self-regulatory organizations (SRO’s), require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by Regulated Persons for compliance with money laundering and anti-terrorism legislation as well as securities regulation. Regulators and SRO’s collect, use, or disclose such personal information for regulatory purposes, including:

Surveillance of trading related activity,
Sales and financial compliance,
Investigation of potential regulatory and statutory violations,
Regulatory databases,
Enforcement or disciplinary proceedings,
Reporting to securities regulators, and
Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

Protecting your Personal Information

Tower Asset Management will protect your information with appropriate safeguards and security measures. We have thorough security standards and procedures to protect all information and all Tower personnel have signed a confidentiality agreement which governs their treatment of all personal information.

When we provide information in response to a legal enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required. Only those Tower employees, agents and authorized service providers who need your personal information to do their jobs are given access to your personal information.

We retain our client’s information only as long as it is required for the reasons it was collected and as dictated by law. This period may extend beyond the end of a client’s relationship with us but only for so long as it is legally necessary for us to have sufficient information to respond to any issue that may arise at a later date.

Accessing Your Personal Information

Tower is committed to keeping your personal information accurate and up-to-date provided you keep us informed of any changes or respond to our request for updates. Our clients have the right to verify the accuracy and completeness of their personal information, and may request that it be amended. Any client who wishes to verify, review, or update your personal information may do so at any time. Please contact the Privacy Office listed below in writing.

Inquiries and complaints received will be reviewed by Tower Asset Management’s Privacy Officer: