How We Collect, Use and Disclose Personal Information
We ask you for only the information we need. We collect only the information we need for the purposes we have identified to you. Our files are kept for the purpose of providing and servicing financial and insurance products and services that we believe are right for you, over your lifetime. We will not sell your personal information.
Why we need the information
Generally, we need to collect personal information to:
understand your needs,
determine your eligibility,
continue to offer you the full range of products and services that we believe meet your changing needs and to service such products and services,
meet regulatory or contractual requirements relating to the products and services provided to you. We will make sure you understand why we need the information by using clear, understandable language when we identify the purpose.
We will obtain your permission
We collect, use or disclose your personal information with your permission. Your permission may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative. You may withdraw your permission to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. Before we make information available to third parties, other than an agent or service provider who needs it, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we want to share with them and why.
We Will Limit How Long We Keep Information
We are responsible for your information. We will keep your personal information as long as it is necessary, including updating the product or service or as required by law. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to the information during the process.
We will protect your personal information
We are responsible for all personal information in our possession, including information transferred to a third party service provider or agent, so that we can provide you with a product or service. All employees, agents and authorized service providers of CI Private Counsel LP (CIPC) are required to protect the confidentiality of your personal information.
How we protect information
Access to your personal information is restricted to those of CIPC’s employees, agents and authorized service providers who need it to do their jobs. We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption.
Your Right To Access Your Personal Information
You have the right to ask whether we hold any personal information about you and to see that information, as provided by law. You have the right to know:
how we collect your personal information,
how we are using it,
and to whom it may have been disclosed.
How to request an update or correction
If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it.
If you show that your personal information is inaccurate or incomplete, we will make the necessary changes.
If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures.
How to register complaints
You may register a privacy-related complaint by contacting CIPC’s Privacy Officer. We will explain CIPC’s complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps to set the situation right, including changing our policies and practices if necessary. We will also let you know what other complaint procedures may be available to you.
For more information
For more information, please contact CIPC’s Privacy Officer at (416) 364-1145 or by email at email@example.com
CIPC’s Privacy Code
Principle 1 – Accountability
Each member, employee or agent of CIPC is responsible for personal information under his or her control and each member company shall designate an individual or individuals to be accountable for compliance with this Code.
Principle 2 – Identifying Purposes
The purposes for which personal information is collected shall be identified before or at the time the information is collected.
Principle 3 – Consent
The prior knowledge and permission of the individual are required for the collection, use or disclosure of personal information, except for legal or security reasons.
Principle 4 – Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified. Personal information shall be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.
Principle 6 – Accuracy
Personal information shall be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
Principle 7 – Safeguarding Information
Personal information will be protected by safeguards appropriate to the sensitivity of the information.
Principle 8 – Openness
CIPC will make readily available to its customers, employees and agents specific information about our policies and procedures relating to the management of our personal information.
Principle 9 – Individual Access
Upon request, an individual will be informed of the existence, use and disclosure of his or her personal information and shall be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 – Handling Customer Complaints and Suggestions
Individuals can address any complaint regarding compliance with the above principles with our Privacy Officer at firstname.lastname@example.org.
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