Privacy Policy

Protecting Your Privacy 

At Genova Private Management (“Genova”), your privacy is very important to us. We are committed to providing you with the best possible service while safeguarding your personal information.  Genova collects personally identifying information about you only when you specifically and knowingly provide it to us. 

Genova’s privacy policy has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA” or the “Act”). PIPEDA sets out rules for the collection, use and disclosure of personal information in the course of commercial activity as defined in the Act.

The Ten Principles of PIPEDA

The following principles form the basis of Genova’s Privacy Policy:

  1. Accountability: Genova is accountable for the personal information it collects, uses, retains and discloses in the course of our commercial activities, including, but not limited to, the appointment of a Chief Privacy Officer;
  2. Identifying Purposes: Genova will explain the purposes for which the information is being used at the time of collection and can only be used for those purposes;
  3. Consent: Genova must obtain an individual’s express or implied consent when we collect, use, or disclose the individual’s personal information;
  4. Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
  5. Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the individual consents to the alternative use or disclosure;
  6. Accuracy: Genova is required to keep personal information in active files accurate and up-to-date;
  7. Safeguards: Genova uses physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure;
  8. Openness: Genova must inform their clients and train their employees about its privacy policies and procedures;
  9. Individual Access: an individual has a right to access personal information held by Genova and to challenge its accuracy if need be; and
  10. Providing Recourse: Genova will inform clients and employees of how to bring a request for access, or complaint, to the Chief Privacy Officer, and respond promptly to a request or complaint by the individual.

How Do We Define Personal Information 

Personal information refers to information that specifically distinguishes you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, social insurance number, banking information, as well as your investment and financial information. 

How and Why We Ask for Your Personal Information

We obtain most of our information about you directly from you. This information is gathered, primarily through our detailed Client Profile form, which we use in managing your account(s). This information is necessary for a number of reasons, including to: 

• Fully understand your investment needs and objectives in order to manage your investment portfolio 

• Verify your identity and protect you against fraud 

• Establish custody accounts that you have requested for the safekeeping of the securities that we manage 

• Comply with the regulatory obligations of the securities industry 

• Comply with the Canada Revenue Agency’s income reporting requirements. 

We limit the information we collect to what we need for these purposes, and we use it only for these purposes.

Who We May Disclose Your Information To 

In order to provide our products and services to you we may provide your information to other persons where: 

• We have your consent 

• The other parties are our agents or suppliers who assist us in serving you 

• We are required or permitted to do so by law 

How We Protect Your Information 

Genova protects your information with appropriate safeguards and security measures. We have security standards to protect our systems and your information against unauthorized access and use. 

All of our employees, agents and suppliers, as part of their agreements with Genova, are bound to maintain your confidentiality and may not use the information for any unauthorized purposes. 

We monitor and review our procedures and security measures regularly to ensure that they are being properly administered and that they remain effective and appropriate. 

Genova makes every reasonable effort to keep your information accurate and up-to-date. We retain your information for only as long as we require it for the reasons it was collected. When it is no longer required we will destroy or delete it in an appropriate manner. 

Questions, Concerns and How to Make a Complaint

Jennifer A. Dewling, Principal and Chief Compliance Officer, is Genova’s Chief Privacy Officer and Quebec Privacy Officer and is responsible for Genova’s privacy policies and practices. We would be happy to provide you with a copy of our complete Privacy Policy upon request.  

If you have any questions or concerns about the privacy and confidentiality of your personal information, if you would like to request access to any of your personal information, for example to verify that it is correct, or if you would like to make a privacy-related complaint, please contact Jennifer A. Dewling at: 

90 Adelaide Street West, Suite 800
Toronto, ON M5H 3V9
(416) 361-2807

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