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      2. Privacy Notice

        We respect your privacy rights and are dedicated to maintaining and protecting these rights. This Privacy Notice informs you of our commitment to privacy and explains the nature, purpose and consequences of consent to State Street Canada’s collection, use and disclosure of your personal information.

        Throughout this document, the words “we”, “our” and “us” refer to State Street Canada [1].  The words “you” and “your” refer to State Street Canada’s clients, former clients, potential clients, clients’ employees, as well as visitors to the State Street Canada website or persons who otherwise provide personal information to State Street Canada.  This Privacy Notice does not apply to State Street Canada employees.

        TYPES OF PERSONAL INFORMATION WE MAY COLLECT

        During the course of our business relationship, we occasionally collect your personal information or personal information that you have collected and disclosed to us.  We consider personal information as any factual or subjective information, whether recorded or not, about an identifiable individual.  

        In this Privacy Notice, “personal information” means information about an identifiable individual, including, but not limited to:

        • Personal Descriptors: legal name, age, date of birth
        • Personal identification documents: Social Insurance Number (SIN), birth certificate, passport number, driver’s license
        • Credit: credit file from Canadian credit bureaus: Equifax Canada or TransUnion Canada

        You may also provide us with personal information on behalf of your clients, employees, and/or pensioners that we require for certain services we provide such as when we are acting as registrar, plan or trust record keeper or when we process activities relating to the administration or recordkeeping of pensioner benefit payments.  The type of personal information we are sometimes required to collect includes an individual’s street address, SIN, asset holdings, identification documents or other information necessary to perform the services on your behalf or to meet our regulatory obligations.

        We will make all reasonable efforts to fully inform you about how we collect, use or disclose your personal information in a manner that you will clearly understand.

        HOW WE COLLECT INFORMATION

        We collect personal information in a variety of ways when you visit our website or when we provide you services including, but not limited to: various applications, trade instructions, verbal instructions, and other documentation that you provide to us. We may also receive this information from firms that assist us in administering your account and processing transactions on your behalf or from agents or mandataries you may have designated to act on your behalf. We collect this information in order to service your account properly and provide you with the services you expect to receive. We limit our collection and use of personal information to that required for valid business purposes or to comply with applicable law.

        By using our website and/or our services, you agree to the terms of this Privacy Notice as they may be amended from time to time and to the collection, use and disclosure of your personal information as outlined in this Privacy Notice.

        Use of Recorded Lines

        As a normal business practice in our industry, recorded lines are occasionally used for quality assurance and for a record of information exchanged. We may potentially obtain personal information via the use of such recorded telephone lines. In the event that a recorded line is in use for any telephone conversation, you will be notified that the line is recorded.  Such recordings may be transferred and held outside of Canada, including in the United States, and thus will be accessible to authorities under the laws of the jurisdiction in which the recordings are held and stored.

        State Street Canada Website

        We may periodically collect information from you through automated means.  When you browse our website, use our services, or read emails or newsletters, we may use “cookies” or other online tracking mechanisms in order to provide better services, facilitate your use of our website or services, store online preferences, track usage of our website or services, tailor the marketing of business services to our institutional customers, or enhance security.

        We do not collect personal information about you when you visit our website, unless you choose to directly provide such information when contacting us via email or some other means.  We will use this information to process your request and when applicable, respond to you.  By contacting us in this manner, you consent to and understand the nature, purpose and consequences of your consent to the collection, use and retention of this information for a reasonable period of time for the purpose of responding to your request.

        What are cookies?

        Cookies are text files containing small amounts of information downloaded to your computer or device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes that cookie. Cookies are useful because they allow a site to recognize a user’s device.  You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies.

        Cookies do a lot of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and they generally improve the user experience. They can also help to tailor the advertisements you see online so that they are more relevant to you and your interests.

        Some of our cookies are used for web analytics and intelligence about our website. This information may be combined with other information for the purposes described below, including marketing. We may also use web beacons or other technologies for similar purposes and we may include these in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor online activity.

        What if I don’t want cookies or website tracking of my activities?

        By using our website you agree that we can place cookies on your device and use other online tracking mechanisms as explained in this Privacy Notice and State Street’s Privacy Notice. If you want to remove existing cookies from your device, you can do this using your browser options. If you want to block future cookies being placed on your device, you can change your browser settings to do this.  For more information about the cookies used by us and State Street Bank and Trust Company, please refer to State Street’s Privacy Notice found at statestreet.com.

        Deleting and blocking cookies will have an impact on your user experience as parts of the website may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon you visit our website, even if you have previously deleted our cookies.

        HOW WE USE AND SHARE PERSONAL INFORMATION

        We may use your personal information in a variety of ways, including, but not limited to, providing you with services (custodial, investment management, fund accounting, administrative, trustee and other related services); improving our services; responding to regulatory inquiries or requests; making our procedures more efficient, and implementing security measures.

        We may disclose or share personal information with our affiliates for various purposes, as permitted by law, including in order for our affiliates to provide services.  Personal information may also be transferred to or shared with non-affiliated third parties with whom we have contracted to perform services on our behalf.  We require our service providers to agree to comply with appropriate privacy and security standards or to undertake to provide similar and appropriate levels of protection as we do when processing personal information.  These service providers and/or affiliates may be located in a domestic or foreign jurisdiction, such as the United States and personal information, can become subject to the legal systems and laws in force in each province, state or country: (a) where it is held, received or stored by you or us: (b) from where It is accessed by your or us: or, (c) through which it passes.

        We may also share information including personal information about you and your accounts and transactions to government agencies, exchanges, self-regulatory organizations, and law enforcement authorities, as required or permitted by law, rule, regulation or legal process, including, without limitation, for governmental reporting or to enforce any rights State Street may have against you as necessary.  

        We may share personal information and other information collected through the services provided to you with a successor entity in the event of a merger, acquisition or similar transaction of part or all of our business.  We will require the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Notice.

        We do not disclose or share personal information that we have collected to anyone except as permitted by this Privacy Notice or as may be required by law.  We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

        MARKETING COMMUNICATIONS AND YOUR CHOICES

        State Street Canada uses information collected on the State Street Canada website and information obtained from third-party sources (such as social media networks) to market business services to our institutional customers. Specifically, we may collect, use and/or share your information with our affiliates and service providers in order to provide specific information that you request, thought leadership materials, industry information, invitations to events and webinars, and other communications or solicitations that we believe will be of interest to you. We target and tailor such communications based on your interaction with State Street Canada’s website, mobile apps and emails; your inquiries; your participation in events or webinars; relevant social media activity; and other third-party data. No client proprietary information and no information about any of the individuals or entities that your firm may service, will be collected, used or shared for purposes of delivering these communications to you.

        By using the State Street Canada website or voluntarily submitting your contact information on the State Street Canada website, you consent to the use and sharing of your information for such purposes. You may, however, opt out of receiving such marketing communications by sending an email request as per the “How to Contact Us” section of this Notice, or by following the opt-out instructions contained in each communication.   

        HOW WE TRANSFER AND STORE YOUR PERSONAL INFORMATION

        State Street is a global organization; personal information we collect may be transferred internationally throughout the world to countries where State Street does business, which may not have the same data protection laws as the country in which you reside. We have internal policies and procedures in place in an effort to achieve an equivalent level of protection across our organization. The transfer of personal information to other countries is based on a business need or to comply with applicable laws. Personal information stored or processed in a foreign jurisdiction may be accessed under a lawful order made in that jurisdiction.

        HOW WE SAFEGUARD YOUR PERSONAL INFORMATION

        We use security measures, in compliance with applicable law, to protect personal information from unauthorized access or use. Yet you should understand that the open nature of the Internet is such that information and personal information may flow, without security measures, over networks connecting you to our systems and may be accessed and used by people other than those for whom the data is intended.  Access to your personal information is restricted to those employees, affiliates and third parties who need to know that information in order to provide you with the services required.

        Through ongoing training and communications, our employees who have access to your personal information are made aware of its confidential nature. State Street has a dedicated Privacy program in place to assist our employees in complying with our policies and procedures related to privacy and personal information.

        To safeguard against unauthorized access to personal information by third parties, all electronic personal information held by State Street is maintained on systems protected by secure network architectures that contain firewalls and intrusion detection devices. The servers holding personal information are “backed up” (i.e., recorded) on a regular basis in an effort to avoid any inadvertent erasure or destruction of such personal information and are stored in facilities with appropriate security and fire detection and response system.  Personal information will be retained only for the purpose for which it was collected, and the time that it is required, subject to reasonable business record retention procedures and/or legal requirements.

        HOW YOU CONSENT TO THE USE OF YOUR PERSONAL INFORMATION

        By appointing us as your service provider, you consent to and understand the nature, purpose and consequences of your consent to our collection, as well as the use, transfer and disclosure of the personal information as we have described in this Privacy Notice.

        Where we are providing recordkeeping, pensioner benefit payments or other similar services, and processing the personal information of your clients, employees or pensioners that you have collected and disclosed to us, we will be relying on the consent to the collection, use and disclosure of personal information that you have collected, and confirmed to us.

        You can withdraw your consent at any time, subject to legal or contractual requirements, by contacting and providing us with reasonable notice, such notice must provide us with sufficient time to identify your personal information, explain your options and any consequences of withdrawing your consent.  Where consent has been withdrawn, or where it has not been provided, we may not be able to provide a particular product or service where the personal information is essential to the delivery of that product or service.   

        There may be certain situations where we may be required to collect, use or disclose personal information without consent.  For example, we may be required to comply with a court order or to comply with various Canadian or foreign jurisdiction statutes, regulations or agencies.

        ACCESSING YOUR PERSONAL INFORMATION AND ENSURING ACCURACY

        As a person who provides State Street Canada with personal information, you may inquire as to the nature of the personal information stored at and/or processed by State Street Canada. You will be provided reasonable access to your personal information held by us and, where appropriate, with the ability to review and correct inaccuracies. We will cooperate in providing such access. We commit to using all reasonable efforts to maintain the accuracy of your personal information.  All such requests for access may be made by sending a request in writing.

        To help protect your privacy and provide security, we take reasonable steps to verify your identity before granting access to information. We will respond to such reasonable request made by you within such time period as required under applicable law after your identity has been confirmed and you have clarified the specific personal information that you require.

        HOW TO CONTACT US

        Please contact our applicable Privacy Officer if:

        • you have any questions or concerns regarding your personal information or about this Privacy Notice
        • you want more information about how to access any of your personal information held with us
        • if you wish to withdraw your consent

        You can contact the Privacy Officer by mail, email or telephone:

        For clients of:

        By Mail:

        By email & telephone:

        State Street Trust Company Canada

        State Street Bank and Trust Company-Canada Branch

        State Street Global Markets Canada Inc.

        State Street Fund Services Toronto Inc.

        State Street Financial Centre

        Attention: Chief Privacy Officer

        30 Adelaide Street East

        Suite 1100

        Toronto, Ontario

            M5C 3G6

        canada-information@statestreet.com

         

        (647) 775-7000

        State Street Global Advisors, Ltd.

        State Street Financial Centre

        Attention: Chief Privacy Officer

        30 Adelaide Street East

        Suite 1100

        Toronto, Ontario

        M5C 3G6

        SSgA_Compliance_Canada@ssga.com

         

        (647) 775-7000


        We may update this Privacy Notice from time to time without prior notice to you to reflect changes in our information practices.  The current version can be accessed from the State Street Canada website www.6gont.com

        [1] State Street Canada means the following State Street companies in Canada: State Street Trust Company Canada, State Street Bank and Trust Company-Canada Branch, State Street Fund Services Toronto Inc., State Street Global Advisors, Ltd. and State Street Global Markets Canada Inc

         

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