At Alliance Trust Company (“Alliance”), we are committed to respecting and protecting the confidentiality and privacy of our clients' personal information for privacy entrusted to us.     

 

In our Charter as a “Special Purpose” Trust Company providing Stock Transfer and Corporate Trust services, the collection and use of our clients' personal information is a part of our day-to-day business operations.

 

Our goal is to provide our clients with the highest level of service, with the utmost integrity and professionalism.  The following are the key points of our Privacy Policy:

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1. Definition of Personal Information

 

Personal information is information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization. It includes information that the client has provided to Alliance or was collected from other sources with the client's consent or authorization. It may include details such as the name and address, telephone number and other contact information, securities ownership information, identification including Social Insurance Number or Driver’s License.

 

  2. Ten Principles of Privacy:

 

• Principle #1: Accountability

 

We take our commitment to securing our clients' privacy very seriously. Each of our employees and representatives is responsible for maintaining and protecting our clients' personal information and therefore must abide by this Privacy Policy.   Each staff member and representative is accountable for all personal information in their possession or custody, including any personal information disclosed to third parties for processing or other administrative functions.

 

• Principle #2: The Purpose of Collecting Personal Information

 

Alliance will identify the purpose for which it collects personal information, before or when the information is    

collected, which may include the following:

 

To verify our clients' identity and to protect against fraud

        

To administer and update account records, respond to inquiries and fulfill our contractual service obligations

        

To understand the clients' instructions, and

 

To comply with any legal or regulatory requirements.

 

No person shall collect personal information on behalf of Alliance unless the collection is expressly authorized by statute, used for the purposes of law enforcement or necessary to the proper administration of a lawfully authorized activity.

 

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• Principle #3: Obtaining the Client's Consent

 

Alliance will make a reasonable effort to ensure that the client understands how his/her personal information will be used. Alliance will seek to obtain the clients' consent to collect, use or disclose any personal information.

 

A client's consent can be express, implied, or given through an authorized representative. Express consent may be provided in writing, orally or electronically. Implied consent is when Alliance can reasonably infer consent from an action taken or not taken, or where the circumstances reasonably require that Alliance have and use the information to fulfill the client's directions. A client may, at any time, withdraw his/her consent as long as reasonable notice is provided.

 

Alliance is not legally required to collect, use or disclose the client's information

 

Withdrawing their consent does not impede Alliance’s ability to fulfill its legal or contractual requirements.

 

Alliance may collect, use or disclose personal information without the customer's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

 

• Principle #4: Limits for Collecting Personal Information

 

Alliance limits the amount and type of personal information collected and collects only the information required.  Alliance will collect personal information for the purposes identified. Alliance collects personal information using policies and procedures which are fair and lawful. Alliance may ask the customer to provide the following personal information:

 

Social insurance Number (SIN) for tax reporting purposes. This is done to comply with the Canada Revenue Agency's reporting requirements.

 

Alliance may also collect and use the client’s SIN for administrative purposes, such as an internal identification number to accurately identify clients that have similar names.

 

Contact information such as the client's name, address, telephone number or email address.

 

• Principle #5: Parameters for Using, Disclosing and Retaining Personal Information

 

Alliance will only use or disclose personal information for the reason(s) it was collected, unless consent is provided to use or disclose it for another reason, or it is permitted or required by law.

 

In the ordinary course of Alliance fulfilling its obligations, Alliance may have to share personal information with other parties. For example, the information of security-holders or ESSP plan participants will also be available to the issuer or plan sponsor. Under no circumstances would Alliance sell or give lists of clients to other companies for their own use.

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Under certain exceptional circumstances, Alliance may have a legal duty or right to disclose personal information without the client's knowledge or consent to protect matters which include public interest.  Personal information may be released to legal or regulatory authorities in cases of suspected money laundering, insider trading, manipulative or deceptive trading, or other criminal activity, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of government, regulatory authorities or other self-regulatory organizations.

 

Alliance has policies in place that govern the retention of personal information only for as long as deemed necessary for the identified intended purposes for which it was originally collected or as legally required.

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• Principle #6: Maintaining Accurate Personal Information

 

Alliance is committed to maintaining personal information accurately to the best of its ability for the identified purposes for which it was collected. If the client discovers inaccuracies in his/her personal information, or his/her personal information changes, the client is responsible for notifying Alliance, so that the necessary changes are made promptly. Subject to security requirements, corrections to personal information can be provided to Alliance by mail, fax or email.

 

• Principle #7: Appropriate Safeguarding of Personal Information

 

Alliance maintains appropriate safeguards to protect the sensitivity of the client's personal information. The client's personal information is secure within Alliance, regardless of the format in which it is held. Alliance has security controls to protect against unauthorized use, access, alteration, duplication, destruction, disclosure, loss or theft of the client's personal information.

 

Alliance maintains physical, electronic and procedural safeguards to protect the customer's personal information. Examples of safeguards include restricted access to Alliance's information processing and storage areas, limited access to relevant information by authorized employees only, use of passwords, firewalls and encryption of electronically transmitted information, and the use of secure locks on filing cabinets and doors.

 

Within Alliance’s website, cookies or other information-tracking technologies may be used to improve the functionality or security, or to provide the client with a more customized online experience. As far as Alliance is aware, cookies cannot capture files or data stored on the client's computer. With most Internet browsers you can block, receive a warning or erase all "cookies" from your device. Please refer to your browser instructions or help screen to learn more about these features. If you choose not to accept "cookies", you should be aware that certain aspects of our site may not function properly.

 

• Principle # 8: Availability of Information about Policies and Procedures to Customers

 

Alliance’s Privacy Policy is available upon the customer's request.    The information will be made available in a manner that is generally easy to understand. From time to time, we may make changes to this policy and inform you of changes, as required by law.

 

 

• Principle # 9: Providing Customer Access to Personal Information

 

When clients make a request in writing along with providing satisfactory identification and proof of entitlement, Alliance will within a reasonable time inform them what personal information it has, what it is being used for, and to whom it has been disclosed.

 

Alliance will respond to the written request in a timely fashion. Clients can verify, update and correct their information as well as have obsolete information removed, by submitting such requests in writing. In certain situations, however, Alliance may not be able to provide clients access to their personal information. Alliance will explain the reasons for this lack of access and any recourse that the customer may have, except where prohibited by law.

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• Principle # 10: Handling Complaints and Questions

 

Clients may challenge Alliance’s compliance with this policy. Such questions or concerns should be directed by e-mail (inquiries@alliancetrust.ca) to the Company's Privacy Officer. Further documentation or information may be asked for at the time of the request to verify the client's identity.

 

  3. Internet Services Privacy

 

The safeguarding of personal information while interacting with Alliance via the internet is also extremely important. Alliance applies the 10 principles discussed above in caring for the client personal information. 

 

If the client visits us via the internet, Alliance may place a “cookie” on the client browser that records the number of visits made by the client to Alliance’s website. However, no personal information is collected. Alliance uses cookies for internal web reporting and statistics. This information is gathered at an aggregate level and no individual or computer is identified. This information assists the Company to measure effectiveness of the Company website, monitor website usage, and to determine a response to the corporate marketing strategy and to ensure the ease of use.

 

 4. Regular Internet E-mail is Not Secure

 

E-mail sent within Alliance's IT system, is not secure. Alliance will preserve the content of a client's email and email address and Alliance’s response, for an effective and efficient response to any follow-up questions from the client. Alliance also retains this information to meet legal and regulatory requirements.

 

 5. Protection against Fraud

 

Fraud prevention measures are built into Alliance’s due diligence process and regularly upgrade its fraud detection/prevention systems.

Although technologies can make it easier for fraud to occur, Alliance employs around the clock monitoring systems and controls to detect and prevent fraudulent activity

 

 6. Policy Review

 

This policy may be reviewed and updated from time to time, as deemed necessary.