Privacy Policy of Postro Wealth
BACKGROUND
Postro Wealth is committed to keeping your personal information confidential. We believe that keeping our personal information confidential is of paramount importance.
Postro Wealth’s privacy policy (the “policy”) came into effect on October 1, 2009. It reiterates our commitment to respect the privacy and confidentiality of the personal information of potential clients and all professional contacts. It is tailored to meet or exceed the privacy standards established by Canadian Standards Association’s Model for the Protection of Personal Privacy and Canada’s Personal Information Protection and Electronic Documents Act.
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. This may include, name, social insurance number, income, address, employment status, marital status, credit evaluations as well as new account opening form, documentation relating to new account opening form, account statements and records of trading activity, financial records relating to trading in securities, etc.
THE TEN GUIDING PRINCIPLES
Principle 1 – Accountability: We are responsible for maintaining and protecting your personal information under our control.
Principle 2 – Identifying Purposes: We will identify the purposes for which personal information is collected before or at the time it is collected.
Principle 3 – Consent: We will obtain your consent for collection, use or disclosure of your personal information unless not required by law, regulation or self-regulation.
Principle 4 – Limiting Collection: We collect it by legal means and to the extent necessary to satisfy the identified purposes.
Principle 5 – Limiting Use, Disclosure and Retention: We may use or disclose your personal information only for the purpose for which it was collected unless you consent otherwise, or when required by law, regulations or self-regulation. We retain your personal information only for the period of time required to fulfill the purpose for which it was collected or as is required by law, regulations or self-regulation.
Principle 6 – Accuracy: We will maintain your personal information in its accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
Principle 7 – Safeguarding Information: We will protect your personal information by security safeguards that are appropriate to its sensitivity level.
Principle 8 – Openness: Upon request, we will make available to you the policies and practices that apply to the management of your personal information.
Principle 9 – Access: Upon request and unless prohibited by law, regulation or self-regulation, you will be given access to your personal information and be informed of its existence, use and disclosure. You may also verify its accuracy and completeness and may request to amend it, if appropriate.
Principle 10 – Complaints and Suggestions: You may direct any questions or inquires with respect to Postro Wealth at info@postrowealth.com
PRINCIPLE 1 – ACCOUNTABILITY
The Postro Wealth Privacy Policy applies to all your dealings with us regardless of the mode of communication, whether in person, by telephone, fax, online, or regular mail.
PRINCIPLE 2 – IDENTIFYING PURPOSES
We collect your personal information so that we may establish and service your inquiry and discharge our legal, regulatory and self-regulatory obligations. We are also required to collect specific personal information to satisfy our obligations pursuant to the “know your client” rule.
PRINCIPLE 3 – CONSENT
When you complete our contact form, you are expressly consenting to the collection, use and, where appropriate, disclosure of your personal information. In certain cases, your consent for the collection, use, or disclosure of your personal information can be implied when we can reasonably conclude that you have given your consent by some action you have taken or decided not to take. Your consent can be written or verbal.
You may choose not to provide us with some or all of your personal information, refuse your consent, or withdraw your prior consent.
PRINCIPLE 4 – COLLECTION
You are our primary source of your personal information.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
The responsibility to safeguard your personal information rests with every person at Postro Wealth who has access to it. All Postro Wealth personnel sign a confidentiality agreement which governs their treatment of all personal information. The confidentiality obligation survives the termination, voluntary or involuntary, of such employees. We also keep our employees informed about their confidentiality obligations and the importance of complying with them.
Sharing of Personal Information
In order to serve you better, we may share some or all of your personal information with entities who provide certain services to us. In such situations, we ensure that the third party service providers will provide same or greater level of protection for your personal information.
If you have any questions about how we share your personal information please contact us privacy@postrowealth.com
Disclosure
Subject to certain exceptions, we do not disclose your personal information without your consent to persons outside Postro Wealth. Some examples of the circumstances where we may collect, use, transfer, or disclose your personal information without your consent are:
* on a confidential basis to our agents, suppliers and service providers;
* to protect your best interests when your consent cannot be obtained in a timely manner
* to enforce or protect interests, rights, or property of Postro Wealth; or
* access required by statutory, regulatory or self-regulatory organizations.
We keep a record of what, when, why and to whom the information was disclosed unless the disclosure was made during routine business operations, such as suppliers or service providers.
We do not sell or disclose lists of our clients. If we obtain a list of clients from other organizations, we require that organization to confirm that they have complied with the requisite privacy legislation.
Retention
We retain your personal information so long as we need it when you are a customer and for a reasonable time thereafter, or as required by relevant statutory, regulatory or self-regulatory requirements. Our retention standards fulfill our privacy obligations. We destroy your personal information when we no longer need it and is permitted by law, regulations and self-regulation.
PRINCIPLE 6 – ACCURACY
We are 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. Please ensure that you promptly notify us of changes to the personal information you have provided to us. Also, carefully review our correspondence with you and notify us of any inaccuracies. We will amend our records and make our best efforts to advise others of any important amendments to your personal information.
If we ever decline to make your requested amendments, you may address your concerns in accordance with procedure set out in our Principle 10 – Privacy Governance Section of this policy.
PRINCIPLE 7 – SAFEGUARDS
Within Postro Wealth, your personal information is secure. We have comprehensive security controls to protect against unauthorized use, alteration, duplication, destruction, disclosure, or unauthorized access to your personal information. We ensure the physical, organizational and electronic security of your personal information by using secure locks on filing cabinets and doors, restricting access to our information processing and storage areas, limiting access to authorized personnel, using passwords, electronic firewalls and encryption of electronically transmitted information, where appropriate.
If you are our client and have access to the research area of our website, we may use information tracking technologies to improve the functionality of the website. However, please note that such information tracking technologies do not capture files or data stored on your computer.
PRINCIPLE 8 – OPENNESS
Our policies relating to personal information are transparent. If you request, we will provide names of outside entities we have given your personal information to in accordance with Principle 5 – Limiting use, disclosure and retention in this Policy. This will not include information given to entities engaged during the normal course of our business or our reporting obligations to statutory, regulatory or self-regulatory authorities including but not limited to Canada Customs and Revenue Agency.
PRINCIPLE 9 – ACCESS
If you wish to verify or review your personal information or to find out to whom we have disclosed it pursuant to this privacy policy, we will need 30 days written notice. If we are unable to respond to your query within 30 days, we will inform you of this fact. In certain circumstances, we may be prohibited to permit you access to some of your personal information. Without exhausting all possibilities, these may include the following situations:
* contains personal information about another person;
* is subject to solicitor-client or litigation privilege;
* contains our confidential proprietary information;
* has already been destroyed due to legal requirements or this privacy policy;
* cannot be disclosed for legal, regulatory or self-regulatory reasons.
If we cannot provide you access to your personal information, we will explain the reason why.
PRINCIPLE 10 – PRIVACY GOVERNANCE
We are committed to treating you with respect and consideration. Despite this, there may be times when you feel you have been treated unjustly when dealing with privacy issues. In most circumstances, such misunderstanding can be cleared by talking to our team directly.
If your concern is not resolved, please contact:
POSTRO WEALTH MANAGEMENT GROUP LIMITED
Rooms 1318-19 13/F Hollywood Plaza
610 Nathan Road, Mongkok
Kolwoon, Hong Kong
info@postrowealth.com
If the above steps fail to satisfactorily resolve your concerns,
you may contact the Privacy Commissioner of Canada by writing to:
The Privacy Commissioner of Canada
Place de Ville
Tower B, 3rd Floor
112 Kent Street
Ottawa, ON K1A 1H3
Tel: 1-800-282-1376
Fax: 613-947-6850