Legal

Privacy statement

Capital International Asset Management (Canada), Inc. considers the privacy of the personal information in its control to be of fundamental importance.  This Privacy Statement explains the purposes for which we collect, use, share and otherwise process your personal information:

1. As a visitor of this website;
2. In connection with your investment in investment funds offered by us or our affiliates;
3. In connection with your business relationship with us or our affiliates; or
4. In connection with your interest in a career with us or our affiliate.

What personal information do we collect?

Personal information, as used in this Privacy Statement, means information about an individual that allows that individual to be identified.

We ask for consent to collect, use or disclose your personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. Where your relationship with us is initiated by your agent, such as a dealer firm or your advisor, we rely on your dealer or advisor to obtain your consent to share your personal information with us.

We only collect personal information that is reasonably necessary for us to provide our products and services to you, to manage our relationship with you or to manage our business operations. If you do not provide the information that we ask for, we may not be able to provide the products or services you have requested or establish and/or maintain a relationship with you.

The personal information we collect about you depends on your dealings with us. If you are a client or otherwise deal with us in your individual capacity, including to invest in our investment funds or as a prospective employee, we collect the following categories of personal information about you:

• Contact information such as your name, address and telephone number or email address.
• Personal details such as age, date of birth, gender, citizenship, occupation, and marital status, details relating to your immediate family members and connections to senior political officials.
• Identification documents such as your passport or driver’s licence, as permitted by law, to address client identification requirements.
• Government-issued identification numbers such as a social insurance number, tax identification number, or health card number, as permitted by law, to address anti-money laundering, tax reporting or know your client requirements under applicable laws and regulations.
• Financial information such as your source of funds and investment experience required to meet our regulatory requirements under applicable laws and regulations.
• Information based on your relationship with us.  If you deal in the capacity of an officer, director, principal or employee of one of our clients, we collect contact information, information on your role, position, title and certain identifying information to meet our regulatory obligations. We also request sensitive personal information from associates and prospective employees. In addition to the foregoing types of personal information, we also collect information about memberships of a professional or trade association, criminal records, health information or medical history.
• Information collected when you visit our website: your online identifier (IP address) and your contact details where you register for any of our events or services online.

How do we collect your personal information?

Personal information we collect about you comes either from information that you provide to us or that is otherwise obtained during our relationship with you.  We may obtain information when you call or write to us or, if you are an investor, we may obtain information through your financial advisor or, if you have a user profile to log into the financial advisor section of our website, we may collect information related to your use of our website.  For clients, associates, or prospective employees, we obtain personal information from you through application processes and forms. 

We also obtain personal information from our agents or service providers acting on our behalf, from third parties authorized to provide us with that information, such as agencies used to complete due diligence checks, third parties that provide identity verification services and from third parties who provide services to you, such as your financial advisor.  For example, your financial advisor  may  provide us with your personal information in order to establish a relationship with us.  This could include personal and contact details, and identification documents.  We may also collect personal information about you through social media, subscription services, sanctions lists, public registers, or other publicly accessible sources. 

We will not disclose any personal information except in the limited circumstances set out below.  Any personal information disclosed to us will be retained for as long as it is needed to meet any contractual obligations, provide the requested services to you or to comply with applicable legal or regulatory obligations. 

We do not generally collect and/or use your sensitive personal information except where required and necessary for compliance with a legal or regulatory obligation, where you have made such information publicly available or where we have obtained your consent.

What do we do with the personal information we collect?

We collect and use your personal information to the extent required to provide our products and services to you as our customer, manage our relationship with you and/or to manage our business operations.  What we do with the personal information that we collect depends on your relationship with us and includes:

• Verifying your identity
• Evaluating and processing your application, accounts, transactions and reports
• Providing you with ongoing services and information related to the products, services and accounts you have with us
• Managing our business operations, including for analyzing activities to help us improve the products and services we offer and for internal training purposes
• Confirming your employment and educational background and considering your suitability for current or future roles with us during the recruitment process
• Managing the employment relationship with our employees
• Managing risks to our clients and us, including against fraud and errors, exercising and defending our legal rights, and/or assisting with investigations, complaints, regulatory requests, and litigation
• Complying with legal and regulatory requirements, including the requirements of self-regulatory organizations

Automated decision-making

An automated decision-making process is a process through which a decision is made solely by automated means, without any human involvement.  We will only engage in automated decision-making in accordance with applicable laws, where it is necessary to enter, or to perform, a contract with you, or where you have given your explicit consent.  If we use automated decision-making, we will provide you with information on the personal information used to make such a decision and you may submit your observations on that decision. 

Cookies

We use cookies to track the number of users who visit the public areas of our website and may also record the location of your computer on the internet for systems administrative and trouble-shooting purposes, as well as to report aggregate information.  We also collect and store certain navigational and transactional information, such as page hits, the PDF files you view, and the times and ways you use this website.  We use navigational information to personalize our website, for programing, editorial and financial research and to offer new content that is useful to our users.  For the use of cookies on our website, please see our Cookie Policy.

Targeting or Advertising Through Interest-Based Advertising

We partner with third parties to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (Interest-Based Advertising).  These third parties may use cookies and web beacons to collect information about your activity on our website and they may combine it with information about your activity on other, unaffiliated websites.  For example, third parties may use the fact that you visited our website to target ads for Capitals Express Investments services to you on non-Capitals Express Investments websites.  In addition, our third-party advertising providers may use information about your use of our website to help target non-Capitals Express Investments advertisements based on your online activity in general. 

For information about Interest-Based Advertising and how to opt out, please visit:

• Network Advertising Initiative (NAI) opt-out page, available at www.networkadvertising.org/choices; or
• Digital Advertising Alliance consumer choice page here

When do we disclose and transfer your personal information?

We do not sell any personal information to third parties. 

We may disclose or transfer, in confidence, your personal information to third party service providers for services that include the preparation and mailing of client documents on our behalf and for other services such as data processing, information technology, and advertising or marketing services. 

We use other Capitals Express Investments companies (this means our ultimate holding company and all its subsidiaries), located outside Canada, including the United States and European Union, to manage your entire relationship with us, including servicing any accounts or products with us and maintaining consistent information about you, to manage and assess our risks and business operations and to comply with legal and/or regulatory requirements. 

The personal information we share and/or transfer continues to be subject to applicable Canadian laws and the laws of the service providers’ jurisdiction of business.  We require our service providers to protect the personal information we entrust to them and only use it for the limited purpose of providing their services to us.  You should be aware that as some of our service providers are located outside Canada, your personal information may potentially be accessible to governmental, national security, law enforcement and other regulatory authorities of the foreign jurisdiction in accordance with the laws of the jurisdiction. 

We may also share your personal information with other financial institutions and government organizations and, if you invest in our funds, your financial advisor.  We only share information that is necessary to provide services to you or to meet our legal and regulatory obligations, such as for tax reporting purposes.  We may need to disclose your personal information to our auditors and/or professional advisers to meet our statutory, audit and risk management requirements, to obtain professional advice or to establish, exercise or defend any legal claims, or in response to a legal or regulatory request or requirement.  We may also share your personal information with certain government entities in the event we reasonably believe your personal information has been compromised and reporting to such entity may reduce or mitigate the risk of significant harm to you. 

How do we protect your personal information?

We maintain appropriate physical, electronic and procedural safeguards to protect your personal information against accidental or unauthorized loss or access.  Within Capitals Express Investments and among our service providers, we seek to restrict access to personal information to those persons who need it to provide products and services to you.  These measures reflect our commitment to maintaining the privacy and confidentiality of your personal information. 

How long do we keep your personal information?

We will only keep your personal information for as long as we need it to fulfil the purposes for which it is collected  or otherwise processed, including to fulfil our contractual, legal, accounting, tax, or regulatory obligations, or to effectively manage our operations and our relationship with individuals.  Where we keep your personal information for compliance with legal and regulatory obligations in accordance with applicable laws, we keep your personal information for the duration required under applicable laws and regulations.  These retention periods may be extended if we need to preserve your personal information in connection with litigation, investigations or proceedings. 

At the end of the retention period, we will securely dispose of the personal information, in accordance with applicable privacy legislation and Capital International Asset Management's internal policies and procedures.

What are your rights relating to your personal information?

You may have one or more of the following rights under applicable privacy legislation:

• The right to withdraw consent.  Withdrawal of your consent partially or fully to our collection, use and/or disclosure of your personal information may limit our ability to provide services or products to you.  Please contact us for more information;
• The right to request a copy of your personal information held by us;
• The right to request corrections to your personal information held by us;
• The right to request information related to automated decision-making processes that resulted in a decision;
• The right to submit observations on decisions based exclusively on automated processing to a person with authority to review the decision;
• The right, in limited circumstances, to request that your personal information not be disseminated; and
• The right of data portability.

Individuals wishing to exercise these rights should contact us as set out below.  We will respond to your request within 30 days of receiving it.

You can withdraw your consent for us to use your personal information for marketing purposes by using the unsubscribe option in our electronic communications with you or by contacting us to request that we not use your personal information for this purpose. 

How can you contact us?

If you have any questions about this Privacy Statement or want to exercise any of your rights set out above, you can contact us at:

Investors or advisors:
Telephone: (888) 421-5111

Privacy Officer:
Email: CIAMprivacy@capgroup.com

Cookie policy

We recognize the importance of data privacy. To fulfil our transparency obligation, please find below information about how we use cookies on our websites. You have the option to disable or opt-out of them. Should you choose not to do so, we assume that you agree to accept cookies we use on our websites.

What are cookies?

Cookies are small text files that are stored on your device when you visit certain web pages. They can enhance a visitor’s experience when navigating a website and provide valuable feedback such as information regarding a visitor’s page views, downloads and technology preferences. They are commonly downloaded to your computer or mobile device by websites that you visit in order to enable the website to tag your computer/ device and recognize it as you move around the site (and potentially when you return later).

Cookies may be temporary (or “session”) cookies, which are only in use while you visit our website and are deleted when you close your browser, or permanent cookies, which stay on your device’s permanent storage after you leave our website until you delete them manually or your browser deletes them after a period of time.

Cookies that are set by us are called first-party cookies. We also use third-party cookies, which are cookies from a domain different than the domain of the website you are visiting.

How and what cookies do we use?

We use cookies to track the number of users who visit the public areas of our website and may also record the location of your computer on the internet for systems administrative and trouble-shooting purposes, as well as to report aggregate information. We also collect and store certain navigational and transactional information, such as page hits, the PDF files you view, and the times and ways you use this website. We use navigational information to personalize our website, for programing, editorial and financial research and to offer new content that is useful to our users.

We use the following categories of cookies on our website. For more information on how we collect and use information that is identifiable to you, please refer to our Privacy Policy.

ESSENTIAL COOKIES
These cookies are essential for parts of our website to operate. They enable you to move around our website and allow us to recognize you within our website so that we can provide you with the service that you have asked for. These cookies cannot be switched off in our systems, and are not able to track your browsing activity on other websites.

FUNCTIONALITY COOKIES
These cookies help us customize our site content based on your preferences. They remember choices you make such as identifying yourself as a particular investor type (Individual or Institutional), your language, the country you visit our website from and any changes you make. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

PERFORMANCE COOKIES
These cookies collect anonymous information on how you use our website to help us improve areas such as navigation. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve. The information stored by these cookies never show personal details from which your identity can be established.

ADVERTISING COOKIES
We may use data collected to customize advertisements to you in other sites you browse on the web.

THIRD-PARTY WEBSITE COOKIES
When using our website, you may be directed to other websites for such activities as surveys, for job applications, and to view content hosted on those sites such as an embedded video or news article. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our website.

Managing cookies

To manage your cookies you can also use our automated/online tool which is available by clicking  located at the bottom right hand side of your screen. Alternatively, please follow the below instructions to manually control your cookies.

The instructions for amending cookies will depend on the operating system and web browser you are using. For instructions on how to accept or reject cookies, consult your browser's 'Help' section. Most recent browsers provide the flexibility to reject all cookies, accept all cookies, or accept cookies only from websites you trust. You'll also find instructions on how to delete any cookies that already exist on your computer. If your current browser does not provide the flexibility you want in setting preferences for cookies, consider downloading a more recent version.

To learn more about what cookies are set up on your computer or mobile device as you browse the web, visit www.allaboutcookies.org.

Social media terms of use

LinkedIn is owned by a third party unaffiliated with Capital International Asset Management (Canada), Inc. (“CIAM”), an affiliate of Capitals Express Investments or its subsidiaries. Our LinkedIn site is governed by LinkedIn’s User Agreement and privacy policies. We encourage you to follow us on LinkedIn and other social media channels and to read our terms as set out below.

• Capitals Express Investments is not responsible for any content found on LinkedIn or linked websites. Our organization does not endorse, recommend or adopt any content on LinkedIn or linked websites other than content posted by Capitals Express Investments. Use these sites at your own risk after carefully reviewing their terms of use and privacy policies.
• Shares and likes of fan posts are not an endorsement by Capitals Express Investments and do not represent the views of our organization.
  
• Opinions, statements or views expressed by Capitals Express Investments are subject to change and should not be taken as investment advice or recommendations. The use of the “follow” function is not intended to constitute an endorsement or testimonial of the account followed. Additionally, follows, replies or links to third-party content do not constitute an endorsement by Capitals Express Investments of an individual or entity.
  
• Capitals Express Investments reserves the right to block any follower who posts or links content that we deem inappropriate or offensive or constitutes a testimonial, advice, recommendation, or advertisement for securities, products or services, or is promotional in nature. We also reserve the right to block followers whose LinkedIn pages contain offensive or inappropriate content or serve as promotional sites.
  
• While we encourage you to connect with us, please refrain from posting anything personal or account-related. Our service centre at (866) 805-8407 can answer account-related questions and is available Monday through Friday between 9:00 a.m. and 7:00 p.m. Eastern Time (except on holidays).

Accessibility

Capital International Asset Management (Canada), Inc. (CIAM) is committed to meeting its current and ongoing obligations under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the AODA accessibility standards as well as the Ontario Human Rights Code respecting accessibility and no discrimination based on physical or mental disabilities. CIAM is committed to excellence in serving all clients including people with disabilities. Our Accessibility Policy and Accessible Client Service Policy can be found here. If you wish to provide feedback on the services we provide to people with disabilities, you can call (888) 421-7979.

Questions or comments about your investments in the Capitals Express Investments funds should be directed to your financial advisor.