Confidentiality policy

TRIASIMA is committed to protect the confidential information of its clients, employees, and long-term consultants and to ensure the confidentiality of personal information provided to TRIASIMA in the course of our business.

The federal legislation adopted in 2004, the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) applies to any organization, which collects, uses or discloses personal information in the course of its activities. The provinces of Québec, Alberta, and British Colombia have adopted their own specific legislation relating to the protection of private life.  PIPEDA and the three provincial legislations apply to TRIASIMA when dealing with its clients, employees, and the long term consultants.

Our files may contain both personal information and confidential information that do not fall under the definition of personal information. Under all circumstances, it is understood that TRIASIMA shall protect the confidentiality of any information it is entrusted with.

This policy sets out our standards for collecting, using, disposing, and storing the personal information of our clients, employees, and long-term consultants. This Policy also explains how we safeguard the personal information and the right to access that information by our client and employees.  The related procedures specify how it shall be applied.

Identifying purposes

For clients

The purpose of the collection and verification of information is twofold: to ensure that TRIASIMA’s clients are protected by assisting them in determining investment objectives, risk tolerance, and suitability of investments, and to satisfy TRIASIMA’s legal and regulatory obligations, including potential insider or control relationships, the prevention of possible money laundering, and tax reporting requirements.

For employees and long-term consultants

The personal information gathered shall be used for the employment contract between TRIASIMA and the employee or its consultants and for the application of the Personal Trading Policy.

Limiting use, disclosure, retention

When personal information is collected from clients, it is to be retained for the period during which clients maintain an account with TRIASIMA and for a period of time following the termination of the account, which is stipulated, by law or regulations. When personal information is no longer required, it is to be disposed of in a secure manner.

The personal information collected from any employee or any long-term consultant will be retained for the period during which the employee is with TRIASIMA and for a period of time following the termination of the employment or contract as provided by law or regulations.

As a portfolio manager, TRIASIMA may in, certain cases, be required to make certain personal information of its clients, employees or long-term consultants available to certain companies, governmental, regulatory and self-regulatory agencies and organizations. These entities are bound to ensure the confidentiality of the personal information provided by TRIASIMA.  The communication of personal information shall be done with the consent of the individual unless required by law.

The personal information shall not be preserved for longer than needed for the established purposes. Thereafter it shall be disposed of in a secure manner.

Accountability

TRIASIMA has appointed a Privacy Officer who is responsible for ensuring that TRIASIMA complies with the principles outlined in this Privacy Policy and its related procedures.

All employees and long-term consultants of TRIASIMA are bound by TRIASIMA’s established Policy and procedures to ensure that the personal information of its clients remains confidential.

Accuracy

TRIASIMA is committed to maintaining accurate records of its clients’ personal information. From time to time, TRIASIMA will request updated account documentation in order to ensure that the personal information is complete and accurate.

Safeguarding client information

TRIASIMA implemented and continues to maintain rigorous safeguards in order to ensure that the personal information remains confidential and is protected against loss or theft, as well as unauthorized access or disclosure.

Protection methods include limited access to the premises, technological measures such as off-site backups and archiving to protect personal information of its clients.

Request for access to information

All clients, employees, and long-term consultants have the right to request any information we hold about them and to see this information. They also have the right to enquire on how we used it and to whom it may have been disclosed.

Queries regarding TRIASIMA’s Privacy Policy and the assurance of the confidentiality of the personal information, if any, collected from clients, employees, and long-term consultants may be directed, in writing, to:

TRIASIMA Portfolio Management Inc.
c/o Privacy Officer
Regulatory and Compliance
1555 Peel Street
Suite 1200
Montreal, Québec  H3A 3L8

Complaints and concerns

A complaint concerning the protection of personal information should be addresses to the Privacy Officer at the address provided above.

Cookies on Our Web Site

We use cookies to enhance the features and user-friendliness of our Web site, and to better understand how our site is used by visitors. You can change your cookie settings using the banner that appears during your first visit on our Web site.

Cookies do not allow you to be personally identified, but if you have previously contacted us and given us your identity (through a form, for example), then our client relation management system can correlate some cookies with your personal data.

Essential Cookies

Identifier(s) Function
CookieControl This cookie is defined by Cookie Control. It saves your cookie preferences for 365 days. 

Statistical Cookies

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_ga, _gid These cookies are used by Google Universal Analytics, Google’s statistical analysis service. They are used to identify individual users by assigning a unique, randomly-generated number as a client identifier.
_gat This cookie is used by Google Universal Analytics, Google’s statistical analysis service. It is used to reduce the number of queries and expires after 10 minutes.
_gat This cookie is used by Google Universal Analytics, Google’s statistical analysis service. It is used to reduce the number of queries, which limits data collection on very busy Web sites. It expires after 10 minutes.

Compliance

This policy and the related procedures will be reviewed periodically to ascertain their conformity and effectiveness. Furthermore, the Privacy Officer will send at least on annual basis or further to any changes a reminder of the Policy and its related procedures to all employees and long term consultants.