Privacy & Security

Privacy Notice

The following privacy notice (Privacy Notice) is provided by Guardian Capital Group Limited and its Canadian affiliates whose business relates to a purpose identified in this Privacy Notice (Guardian Capital, us or we) in an effort to explain our collection, use, retention and security of personal information. Clients, investors, visitors and investment advisors who interact with us are assured of our commitment to protecting your privacy and the safety, security and confidentiality of your personal information.

Collecting and using personal information is necessary to our business. At Guardian Capital, we believe that the trust of our employees, clients and investors is our greatest strength. That is why we are committed to protecting your privacy and the confidentiality of your personal information.

What is Personal Information?

Personal information is data about an identifiable individual (Personal Information). It is information that on its own or combined with other pieces of data, can identify you as an individual, such as your address, personal identification numbers, financial information or other details about you.

What Information We Gather and How

In order to operate our business in accordance with applicable laws and regulations, Guardian Capital is required to collect certain Personal Information, which may include, among other things, your name and address, Social insurance or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions. We may also collect information about you if you visit the Guardian Capital website (www.guardiancapital.com) (the Website). We may combine the information collected on our Website with Personal Information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you, or from offline sources, such as when you establish your account with us or call customer service.

In addition to the Personal Information you provide to us, we may receive information about you that you authorize other parties to provide to us. We also may obtain Personal Information from service providers unaffiliated with Guardian Capital in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. We will treat such combined information in accordance with our Privacy Notice. If you do not wish to provide certain Personal Information to Guardian Capital, we may be unable to provide certain products or services to you.

Our primary goal in collecting Personal Information is to provide you with a smooth, efficient and customized experience. This allows us to provide features that meet your needs, and to customize our service to make your experience easier.

Account Application Information: When an account is opened, Personal Information may be required as part of the account documentation. This information may include name, address, phone number, email address, social insurance number, date of birth, citizenship, family and marital status, banking information and information about employment, assets, investments, income, investment experience, and investment objectives.

Transaction Information: Any time a transaction is initiated in an account with us, we collect information about that transaction. We also keep information such as transaction history, current balances and current investments related to the account. These records also may include the application information listed above.

We may gather Personal Information for “Know Your Client” and other purposes on a continuing basis through meetings, discussions, document requests, and at times other than those noted above, in order to ensure we have accurate and up-to-date information to service the account and to meet regulatory obligations.

Other Information: If you enter a secured section of the Website through the use of an ID, we already have on file your name, address, and account information. We time-stamp all incoming sessions, and we collect the IP, domain name, session duration, transactions made, and pages viewed. In addition, we, and our service providers, may use various website tracking tools, such as Cookies, Web Beacons and Website Analytics, as described in greater detail in the section below, to enhance your experience with improved design and personalized content that may be relevant to you. Our Website also includes certain web forms for investment advisors to provide Personal Information to Guardian Capital from time to time so advisors can obtain additional information about Guardian Capital and its products and services and can participate in webinars or other information sessions.

Cookies, Web Beacons, Website Analytics and Log Files

We use a variety of online technologies, such as cookies, web beacons, Website analytics and log files as described further below, to collect information that helps us understand how our Website is used. Specifically, when you visit our Website, we or our service suppliers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you select; searches you conduct; the internet protocol (IP) address used to access our Website or mobile application; your general geographic location (e.g., your city, province, or postal code); and the website visited before our site.

We also may use similar tracking technologies in emails that we, or our service providers, send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues, to resolve technical or service problems, and for security purposes. We also analyze this information, with the assistance of our service providers, to improve our Website design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications and advertising to you regarding our products and services.

Cookies

A cookie is a small file of letters and numbers that is stored on your computer or other device when you visit a website or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our online services. This helps us to provide you with a useful experience when you browse and also allows us to improve our online services. We and our service providers use session cookies, which link your actions during a particular online session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.

We, and third party service providers acting on our behalf, use session and persistent cookies to:

• Allow you to access all core Website features and to browse in an optional and secure manner, including by preventing fraud and improving site security;
• Remember preferences that you submit as well as those generated from your usage data on our Website;
• Measure your use of our Website in an effort to improve its quality and enhance your overall experience, including tracking page views, time and date of our Website access, and other usage data, and identifying your operating system and browser type (but not other information about your computer or the programs on it) and your general geographic location; and
• Tailor the advertising you receive, including by measuring the effectiveness of our communications, such as newsletters and advertising campaigns.

We may use aggregated usage data to track trends and analyze patterns on our Website. If you register to enter an area of our Website, the Website will recognize who you are and collect all information that you submit (including subscription to emails, etc.). Any information collected about you from our Website may be associated with other identifying information that we have about you.

Web Beacons

Our Website and the emails that you receive from Guardian Capital use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.

Web beacons allow us, directly or through our service providers, to collect information used for website and mobile application analytics, such as how many users have visited particular pages or downloaded documents, or how frequently users search for a particular term. However, our use of these cookies and web beacons is limited. We do not use them to view or collect data in cookies or similar data files created by other websites. We will not share the information in these data files or give others access to it—except to help us better serve your investment needs and as described in this Privacy Notice.

We and our service providers use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you select any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Guardian Capital relationships.

If you are a Guardian Capital investor who has registered for secure online access to your Guardian Capital accounts, we are able to combine the information we collect about your usage of our Website during a secure (logged-in) session with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to Guardian Capital, even if you do not log in, and link information about that visit, as well as Guardian Capital ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our Website and the effectiveness of our online advertising, as well as to identify Guardian Capital products and services that may be of interest to you.

Our Website includes links to third-party sites or information that we think may be of interest to you. When you select these links and leave our Website, our site’s Legal Terms of Use and this Privacy Notice no longer apply. The collection, use, and disclosure of information through third party websites and services are subject to the privacy policies of the third-party websites or services and you are responsible for complying with such third-party’s terms of use and understanding its privacy policy, both of which you should review carefully.

Website Analytics

We engage service providers to collect the information discussed above to engage in analysis, auditing, research, and reporting. These service providers may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our Website. In particular, our Web Site uses Google Analytics site to help collect and analyze certain information for the purposes discussed above. The information generated about your use of our online services may be transmitted to and stored by Google Analytics on servers outside your country of residence.

Log Files

We also use IP addresses to analyze trends, administer our Website, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to Personal Information.

Managing Privacy Settings

You will be asked to review and accept or modify the use of cookies the first time you visit the Website. You can review and modify your cookies preferences at any time by clicking the “Cookie Settings” button at the bottom of every web page.

If you have any concerns about Guardian Capital’s use of cookies, you can also set your web browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of our Website may not operate correctly.

For further information about deleting or blocking cookies on your web browser, please consult your browser settings.

For clarity, opting out of cookies may not opt you out of web beacons or other tracking technologies. For further information about blocking web beacons or other tracking technologies, please consult the available resources online.

Use of Collected Information

We may use information you provide us to:

• respond to your questions and requests;
• provide specific services or products to you;
• provide service support;
• manage institutional risk;
• assess your satisfaction with our services or products;
• contact you about updates to our online services;
• conduct research and analytics (for example, regarding the use of our online services);
•  provide you with content and communications that we believe may be of interest to you;
• maintain measures aimed at detecting and preventing fraud and protecting the security of Personal Information and our online and offline operational infrastructure, including our Website;
• allow you to utilize features within our Website by granting us access to information from your device, such as contact lists, when you request certain services;
• monitor the performance of our online services, diagnose problems and ensure that our online services function properly, make our online services easier and more convenient to use, and otherwise administer our online services;
• investigate suspected fraud, harassment, or other violations of any law, rule, or regulation, the terms, rules or policies of our online services, or the rights of third parties, or to investigate any suspected conduct which we deem improper;
• comply with laws, regulations, legal processes and law enforcement requirements; and
• otherwise operate our business in accordance with applicable laws and regulations.

Interest Based Advertising

Guardian Capital participates in various forms of targeted advertising (interest-based advertising) and uses third-party analytics and advertising companies to provide you with targeted advertising and offers. Interest-based advertising, which is sometimes called online behavioural advertising, uses data collected from your online activity on a digital device (e.g. smart phone, tablet, computer, etc.) using cookies, pixel tags, and other technologies to show ads that may be of interest to you.  Specifically, this Website works with advertising companies that use tracking technologies (including cookies and pixel tags) on our Website to provide you with tailored advertisements on third party websites. This could mean that we advertise to previous visitors who haven’t completed a task on our site. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network. We may also use advertising cookies to link to social media networks such as LinkedIn. LinkedIn will use any information about your visit to the Website to recognize you, set a cookie or employ other tracking technologies, then deliver targeted advertising to you. Of course, any data collected will be used in accordance with our own Privacy Notice, as well as the privacy policies of such third-party advertisers or social media companies.  

We may also share certain anonymized information with our third-party advertising partners (such as a hashed email address or other anonymized and encrypted “remarketing” lists) to help identify you across sites and across devices and to show you relevant ads, generate similar audiences and to show dynamic ads.

For third party advertisers or social media companies, you can adjust your advertising preferences with the third-party advertiser or social media companies themselves. The social media companies that interact with our Website, and all of the other third-party advertising services that we use, are detailed in the list below. We endeavour to keep this list up to date but may remove or add service providers from time to time. Please contact us if you have any questions about our current services. You can opt-out of vendor-specific targeted advertisements by clicking on the relevant links below.

Vendor	Opt-Out Link
Google Ads	Google Ads
LinkedIn	LinkedIn

For clarity, even if you opt out of interest-based advertising, you may still receive advertising from Guardian Capital. It just means that the advertising you will see will not be customized for you.

Sharing Information About You

Guardian Capital does not sell and does not share Personal Information about our clients, investors or others with unaffiliated third parties for use in marketing their products and services.

We may share Personal Information with the following entities:

• Guardian Capital affiliates, including the affiliates located outside of Canada where we do business, including internal service providers which perform, for example, printing, mailing, and data processing services.
• Unaffiliated service providers. While we may use a service provider to assist in relation to any of the purposes for which we may collect Personal Information, they generally fit within one or more of the following categories of service providers:
  • auditors, accountants, and legal and other professional advisors;
  • infrastructure and technology service providers;
  • marketing, advertising, analysis, research, event, and communications providers;
  • providers of administrative services for Guardian Capital products or services, such as transfer agencies, custodians, and securities’ pricing providers; or
  • if you conduct business with Guardian Capital through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.

The offering documents for various Guardian Capital investment funds provide the names of service providers which in their capacity as custodian, registrar, record keeper or distributor will have Personal Information concerning fund unitholders in their possession.

We will always use our best efforts to ensure that the service providers we work with will keep your Personal Information secure. However, we will only provide our service providers with the information that is necessary for them to perform the services, they will act under our instructions, and we instruct them not to use your Personal Information for any purpose other providing the services to Guardian Capital.

However, Guardian Capital and such service providers may also provide Personal Information to the following:

• Government agencies, regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions).
• Other third-parties, with your consent or as directed by your representative (for example, if you use Guardian Capital as a financial reference in applying for credit with another institution or if you use an external aggregation website or service that you have provided permission to access your Guardian Capital financial account on your behalf).
• Other entities and organizations as permitted or required by law (for example for fraud detection or fraud prevention or to respond to a subpoena)

Information collected from investment professionals’ customers is not shared with Guardian Capital affiliates for marketing purposes, except with your consent and as allowed by law.

Retention of Personal Information

Your Personal Information may be kept in electronic or paper format in the offices of Guardian Capital and its affiliates, in secure off-site storage facilities provided by storage service providers, and any third party (administration) service providers, who may themselves store it in multiple locations and forms (in and outside Canada).

Protecting Personal Information

At Guardian Capital we take the responsibility of securing your Personal Information very seriously and will take measures we determine appropriate in the circumstances to mitigate any identified risks to you.

Where your account information is stored on our Website, such  account information resides on a secure portion of our Website. Access is gained through logging in under a unique username and password assigned to you. This being said, we require your commitment in this relationship – please keep your username and password secure! While on a secure page of our Website, the lock icon on the bottom of Web browsers such as Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just ‘surfing’. While we use encryption to protect Personal Information online, we also protect Personal Information off-line. Access to Personal Information is restricted in our offices. Only employees who need the information to perform a specific job are granted access to Personal Information. Furthermore, all employees are kept up-to-date on our security and privacy practices. In addition, the servers that we use to store Personal Information are kept in a secure environment.

We have agreements in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.

Notwithstanding the above, no method of transmitting or storing Personal Information online is completely secure. As a result, while Guardian Capital strives to protect Personal Information, you should understand that there are security and privacy limitations of the Internet which are beyond our control. The security, integrity and privacy of any and all information and data exchanged between you and us through our Website cannot be guaranteed and any such information and data may be viewed or tampered with in transit by a third party. Guardian Capital endeavours to protect Personal Information, but it cannot guarantee the security of information transmitted to us, or by us, by electronic means.

In the event a breach occurs, Guardian Capital will take all reasonable measures to secure the Personal Information, including requiring any third party service providers to take such appropriate measures considered necessary to secure and remedy the breach.

In the event a detected breach may result in the potential risk of harm, disclosure of sensitive information or risk of theft of identity and/or assets, Guardian Capital will contact you as soon as possible, as we would had you raised a privacy complaint with us directly, outlining the details and actions taken to reduce the risks identified.

Access and Updating Personal Information

Requests to review and verify, and to correct or delete your Personal Information, or to find out to whom we have disclosed it, must be made to us in writing. We will need specific information from you to enable us to search for, and provide you with, the Personal Information we hold about you. We may charge you a reasonable fee depending on the nature of your request and we will advise you of any fee prior to proceeding with your request. If we are unable to provide some of the Personal Information we hold about you, we will tell you why.

To make a request for access to your Personal Information, for a purpose detailed above, please submit your written request to our Privacy Officer as listed in the Contact Us section below.

Notification of Changes

If we decide to change our privacy policy, we will post an updated Privacy Notice and the date of the last change so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

The Privacy Notice was last updated on June 2024.

If at any point we determine a new use of your Personal Information, which is different from that stated at the time it was collected, we will notify you. You will have a choice as to whether or not we use your Personal Information in this different manner. We will only use Personal Information in accordance with the privacy policy under which the information was collected.

Your Consent

Meaningful consent is required for the collection, use and disclosure of Personal Information. To make consent meaningful, you will be required to confirm your consent to the collection of your Personal Information, based on the disclosed nature, purpose and consequences of the collection, use or disclosure of your Personal Information.

You may withdraw your consent for the collection and use of your Personal Information by contacting Guardian Capital at any time or, in the case of electronic communications, by using the unsubscribe option that we provide in electronic communications. Certain services and products may no longer be provided to you, in the event you withhold consent to the use of information upon which such services and products are dependent and/or required by rules and regulations that govern them.

By using our Website, you consent to the collection and use of your Personal Information by Guardian Capital, its subsidiaries, affiliates, partners and associated businesses. If you do not agree to the terms of this Privacy Notice, please change the selection on our Website cookies tracking and/or do not use our Website.

Contact Us

We welcome your questions and concerns about privacy or your Personal Information.  Your issue or concern may be easily resolved by contacting our Client Relations team:

Telephone:  416·364·8341
Toll free: 1·800·253·9181
Email:  info@guardiancapital.com

If your concerns are unresolved, you may escalate to the Privacy Officer of Guardian Capital:

Telephone: 1-800-253-9181
Email: privacyofficer@guardiancapital.com

If, after contacting Guardian Capital’s Privacy Officer, your issue or concern has not been resolved, you may contact:

The Office of the Privacy Commissioner of Canada

30 Victoria Street
Gatineau, Quebec K1A 1H3
Telephone: 1-800-282-1376 or 819-994-5444
Fax: 819-994-5424
TTY: 819-994-6591
Visit: www.priv.gc.ca