OVERVIEW

BEFORE USING OUR SITES OR PROVIDING US WITH PERSONAL INFORMATION, PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy is applicable to Greybrook Capital Inc. and its affiliated companies, including, but not limited to, Greybrook Realty Partners Inc. and Greybrook Securities Inc. (collectively, “Greybrook”, “us”, “we” or “the Company”), and describes how we collect, use and disclose Personal Information through this site and our other sites (collectively “Sites”), through communications with us, or through otherwise doing business with us. Greybrook is committed to providing safe web sites for visitors of all ages and to protecting any Personal Information (defined below) provided to or collected by us, and we have implemented this Privacy Policy to demonstrate our firm commitment to your privacy. We comply with applicable Canadian Federal and Provincial private-sector privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act and its provincial equivalents. We also comply with Canada’s Anti-Spam Legislation.

This Privacy Policy contains important information concerning how we collect, use, store and protect your Personal Information, including:

  • What we mean by Personal Information and when we collect it.
  • What Personal Information we collect from you.
  • The purposes for which we collect and use your Personal Information.
  • The Internet technologies we may use to collect and process your Personal Information.
  • With whom we may share your Personal Information, and the location in which your Personal Information may be stored.
  • The ways that we protect your Personal Information and how long we retain it.
  • How to access, correct or update your Personal Information.
  • How to contact us about privacy issues.

Please read through this Privacy Policy before submitting any of your Personal Information to us. Please note that by using the Sites, or otherwise submitting information to us, you are authorizing us to collect, store, transfer and use your Personal Information in accordance with this Privacy Policy.

If you do not agree to this Privacy Policy, please do not continue to use our Sites. Your continued use of the Sites signifies your acceptance of these terms and any changes in effect at the time of use.

We reserve the right to update this policy at any time without notice. When we make changes to this Privacy Policy we will revise the “last updated” date at the top of the policy. You should check back here periodically to find out if any changes have been made to this Privacy Policy. If we make substantial changes we will, as appropriate prominently post these changes to our Site or notify registered Users directly.

If you disagree with any change to the Privacy Policy, you may close your account and refrain from using our services or visiting the Sites. Continuing to use our services or visit our Sites after we post or communicate a change signifies that you consent to the revised terms of the Privacy Policy.

PERSONAL INFORMATION

For the purposes of this Privacy Policy, and in accordance with applicable privacy laws, the term “Personal Information” refers to any information that may be used to identify you, such as but not limited to your name, e-mail address, postal address or telephone number and information that may be generated through the use of websites, such as your IP address (as further described below).

We collect Personal Information that you voluntarily provide to us through responses to non-anonymous surveys, questionnaires, feedback, registration forms and the like. We may also ask you to provide additional information, such as your e-mail address, if you wish to obtain additional services, information or to resolve your complaints or concerns. If you decide to invest with us, we will collect additional information to open your account and as required by law.

YOUR CONSENT

We collect, use and share your Personal Information only for purposes related to the products and services we offer and only with your consent, or as permitted or required by law. Your consent may be expressed in writing or it may be given verbally, electronically or through your authorized representative(s) Your consent may also be implied or inferred from certain actions, such as by visiting our Sites, where this Privacy Policy is posted. You may withhold or withdraw your consent for us to collect, use and share your Personal Information, as long as there are no legal or contractual reasons preventing you from doing so. Depending on the circumstances, however, withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested.

WHAT PERSONAL INFORMATION WE COLLECT AND WHY

We collect information from you and about you, only with your consent, or as required or permitted by law. In general, we will collect Personal Information such as your name, address, telephone number(s) or other identifying information, such as your Social Insurance Number (SIN) or date of birth. The information gathered may be financial, which would include such information as you place of employment, annual income, assets and liabilities. It may be investment- or advice-related information concerning such things as your financial goals and retirement plans. Generally, we collect, use and disclose your Personal Information in order to provide you with our products and services (collectively, the “Services”), including to:

  • Confirm your identity, and to protect both you and us against errors, fraud or other misrepresentations.
  • Evaluate your financial needs and determine the suitability of our products and services for you.
  • Determine your eligibility for products and services.
  • Properly administer the products and services we provide.
  • Comply with a variety of legal and regulatory requirements, including securities law requirement, tax reporting obligations under the Income Tax Act and certain terrorist financing and anti-money laundering regulations.
  • To personalize the user experience and improve our services by assessing how our clients use our products and services, and the resources provided on our Sites.
  • To make available, promote and offer services, products and/or special offers.
  • To conduct, process and complete transactions with you.
  • To develop, modify and customize services and offers that would appeal to our clientele.

SECONDARY USES

As permitted by law, we may also use some of your Personal Information for purposes not directly connected to your use of the Services, as set out below. In some cases, you may choose not to participate in such activities, or to refrain from providing us with your Personal Information. In other cases, you may opt-out of the use of your Personal Information for secondary purposes by contacting us, as set out below under Contact. For completeness, we also note below a number of practices that involve only the collection and use of aggregated information.

With the permission of an online visitor, information submitted at the time of registration or submission may be used for marketing and promotional purposes by Greybrook. If a visitor objects to such use for any reason, he/she may prevent that use, either by e-mail request or by modifying the registration information provided.

If you do not want us to use your Personal Information for secondary purposes, or wish to manage your communication preferences, including to opt out of the receipt of any correspondence from Greybrook in the future, please contact our Privacy Officer at the addresses provided below. Note that you may opt out of the receipt of marketing and promotional email messages at any time by clicking the “unsubscribe” link in any such messages.

Greybrook, in common with many web site operators, may use standard technology called “cookies” on its Sites. Cookies are small data files that are downloaded onto your computer when you visit a particular web site. Cookies identify your browser/IP address – but not you as an individual – to our computers each time you visit our Site.

We may use cookies to create a profile of Site users, detailing their stated and inferred preferences, in order to facilitate a more personalized web browsing experience, including by providing more personalized products and services that are tailored to your needs. We may also use cookies to collect aggregated statistical information about how our Site and its features are used.

Most web browsers contain controls that allow you to block or delete cookies (this is usually done through privacy settings), or to notify you when a request to set one is made. You do not need to enable cookies to visit our Site; however, certain features of our Site and Services depend on the use of cookies. Accordingly, if you choose to block cookies you may not be able to use those features or may lose preferences based on those cookies.

PROTECTION AND RETENTION OF PERSONAL INFORMATION

We will only keep your Personal Information in our records for as long as it is needed to fulfill the purposes for which it was collected, or as may be required or permitted by law. Personal information that is no longer required will be securely destroyed, permanently erased, or reliably de-identified, such that it can no longer be associated with you as an identifiable individual.

We have put in place physical, electronic, and managerial procedures and safeguards designed to protect your Personal Information from unauthorized access, use and disclosure. Greybrook applies security safeguards appropriate to the sensitivity of the information, such as retaining information in secure facilities and making Personal Information accessible only to a limited number of authorized Greybrook employees on a need-to-know basis. In those cases where we may engage a third party to provide Greybrook with services that assist us in providing you with services, such as customer relationship management customization or information technology support, where such a third party requires certain access to Personal Information in order to provide the service in question, we take appropriate contractual and other measures to ensure that the third party has access to only the Personal Information required to provide the service in question, and to ensure that such data is used solely to provide that service, is kept confidential and is protected by appropriate security safeguards.

While Greybrook employs these advanced techniques when interfacing with its clients, representatives and third party service providers, you should be aware that there is a residual risk in transmitting any data electronically. This risk is inherent in all Internet dealings. We assume no liability in the event of any interception, misuse or alternation of data transmitted via the Internet.

Please note that this Privacy Policy applies only to our Sites and not to web sites of other companies or organizations to which our Sites may be linked. You may wish to review the privacy policy on any sites linked to the Greybrook Sites and/or make any necessary inquiries in respect of that privacy policy with the operator of the linked site. These links to third party websites are provided as a convenience and are for informational purposes only. Greybrook does not endorse, and is not responsible for, these linked websites, or any Personal Information that may be collected by these third party sites.

SHARING OF PERSONAL INFORMATION

Greybrook will not share Personal Information that you provide on its Sites to any third parties except: i) in accordance with the terms of this Privacy Policy, and/or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order that requires Greybrook to disclose such information to bodies such as, but not limited to, Canadian and/or international regulatory authorities.

Greybrook may, from time to time, share Personal Information with third parties that we engage to provide services on our behalf, such as, customer relationship management experts and our information technology consultants. We will share with such service providers only the Personal Information that is reasonably necessary for the purpose or service for which the service provider is engaged. We will also use contractual and other means to provide a comparable level of protection while the information is being processed by such service providers, including requiring that any Personal Information that we share be used solely to provide us with the specific service for which they were engaged, and for no other purpose. You can obtain more information about our policies and practices with respect to the use of Personal Information by third party service providers by contacting us as described below, under Contact.

Please note that sharing of Personal Information with such service providers may result in the storage or processing of Personal Information outside of Canada, where it may be subject to the laws of the country in which it is stored, including laws that require the disclosure of Personal Information to governmental authorities under circumstances that are different than those that apply in Canada.

Generally, the disclosure of your Personal Information will be restricted to those who have a need for, and the right to, the information. Only the following persons may be provided with access to your Personal Information:

  • Our employees and representatives who need the information in the performance of their duties for us.
  • Service providers, who need the information in the performance of their duties for us, and to satisfy their obligations to us.
  • Any person or organization to whom you gave consent to access your Personal Information held by Greybrook.
  • Anyone who is otherwise authorized by law.

Finally, we may share or transfer your Personal Information where reasonably required in the context of a sale, merger or amalgamation of all or part of our business or the insurance or securitization of our assets. In any such case, the recipient parties will be contractually required to keep the information confidential and use it only for the purposes of the transaction, or proposed transaction, in question. In the event a business transaction is affected, assignees or successors of Greybrook or our business or assets may use and disclose Personal Information only for the purposes as set out this Privacy Policy, unless further consent is obtained.

ACCESSING AND AMENDING YOUR PERSONAL INFORMATION

We will make all reasonable efforts to ensure that any Personal Information we collect and keep is as accurate, complete and up-to-date as required for the identified purposes. To do so, we will rely on you to provide us with accurate information and to inform us of changes, such as changes in your contact information. Under Canadian privacy law you have the right to access and verify your Personal Information maintained in our files, and to request that any factually inaccurate Personal Information be corrected, if appropriate, subject to certain restrictions provided by law. If we receive a request to release your Personal Information, we will only do so upon satisfactory identification and proof of entitlement of the requestor, or as required or permitted by law. To access or request amendment to the Personal Information we hold about you, please make your request in writing to our Privacy Officer, at the addresses set out below.

CONTACT US

Should you wish to inquire about the Personal Information about you we maintain, or about any other matter relating to our privacy policies, please contact Greybrook’s Privacy Officer at [email protected] or write to:

Privacy Officer
Greybrook Capital
890 Yonge Street, 7th Floor
Toronto, Ontario
M4W 3P4