Privacy Policy
The Purpose of our Privacy Policy
In keeping with our mission to provide personalized investment strategies designed to meet the wealth objectives of you and your family, with an absolute commitment to honest and integrity, Elysium Wealth Management Inc. (hereafter called Elysium) has drafted this document to inform you about how we safeguard the information you provide to us.
Safeguarding your confidentiality and protecting your personal and financial information has always been fundamental to the way we conduct our business. We have always been committed to maintaining the accuracy, confidentiality, and security of your personal and financial information. As part of this commitment, we have established this Privacy Policy document to govern our actions as they relate to the use of the information you provide to us.
Our Privacy Policy is based on the following principles:
The Purposes for Collecting Personal Information
We are in the business of maintaining a long-term relationship with you. We recognize that an important aspect of our relationship is having comprehensive knowledge of you and your needs. Knowing more about your family, the assets you hold elsewhere, your financial goals, retirement plans, tax situation, trusts, will and estate plans, etc., ensures that we thoroughly understand your goals and objectives. It also helps us identify your financial needs, and enables us to recommend investment solutions that can help you realize your goals and manage your financial affairs more effectively.
Elysium will identify the purpose(s) for which your personal information is collected. The purpose(s) will be identified before or at the time the information is collected.
The two primary types of information used are:
1. Personal and financial information
We use your personal and financial information to communicate with you, process applications and effectively provide the services you have requested. The better we know you, the better we can help you achieve your financial goals.
2. Anonymous/non-personal electronic information
We occasionally collect anonymous/non-personal information. This type of information cannot be associated with or traced back to a specific individual or business entity. For example, our web servers collect some anonymous/non-personal information automatically when you visit our company's web sites. Gathered electronically, this information may include the pages you visited, the type of web browser you are using, the level of encryption your browser supports and your Internet Protocol address. The anonymous/non-personal information collected may be used for research and analytical purposes. For example, we are able to determine how many times our website has been visited, but we do not know any specific information about those visitors.
Accountability
Elysium is responsible for maintaining and protecting your information under our control. This includes information in our physical custody or control, as well as personal information that has been transferred to a third party as part of our ongoing business operations. To ensure accountability, we have a designated Privacy Officer who is accountable for our company's compliance with this privacy policy.
Consent of the Individual
Your knowledge and consent are required for the collection, use or disclosure of your information except where required or permitted by law. We will not ask for your consent unless we have made a reasonable effort to inform you of the purposes for which we will be collecting, using and/or disclosing your personal information.
Your consent may be expressed in writing or be implied and you may give it to us verbally, electronically, or through your authorized representative. You may withdraw your consent at any time by contacting Elysium's designated Privacy Officer.
Limits on Collection
The information we obtain from you will be limited to those details required by Elysium to conduct our business effectively. This information will always be collected by fair and lawful means.
The type of information we usually collect and maintain in your client file may include:
For Personal Clients
Name
Mailing Address
E-mail Address
Telephone Number
Social Insurance Number
Date of Birth
History of Employment
Estimated Annual Income
Previous Investment Experience
Bank Account Numbers
Driver's License or Passport Information
Information about your family members
Information regarding estate planning
For Corporate Clients
Business Name
Business Mailing Address
Business E-mail Address
Business Telephone Number
Name(s) of Owner(s), Officer(s) and Director(s)
Articles of Incorporation
Trading Resolutions
History of the company
Restrictions on a public corporation
In addition, we will collect the same types of information we obtain from our personal clients for each director or officer of the corporation.
We are committed to protecting the confidentiality of your personal information.
All the information you provide to us is kept strictly confidential.
Limits on Use, Disclosure and Retention
Your personal information collected by Elysium will not be used or disclosed for purposes other than those for which it was collected, except with your informed consent or as required by law. This information will be retained as long as necessary for the fulfillment of those purposes.
We only use your personal information for the purposes that we have disclosed to you. If for any reason your information is required to fulfill a different purpose, we will notify you and ask you for your consent before we proceed.
As a condition of their employment, all employees of Elysium are required to abide by a Code of Ethics and Standards of Professional Conduct and the Privacy Policy we have established. In addition, all employees must abide by all applicable laws and regulations. Our employees are aware of the importance of protecting your privacy and confidentiality and they are required to sign a code of conduct that prohibits the disclosure of your information to unauthorized individuals or parties. To reinforce their understanding and commitment to upholding client privacy and confidentiality, employees periodically receive updates about our privacy policies.
Unauthorized access to and/or disclosure of your personal information by an employee of Elysium is strictly prohibited. All employees are expected to maintain the confidentiality of your personal information at all times and failing to do so will result in appropriate disciplinary measures, which may include dismissal.
Elysium sometimes contracts with outside organizations to perform specialized services such as custody of securities and record keeping. Our trusted service suppliers may at times be responsible for processing and handling some of the information we receive from you.
When we contract our suppliers to provide these specialized services, they are given only the information necessary to perform those services. Additionally, they are prohibited from storing, analyzing or using that information for purposes other than to carry out the service they have been contracted to provide. Our specialized service suppliers are bound by strict contractual obligations that have been designed to protect the privacy and security of our clients' personal information. As part of our contract agreements, our suppliers and their employees are required to protect your information in a manner that is consistent with the privacy policies and practices that Elysium has established.
Accuracy
Elysium will ensure that all your personal information will be accurate, complete and up-to-date as is necessary to fulfill the purposes for which it is to be used. You can contact the Privacy Officer to access and/or correct your personal information that is in our custody and control.
Safeguarding Customer Information
Elysium will ensure that your personal information will be protected by security safeguards against loss or theft, unauthorized disclosure, copying, use or modification. These safeguards will be appropriate to the sensitivity level of the information.
We safeguard your personal information by using state-of-the-art technologies and maintain current security standards to ensure that all your personal and financial information is protected against unauthorized access, disclosure, inappropriate alteration or misuse.
Electronic files are kept in a highly secured environment with restricted access. Paper-based files are stored in locked fire-resistant filing areas. Access is also restricted.
We manage our server environment appropriately and our firewall infrastructure is strictly adhered to. Our security practices are reviewed on a regular basis and we routinely employ current technologies to ensure that the confidentiality and privacy of your information is not compromised.
If you choose to access your account information electronically, or send information from secured sites, encryption will scramble your data into an unreadable format to inhibit unauthorized access by others.
To safeguard against unauthorized access to your accounts, you are required to "sign-on" using an encrypted password to certain secured areas of the Elysium web site. If you are unable to provide the correct password, you will not be able to access these sections. Your password information is encrypted which is presently the most effective way to secure data.
Passwords are necessary to identify you and authenticate their permission to access their accounts electronically. Just as it is important for Elysium Wealth Management to employ strict procedures to safeguard your information, we encourage you to take precautions in handling their passwords. When selecting a password, we suggest that they use a combination of letters and numbers and do not use words that can be easily associated with them such as the name of a family member, a pet or the street on which they live. We also suggest that you change their password regularly.
Openness
Elysium will make readily available all relevant information about our policies and practices relating to the management of your personal information. We believe that openness and transparency are essential to ensure your trust.
Access
Upon request, you shall be informed of the existence, use and disclosure of your personal information, and shall be given access to it. You may challenge the accuracy and completeness of their information, and may request that it be amended, if appropriate.
At Elysium, the investment decisions we make are often based on the information we have in our files. Therefore, it is important that your personal and financial information is accurate and complete. To help us keep your personal information up-to-date, we encourage you to amend inaccuracies and make corrections as often as necessary. Despite our best efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file(s), we will make the proper changes and provide you with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally received incorrect information from us.
To make a change to your personal contact information contained in your file, please call us at 1-204-989-6200 or contact our Privacy Officer or your Portfolio Manager.
Inquiries and Suggestions
You may direct any questions or enquiries with respect to the privacy principles outlined above or about our practices by contacting our Privacy Officer at:
Elysium Wealth Management
1220-One Lombard Place
Winnipeg, Manitoba
R3B 0X3
Updating this Policy
Any changes to our privacy policy and information handling practices shall be acknowledged in this policy in a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so. You may determine when this policy was last updated by referring to the modification date found at the bottom of this document.
Last Modified: March 3, 2003