SEI Investments Canada Privacy Policy

Last Modified: September 2017

SEI Investments Canada Company (ďSEIĒ) recognizes the importance of respecting identifiable information about individuals (ďPersonal InformationĒ) that is collected through all of its standard and online business processes. SEI is committed to protecting the confidentiality and integrity of the Personal Information to which it has been entrusted by its clients, in accordance with laws and regulations governing collection, use and disclosure of Personal Information that are applicable to SEI, including applicable provisions of the Personal Information Protection and Electronic Documents Act (ďPIPEDAĒ).

The following is SEIís Privacy Policy and Procedures (ďPolicyĒ) which have been prepared in accordance with the 10 fair information principles incorporated into PIPEDA.

Personal Information Collected:
SEI may collect Personal Information from individuals on its own behalf where SEI provides services directly to such individuals.

Where SEI acts as a service provider for institutional entities (such as pension plans and endowments), SEI does not collect any Personal Information on its own behalf, but only collects, uses and discloses Personal Information by, and in accordance with the instructions of, such institutional entities.

In certain circumstances where you and SEI have established or are considering establishing a relationship through an advisor or consultant, SEI may collect Personal Information during the course of its normal business activities, such as information provided to the advisor or consultant in connection with a client or prospective clientís interaction and relationship with SEI and as may otherwise be permitted by law.

Where SEI collects Personal Information on its own behalf, it may collect Personal Information such as name, address, phone number, email, date of birth, Social Insurance Number, personal income, investment information and other financial or lifestyle information necessary for SEI to provide services to you and to meet SEIís regulatory obligations. SEI may also collect Personal Information that individuals provide through the course of normal correspondence with SEI.

Consent:
Your provision of Personal Information to SEI means that you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. You may withdraw your consent at any time by contacting SEIís Privacy Officer. Please note that withdrawing your consent will affect SEIís ability to continue to provide products and services to you and that you may be required to close your account where, by law, SEI is required to collect and use your Personal Information in order to maintain the account. If SEI uses your Personal Information for secondary purposes, such as sending you marketing material, you may opt out of such use by contacting SEIís Privacy Officer. If you have questions about this Policy, please contact SEIís Privacy Officer as indicated below.

Visiting the SEI Website:
Cookies. This Policy applies equally to all Personal Information collected by SEI on its own behalf including information collected on the SEI website. This site uses cookies (files sent by us to your computer) and may store information about you, which we can access when you visit our site. SEI does this in order to assist in pre-filling forms (so you donít have to enter the same information twice), as well as direct you to the last SEI regional site you visited, among other things.

You can accept or decline cookies by modifying your browser settings. To do so, refer to the instructions for your file management software. Cookies associated with SEI sites will include the file name ď@www.seic.comĒ. By deleting or declining cookies, you may not be able to use some interactive features or access certain areas of the site that depend on cookies.

Clear GIFs. This site may also use clear GIFs (a.k.a. web beacons, web bugs or pixel tags) which are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, though, clear GIFs are embedded invisibly on web pages, not stored on your hard drive. We might use clear GIFs to track the activities of visitors on the SEI website and compile statistics about usage.

Third-Party Analytics. SEI may also use automated devices and applications such as Google Analytics (to opt out, go here) to evaluate usage of the SEI site. SEI uses these tools to gather information about users to help it improve its services, performance and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the anonymous information that they collect about you with other information that they have collected. This Privacy Policy does not cover such third partiesí use of the data: for further information please see the relevant party's privacy policy.

Do-Not-Track. Currently, SEIís systems do not recognize browser ďdo-not-trackĒ requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or opting out of ad networks).

Identifying Purposes Ė How SEI uses Personal Information:
Where SEI is a service provider for an individual, SEI will collect and use Personal Information to:

  • establish and service the individualís account and respond to requests made by or on behalf of the individual;
  • develop and offer additional products and services that SEI believes may fit the individualís needs and to communicate, advise and inform the individual about such additional products and services all in accordance with its obligations under applicable anti-spam legislation;
  • †maintain key contact information in SEIís contacts database;
  • compile statistics about SEIís client base and conduct market research;
  • protect against error and fraud;
  • meet regulatory requirements; and
  • satisfy legal, regulatory and other requirements of industry organizations that SEI is or may become a member of, such as the Mutual Fund Dealers Association of Canada or the Investment Industry Regulatory Organization of Canada.

Where SEI acts as a service provider for institutional entities, SEI will only act on Personal Information provided by its institutional clients. This may be done through the course of normal business activity, such as through SEIís dealings with the institutional entities other service providers and as part of the services provided by SEI. To the extent you are a customer of any of these institutional entities, you should contact such entity directly regarding how they collect and use Personal Information that you provide to them. To the extent you direct any such questions to SEI, SEI will endeavour to redirect such questions to the institutional entity with whom you do business.

Use of Service Providers Outside of Canada:
SEI may utilize third parties outside of Canada (including SEI affiliates) to perform services on behalf of SEI. SEI may transfer Personal Information to such service providers, including those located in the United States, to the extent appropriate for such service providers to perform the services for which they have been engaged by SEI and as permitted by law. Such service providers are contractually obligated to protect the confidentiality and security of the Personal Information they receive in accordance with this Policy. Please note that when your Personal Information is located outside of Canada it will be subject to the laws of the country in which it is situated and these jurisdictions may not have an equivalent level of data protection laws as those in your country.

If you have any questions regarding SEIís use of service providers outside of Canada, please feel free to contact SEIís Privacy Officer as indicated below. In addition, requests for written information about SEIís policies and practices regarding service providers outside of Canada should also be directed to SEI's Privacy Officer.

Limited Disclosure of Personal Information:
At SEI we are committed to safeguarding your Personal Information and maintaining your privacy. Except as provided in this Policy or as permitted by law, we do not sell or disclose Personal Information to third parties unless we have your prior written consent.

Personal Information collected by SEI may be subject to transfer to another company in the event of a change of ownership of all or part of the organization. This will only occur where the parties have entered into an agreement under which the collection, use and disclosure of Personal Information is restricted to those purposes that relate to the business transaction, including a determination of whether or not to proceed with the business transaction.

SEI also shares Personal Information with the following parties:

  • parties representing individual clients, such as representatives of an investment dealer or mutual fund dealer, or other third parties as directed by the individual;
  • an affiliated company or a third party service provider to enable them to provide business services for SEI, such as performing general administrative activities and/or assisting in processing transactions; and
  • regulatory and government entities as part of normal legal/regulatory requirements.

Social Insurance Numbers:
Notwithstanding the foregoing, SEI will only use and disclose an individualís SIN to the extent required by law.

How SEI Protects Personal Information:
SEI utilizes physical, organizational and technological safeguards in order to protect the Personal Information under its control against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Only authorized SEI employees are permitted to have access to files maintained on SEIís premises and such employees are made aware of the importance of keeping your Personal Information confidential. All SEI employees complete mandatory privacy training at least annually. SEI will only retain your Personal Information for as long as is necessary to fulfill the purpose for which it was collected or to meet legal or business requirements, after which it either deletes or anonymizes your Personal Information rendering it unable to identify you.

Accountability:
SEI has appointed a Privacy Officer who is responsible for implementation and ongoing compliance of this Policy. Every employee of SEI is also required to abide by the Policy and maintain the confidentiality of Personal Information that is collected and used by SEI.

Changes to this Privacy Policy:
SEI may, from time to time, update this Policy to reflect changes to its practices with respect to the collection, use and disclosure of Personal Information. You are responsible for reviewing this Policy periodically and informing yourself of any such changes to this Policy provided that SEI will notify you of any such changes to the extent required by applicable law.

Questions About or Access to your Personal Information:
SEI is committed to protecting your Personal Information and ensuring that it is kept up to date, accurate and complete as necessary for the purposes for which SEI uses the data. To ensure the continued quality of service provided, please advise SEI if your Personal Information has changed.

Where SEI has collected Personal Information about you on its own behalf, please contact SEIís Privacy Officer at the address below to:

  • ask questions about the collection, use or disclosure of Personal Information by SEI;
  • request written information about SEIís policies and practices regarding service providers outside of Canada;
  • request access to your Personal Information at minimal or no cost to you;
  • update your Personal Information that is inaccurate, incomplete or out of date; or
  • register a privacy-related complaint in the event of any conflict or other concern regarding access to, or the accuracy or use of, your Personal Information.

SEI Investments Canada Company
Attention: Privacy Officer
130 King Street West
Suite 2810, Toronto, ON
M5X 1E3
Phone: 416 777 9700
Email: privacyofficecanada@seic.com