Privacy Policy

Prime Quadrant is required to collect private information from our clients and prospective clients in order to properly fulfill our duties. Understanding a client’s needs and wants, financial position and family issues enables us to ensure that all investment recommendations are suitable. This is both a regulatory requirement and good business. Prime Quadrant is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This policy explains the measures we take to fulfill these commitments.

We ask our clients for no more personal information than necessary.

The “KYC” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone and fax numbers, e-mail addresses, birth date, social insurance numbers, asset holdings and values, investment knowledge and objectives, spouse’s name and occupation, and children’s and dependents’ names and ages. Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including, social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Policy.

We limit access to clients’ personal information.

We record clients’ personal information electronically on computer servers to which only authorized persons have access. Relevant employees may only access information by means of secure passwords. We authorize employees to have access to clients’ personal information only on a “need to know” basis. We have installed hardware and software security to keep our servers clean and secure. We maintain a duplicate copy of our data at an offsite location for disaster recovery purposes. This data is password protected. We keep paper copies of clients’ personal information in filing cabinets. We keep the computers and filing cabinets in which such information is stored in areas of our business premises that are kept locked when not in use.

We prevent unauthorized disclosure of clients’ personal information.

We train our employees to keep clients’ personal information strictly private and confidential. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information. We shred paper documents containing clients’ personal information before discarding such documents.

We expect similar safeguards from our service providers.

We may use service providers to provide us with various services such as technology, administration, printing, marketing, legal and accounting. We will require them to have a similar privacy policy or to agree to acknowledge and abide by ours.

We take privacy seriously.

Prime Quadrant’s Chief Compliance Officer (“CCO”) is responsible for ensuring that Prime Quadrant adheres to its privacy policy. Our CCO is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. We invite any client or prospective client to contact our CCO at privacy@primequadrant.com for any additional clarification desired. A client wishing to review his or her personal information in our possession should send a written request to this effect to our CCO.