“Individual” means any identifiable individual. For legal entities, such as companies, partnerships, or trusts, this includes information about any authorized person, partner, or trustee, as appropriate.
“Services” means any brokerage or financial product or service offered by us.
“You” and “your” mean any data subject from whom we collect, use, or disclose Personal Information in the course of our commercial activities, whether an individual who has made an application to us or signed an application in respect of any Service offered by us, including any co-applicants, guarantors or personal or corporate representatives such as directors or officers, or any data subjects that share their Personal Information via our Website.
Bloom Burton may collect different types of Personal Information from you, including: name, contact information and personal email. Your Personal information may be collected in paper or electronic form.
Bloom Burton will collect and retain Personal Information for a number of purposes and uses including to determine a client’s identity. The collected Personal Information may be used in accordance with the stated purposes above, a requisite ancillary purpose, or for such other use or purposes to which you may later consent.
You may withdraw your consent for us to use your Personal Information by giving us prior written notice.
Personal Information Posted by the Individual
From time to time, Bloom Burton may offer interactive services that allow an Individual to share Personal Information on the Website or through an online portal. These features may permit an Individual to publish Personal Information about themselves or another Individual, although Bloom Burton does not encourage any Individual to share any Personal Information publicly online. By submitting such information, the Individual represents that:
Bloom Burton shall not be liable for any content or information you share in this way.
We strive to keep client information correct, complete and up to date. Clients are requested to advise Bloom Burton of any changes to client information. Bloom Burton is not liable for errors that cannot be corrected without client input. Should an inaccuracy be found, we will act efficiently to correct it at no cost to the client.
If an Individual believes that his or her Personal Information has been posted by a third party without consent, that Individual should contact our Chief Privacy Officer to notify us so that the complaint may be investigated, and the content removed, if it is appropriate to do so.
Disclosure to Agents and Third Parties
To provide our services, Bloom Burton may need to disclose Personal Information to certain third party agents or service providers, including but not limited to our carrying broker, Haywood Securities Inc. Personal Information may also be provided to Bloom Burton’s professional advisors in connection with our business operations, for example, where Bloom Burton undergoes a fundamental business change such as a sale, financing, merger, or a transfer of all or a portion of our business or assets. Personal Information collected from you may be transferred or disclosed outside of the province or territory in which it was collected, including to service providers outside of Canada. In particular, your personal information may be transferred to service providers in the following countries: United States. Bloom Burton shall ensure that third parties accessing your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information.
Disclosure in Compliance with Law
Bloom Burton may also disclose Personal Information to establish or exercise our legal rights or defend against legal claims or in connection with an emergency that warrants use or disclosure of the information.
It may also be necessary for Bloom Burton to disclose Personal Information to law enforcement officials, regulatory bodies, government agencies; law enforcement agencies; securities commissions; stock exchanges; other self-regulatory organizations (“SROs”); or under a court order. Express consent will not be required if needed for: audit, statistical or record-keeping purposes; a legal reason or request by securities or legal regulatory authorities or SRO; to collect a debt owed by the client; to a legal professional for the purposes of obtaining legal advice; and pursuant to a court order. Should Bloom Burton be asked to produce confidential information by any such entity, we will assess whether we have an obligation to comply. In some cases, Bloom Burton may provide information on its own initiative if there are reasonable grounds to believe a crime or a violation of an applicable regulation is involved.
Such Personal Information includes: the client’s given name, surname, and/or contact information including the client’s mailing address, phone number, and email address, as applicable.
Individuals have a right to access and review their Personal Information held by Bloom Burton by making a request to our Chief Privacy Officer. However, an Individual’s right to access is not absolute and may be subject to legal restrictions, such as if providing access to the personal information would impede a criminal investigation or result in the disclosure of other protected information.
Bloom Burton may also deny an Individual’s request to access if granting access would have an unreasonable impact on other people’s privacy or where the requested information cannot be severed from the balance of the record in which it is contained. Access will not be provided to information that has been destroyed or is too costly to retrieve. We will make a reasonable effort to respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.
It is important for Bloom Burton to maintain accurate Personal Information about an Individual in order for us to provide efficient and effective delivery of information. Individuals may contact the Chief Privacy Officer using the contact information provided below to modify or correct Personal Information that Bloom Burton holds about them.
Under certain circumstances, you may also have a right to:
Bloom Burton will not retain any Personal Information longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided or as may be required by any federal or provincial record keeping requirements, whichever is longer. This may involve the retention of your Personal Information for a period exceeding your actual relationship with Bloom Burton. Once Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or rendered anonymous.
We take the security of your personal information seriously and are committed to protecting your privacy by using a combination of administrative, physical and technical safeguards, in accordance with applicable laws.
Threats to Personal Information include loss, misuse, theft, inadvertent disclosure, and improper modification. At all times, Bloom Burton employs reasonable physical, technical, organizational, and digital precautions to safeguard your Personal Information. Bloom Burton restricts access to Personal Information to authorized personnel who are appropriately trained to handle Personal Information.
CASL regulates commercial electronic messages, which are electronic messages including, without limitation, emails, text messages, or other electronic messages that, having regard to the content to the message or hyperlinks in the message, makes it reasonable to conclude that the message has, as a purpose, encouraging participation in a commercial activity (a “CEM”). In compliance with CASL, Bloom Burton will not send CEMs without necessary consent of an Individual. Any Individual who wishes to revoke their consent may opt-out of receiving future CEMs by following the conspicuous unsubscribe mechanism contained in each CEM or by contacting our Chief Privacy Officer, as described below. Any such opt-out will not apply to any communications that are required by law.
If you have any questions about our privacy policies and practices and how they relate to you, please contact our Chief Privacy Officer by telephone at (416) 640-7575, by e-mail at email@example.com or by mail to Bloom Burton Securities Inc., Suite 3410, 181 Bay Street, Toronto, Ontario M5J 2T3, Attention: Chief Privacy Officer.
Clients who remain dissatisfied with the results can bring the complaint to the attention of the federal Privacy Commissioner, who is the ombudsperson for complaints under PIPEDA at: Officer of the Privacy Commissioner, 112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario K1A 1H3, Attention: The Privacy Commissioner of Canada. The request must be made in writing and include full contact details and as much detail as possible about the complaint. Complaints under provincial law should be brought to a provincial privacy regulator.