Privacy Policy

 

Fonds de solidarité FTQ

The Fonds de solidarité des travailleurs du Québec (F.T.Q.) (the "Fonds") attaches fundamental importance to the protection of personal information it collects or is disclosed to it, from time to time, by any person with whom it transacts. It is committed to protecting the privacy of its shareholders, employees, partners and agents, including its local representatives, among others, and preserving the confidentiality of personal information provided to it in the course of operations.

OBJECTIVES

The Privacy Policy describes the standards for collecting, using, disclosing and retaining personal information obtained as part of the Fonds' operations. It also explains how the Fonds protects personal information obtained and the right of access such information.

PERSONAL INFORMATION

Personal information is defined as any piece of information or combination of pieces of information that relates to a natural person and allows that person to be identified (such as the name, address, phone number, email address, position, employer, social insurance number, date of birth, banking information).

Personal information must be protected, regardless of its medium or form: written, graphic, audio, video/visual, computerized or other.

COLLECTING INFORMATION

The nature and sensitivity of information collected may vary based on the services provided by the Fonds and the requirements to which the Fonds is subject.

The purposes for which a file is assembled and personal information is collected are determined before or when such information is collected: for instance, upon enrolment, an additional subscription, or a redemption, purchase by agreement or transfer request.

The Fonds notifies any person that it collects information about such person, why it collects such information and how it will use such information The Fonds collects personal information directly from the individuals involved, unless it received a consent to collect such information from a third party or is authorized to collect it by law.

In general, information is collected for the following purposes: to confirm the identity of a person; to create a profile; to open an account; to register or administer a plan; to issue shares; to carry out transactions; to provide services; to maintain records; to produce prescribed documents, such as tax slips and forms; to prevent fraud; to meet regulatory or legal obligations; to disclose information relating to the Fonds, its products and its subsidiaries; to send targeted advertisements; and to ensure that services are adequately managed, such as access and maintenance of websites and online services.

When accessing the Fonds' website

When someone accesses the Fonds' website, some data are automatically collected. In fact, the Fonds' web server can collect the IP address used to access the website.  Such information is used to record the number of visits to the website, measure the average duration of each visit and identify viewed web pages. This enables the Fonds to compile trends and statistics on users and assess the website's performance. Such information may also be used to manage and improve services. Lastly, the IP address provides information on the type of device used to browse the website, which helps optimizing the way the website is displayed based on the device used and facilitates browsing.  

The Fonds is also able to collect data relating to geolocation of its users via the IP address used to access the website. Demographic data collected allow the Fonds to personalize and adapt its communications to the reality and needs of its users, in order to provide a better web experience to users.

The Fonds and some of its partner advertising networks may collect other information about the use of its website, by using what is commonly called "cookies". A cookie is a small information file stored by your Internet browser on your computer's hard drive. Cookies help recognize visitors when they access the website and when they navigate from one page to another. The Fonds and its partner advertising networks, as appropriate, use cookies to identify users' specific interest in certain pages of the website for behavioural retargeting purposes. This way, they are able to display specific advertisements in the form of banners on other websites visited by its users. It is important to note that users have the opportunity to configure the settings of their browser in order to be notified when receiving a cookie. This way, the user will be free to accept or block cookies. 

Lastly, in some cases, it may be necessary for users to transmit certain information for the application and use of other Fonds' websites, such as My Online Account, Employer Extranet, LR Extranet, and their related services. Personal information is collected to manage access to secure sections of these websites, to manage subscriptions to the mailing list, including changing subscription settings and deleting names from the mailing list. Personal information is also collected to enhance the effectiveness of communicating relevant information and to learn more about a user's profile. 

No information other than the one described above is collected by the Fonds when users browse its websites, unless it is voluntarily provided by users. By browsing this website and identifying yourself with your password when required, you agree to the contents of this section. If you refuse to consent to one of them, you need to abstain from using Fonds de solidarité FTQ's websites.

USING AND DICLOSING INFORMATION

The Fonds de solidarité FTQ uses the personal information it holds in a way that maintains its confidentiality.

In this context and only for the above-mentioned purposes, personal information collected may be disclosed to third parties who need to access it in connection with their duties, mandates or contracts to the extent required to fulfil such duties, mandates or contracts. Such third parties could include the Fonds' employees, its subsidiaries and their employees, its service suppliers, including advertising services suppliers, its local representatives and its agents.

The Fonds de solidarité FTQ may also use and disclose personal information collected, to the extent permitted or required by applicable law, in particular to government or tax authorities, or in case it becomes necessary to establish and exercise legal rights in a litigation context. For instance, the Fonds may, without the consent of the person concerned, disclose personal information contained in a file held about others, in particular to the Director of Criminal and Penal Prosecutions, if the information relates to the prosecution for an offence of an applicable law in Québec. In addition, personal information may be shared with other authorized third parties such as securities regulatory authorities, self-regulatory bodies, the Financial Transactions and Reports Analysis Centre of Canada or any other organization authorized by law.

Lastly, a nominal list (list including the names and addresses of shareholders, among others) or an information may be developed and shared with companies related to the Fonds, for commercial or philanthropic prospection purposes, in compliance with the law and by giving the person concerned a valid opportunity to refuse the use of such information by a third party, for commercial and philanthropic prospection purposes (for instance, by allowing the person concerned to request that their name be deleted from the list before the list is disclosed). It is important to note that the Fonds does not sell personal information provided to it in the course of its operations.

RETAINING INFORMATION

The Fonds de solidarité FTQ retains the personal information that is collected as long as necessary for the purposes for which it was collected and in accordance with legislative restrictions.

Personal information collected is held in Canada. It may also be held in any country where the Fonds de solidarité FTQ hires third-party service suppliers who must access it in connection with their duties, mandates or contracts. You consent to the transfer of information to countries other than your country of residence, where data protection rules may differ from those in your country of residence. When information is located outside your country of residence, it is subject to the laws of the country where it is located and may be disclosed to governments, courts or law or regulation enforcement organizations of such country, in compliance with its laws. However, our practices with respect to your personal information remain at all times governed by this Policy.

SECURITY MEASURES

Given the confidential nature of information if holds, the Fonds de solidarité FTQ is committed to put in place the security measures needed to ensure that personal information collected, used, disclosed, retained or destroyed is protected in accordance with applicable laws. The Fonds implements personal information protection policies and procedures and takes reasonable measures to educate and train its employees and local representatives on them.

The Fonds stores information it holds in secure computerized records. In addition, security measures are in place to protect personal information against loss or theft and against any unauthorized viewing, disclosure, copying, use or modification. 

These security measures include administrative measures, such as implementing a normative framework to protect information assets based on the ISO27002 international standard, continuously monitoring the development of threats and deploying activities on an ongoing basis to make employees aware of information security; physical measures, such as restricting access to facilities and encrypting data on physical media; and technical measures, such as restricting logical access by applying the "need-to-know" principle, implementing alerts when suspicious events occur and securely encrypting communications.

Although the Fonds de solidarité FTQ deploys a multitude of security measures to adequately protect the information it holds and minimize the risk of breach, there is always a residual risk and, because of that risk, we cannot entirely guarantee that information will not be viewed, obtained, disclosed, modified or destroyed in an unauthorized manner as a result of a breach of our physical, technical or administrative security measures. If you have reasons to believe that personal information has been compromised, please contact us using the information set out in the "Contact us" section.

RIGHT TO ACCESS, CORRECT AND DESTROY INFORMATION

In certain circumstances and in accordance with applicable laws, individuals can access information about them held by the Fonds by sending a written request to that effect using the contact form in the "Contact us" section of this website. Reasonable fees may be charged for transcribing, reproducing or sending such information.

In addition, in certain circumstances and in accordance with applicable laws, individuals can request that personal information about them held by the Fonds be updated, modified or deleted by sending a written request to that effect using the same contact form in the "Contact us" section.

The Fonds destroys information it holds in accordance with applicable legislation. When the Fonds destroys personal information, it takes the necessary measures to preserve its confidentiality and ensure that no unauthorized person can access it during the destruction process.

CHANGES TO POLICY

The Fonds may change the contents of its websites and the way it uses cookies without notice and, accordingly, it may change its Privacy Policy from time to time. We therefore encourage you to review the Policy every time you visit our website to stay informed on how the Fonds handles personal information. The Fonds will request your consent in accordance with applicable laws when new uses or disclosures of personal information should occur. 

FlexiFonds de solidarité FTQ


Preamble

FlexiFonds de solidarité FTQ ("FlexiFonds"), a wholly-owned subsidiary of the Fonds de solidarité FTQ, is committed to protecting the privacy of its clients, that is, any person who has opened an investment account with FlexiFonds, and its employees, and to ensuring the confidentiality of the personal information entrusted to it for the purposes of its activities, while complying with the Act Respecting the Protection of Personal Information in the Private Sector (the "Act").

Policy objectives

The privacy policy outlines the terms and conditions concerning the collection, use, disclosure and storage of personal information obtained in the course of FlexiFonds’ business. The policy explains how FlexiFonds protects the personal information it obtains and all access rights to it.

Scope of the policy

The policy applies to all FlexiFonds staff, including mutual fund representatives, salaried employees and executives. This policy also applies to individuals whose professional services are retained on a contractual basis. They are referred to individually as "employee" and collectively as "employees", unless otherwise specified.

Personal information

Personal information is defined as any information or combination of information that serves to identify a physical person, such as name, address, phone number or email, and the value of investments held in the client's account. This list is non-exhaustive. Employees must consult the chief compliance officer when in doubt as to the nature of a piece of information concerning a physical person, to determine if it is considered personal information.

Personal information must be protected regardless of the medium or form, whether written, graphic, sound, visual, computer or any other form.


Detailed provisions

Collection of information

FlexiFonds must collect information concerning its clients and employees in order to provide premium quality services or as part of FlexiFonds' business. The nature and sensitivity of information collected may vary based on the services provided by or to FlexiFonds, as well as the legal requirements with which FlexiFonds must comply.

The purposes for which a file is created and personal information is collected are determined before or at the time the information is collected. For example: when opening an account; making an additional investment; submitting a request for a redemption or a switch.

The purposes for which information is collected are generally to open an account, confirm a person's identify, understand the client's needs, propose financial products and services that may meet the client's investment objectives, prevent fraud, issue the required tax slips and communicate information concerning FlexiFonds and the products it distributes.

Consent, collection and use

Flexifonds informs every person that it is collecting information about them, the purposes for which it is being collected and how the information will be used.

Consent must be given by the individual concerned or by a duly authorized person. Flexifonds collects personal information directly from the individuals concerned, unless consent has been obtained to gather information from a third party, or as authorized by law.

Consent may be withdrawn at any time, subject to legal or contractual restrictions.

In the event that a client refuses to give consent or withdraws consent, flexifonds may not be able to provide them with products or services likely to be of interest to them.

Limits for collecting, using and disclosing information

FlexiFonds limits the collection of personal information to what is necessary for the purposes of its mutual fund brokerage activities, particularly as principal distributor of the Fonds de solidarité FTQ's investment fund units defined as "FlexiFonds Funds." In addition, this personal information is accessible only to the persons authorized to access them and for whom it is necessary to discharge their duties.

FlexiFonds may not divulge any personal information to anyone without obtaining prior consent except where required by Law. For example, FlexiFonds may, without consent from the person concerned, disclose personal information in a file it holds on that person, in particular to the Director of Criminal and Penal Prosecutions, if the information is needed for purposes of prosecution for violating a law applicable in Quebec.

Sharing personal and financial information with the investment fund manager is an inherent part of the role of principal distributor that is played by FlexiFonds. Much information deemed necessary to be collected by FlexiFonds employees must also be accessible to the Fonds de solidarité FTQ—the investment fund manager of the FlexiFonds Funds.

Additionally, personal information may be shared with third parties such as securities regulatory authorities, self-regulatory organizations, the Financial Transactions and Reports Analysis Centre of Canada and any other body authorized by law.

FlexiFonds may share, under certain circumstances, personal information with third-party service providers or suppliers to ensure the proper administration of services such as access to, servicing and maintenance of the computer platform; the printing of statements of accounts and tax slips; and marketing activities.

Retention and destruction

FlexiFonds retains personal information for as long as necessary for the purposes for which they were collected and in accordance with legislative restrictions. FlexiFonds must destroy such information in accordance with the applicable legislation and regulations. When FlexiFonds destroys personal information, it takes the necessary measures to ensure confidentiality.

Nominative list

A list of names (comprising the names and addresses of clients) may be compiled and shared, or information serving to compile such a list may be shared, with companies related to FlexiFonds for the purpose of commercial or philanthropic prospecting, in accordance with the law and by giving the people concerned a valid opportunity to refuse that this information be used by a third party for the purposes of commercial or philanthropic prospecting (e.g. by allowing the person concerned to request the removal of their name prior to the list being disclosed).

FlexiFonds does not sell personal information that has been entrusted to it as part of its business operations.

Accuracy

FlexiFonds makes every effort to ensure that the personal information it holds is as accurate and comprehensive as necessary for the purposes for which it was collected, used and disclosed.

However, it is the responsibility of every client and employee to promptly inform FlexiFonds of any change in name, address or any other relevant modification to be made to the client's personal information.

Responsibility

FlexiFonds is responsible for all personal information it has in its possession, including information entrusted to third parties.

FlexiFonds takes reasonable steps to inform and train its employees on its policies and procedures concerning the protection of personal information.

Security measures

Security measures are in place to protect personal information against loss or theft, or any unauthorized access, disclosure, copying, use or modification.

These security measures include organizational measures such as restricted access to what is necessary, physical measures, and technological measures such as the use of passwords.

Requesting access to information and correction

Any person has the right to know if FlexiFonds holds personal information about them, to view this information, obtain a copy of it, check its accuracy, request a correction and find out to whom the information may have been disclosed.

The information will be provided within thirty (30) days of receiving a written request. A reasonable fee may be charged to cover the costs of transcription, duplication or transmission of information.

FlexiFonds may refuse to disclose to a person certain personal information about them when required to by Law, in particular if disclosing such information could result in revealing personal information about a third party.

All requests for information or correction must be submitted to the following address:

Chief Compliance Officer
FlexiFonds de solidarité FTQ
545 Crémazie Blvd. East
Suite 200
Montréal, Québec H2M 2W4

Concerns and complaints

FlexiFonds employees can address any questions and concerns about the protection of personal information and anyone can seek information by contacting FlexiFonds at 514-850-4981 or 1-833-383-2121 or by email at info@flexifondsftq.com.

Any complaint concerning the protection of personal information must be submitted to the Officer in Charge of the Protection of Personal Information at the above address.