Samara Family Foundation (hereinafter referred to as Samara) ensures that the personal information you provide to Samara is used only for the purposes for which it was intended in compliance with the Personal Information Protection and Electronic Documents Act, (PIPEDA) and the Act Respecting The Protection Of Personal Information In The Private Sector (the “Quebec Private Sector Act”, together “Applicable Privacy Acts”) The Applicable Privacy Acts notably governs the processing of personal information that individuals provide to companies as part of a commercial relationship. Under the terms of this legislation we are required to obtain your consent with respect to the collection, use and disclosure of your personal information. We have summarized below Samara’s current practices concerning the collection, use and disclosure of our clients’ personal information. Should you have any questions or concerns in connection with these policies contact the Chief Compliance Officer at email@example.com.
When you open an account with Samara, we obtain personal information about you that is kept on file in accordance with industry regulations, such as your name, surname, date of birth, address. Only authorized employees, authorized third-party service providers and regulatory authorities have access to this information. The information that we collect allows us to identify you, to protect you against possible fraud, to assess your investment needs, and to comply with legal and regulatory requirements.
If you are an individual, Samara is required to collect, use and disclose your Social Insurance Number for income tax reporting purposes.
Samara may, from time to time, disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to Samara. We may also rely on external sources, such as credit agencies, to collect personal information about you. In the event of a change of ownership, sale, amalgamation, liquidation, reorganization or acquisition of Samara, in whole or in part, your personal information may be transferred as part of the transaction.
Samara requires your consent to the collection, use and disclosure of your personal information to administer your account in the normal course of business. Your consent is also required before we may provide your information to our affiliates and any third parties for the purposes described in the paragraphs above. In certain situations, however, your personal information may be collected, used or disclosed by us without your consent. These situations include: collection and use of publicly available information specified by regulation; disclosure to legal counsel for the purposes of obtaining advice; collection or use that is clearly in your interests in situations that we cannot obtain your consent in a timely way; use and disclosure to investigate a breach of an agreement or a contravention of a law; disclosure for the collection of a debt that you owe to us; use and disclosure in an emergency that threatens your life, health or security; disclosure to comply with a subpoena, warrant or court order, or to otherwise comply with applicable law, including securities regulatory authorities.
You may access the information you have provided to Samara and make corrections to it. We request that you provide these corrections in writing, addressed to our Privacy Officer listed below: Maxim Saint-Amant Lamy, Chief Compliance Officer Samara Multi-Family Office Inc./Samara Bureau multi-familial inc. firstname.lastname@example.org
We may retain your personal information on file after you cease to be a client of Samara for as long as we require such information or as long as is demanded by regulatory requirements. Having opened an account at Samara, unless you advise us otherwise in writing to the attention of the privacy officer named above, we shall assume that you are providing us with consent to collect, use and disclose your personal information for the purposes as set out herein. Although you may refuse or withdraw your consent at any time to any of these purposes, please be advised that withdrawing your consent in certain circumstances may cause us by regulation, to be unable to administer your account.
We have implemented physical, organizational, contractual and technological security measures to protect your personal information and other data from loss or theft, unauthorized access, disclosure, copying, use, or disclosure and modification, such as: physical measures (e.g., locked filing cabinets and restricted access to offices); organizational measures (e.g., security clearances and limiting access on a “need-to-know” basis); and technological measures (e.g., the use of passwords and encryption). We have taken actions to ensure that only Samara’s employees who need to access your personal information in the course of their duties have access to it.
Your personal information is currently stored in Canada.
We will update this Policy from time to time to reflect the changes in our practices, our technology, our legal obligations and other factors. Please see “Last Update” at the bottom of this page for the latest update of this Policy. Last update Adoption: February 2021