Pavilion Financial Corporation is committed to protecting your privacy, and maintaining a general policy of openness about how we collect, use and disclose your Personal Information (as defined below).
The purpose of this Privacy Statement is to inform you about our practices relating to the collection, use, disclosure and protection of Personal Information that may be provided through access to, or use of, our web site, and our account opening documents.
This Privacy Statement also explains how you can contact us if you have a question about, want to make a change to, or want to delete any Personal Information that we may be maintaining about you. We strongly recommend that you take the time to read this Privacy Statement and refer to it from time to time.
WHAT PERSONAL INFORMATION WE COLLECT
For the purpose of this Privacy Statement, “Personal Information” is defined as information about an identifiable individual, or information that allows an individual to be identified and which is not business related. As a general rule, Pavilion Financial Corporation does not collect Personal Information. However many of our subsidiaries do collect Personal Information, for example:
- Information on applications and other forms to open an account or provide investment advice to you (such as your name, home or business address, social security number, telephone number, and financial information);
- Information that generated to service your account (such as trade tickets and account statements);
- Information that received from third parties with respect to your account or about your transactions (such as trade confirmations from brokerage firms);
Should you provide us with your Personal Information, we will inform you as to why we are collecting it, and how it will be used.
Certain of our subsidiaries may record and do real time monitoring of all telephone conversations that you may have. You will be informed of that prior to the start of any such recording. Further, all communications by mail, electronic communications system (including, without limitation, email), facsimile or otherwise may be monitored and recorded and archived.
WHEN WE DISCLOSE PERSONAL INFORMATION
Should we collect your Personal Information, we will not sell, license, trade or rent your Personal Information to or with any third party. We may provide your personal information to our subsidiaries for the purposes for which it was collected.
If you provide us with Personal Information, we may provide it to third parties engaged to assist us in providing services to you. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance to us.
We reserve the right to disclose Personal Information to a third party (including, for example, any regulatory or governmental body) if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so, or a request from a regulatory or self-regulatory body.
We reserve the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of the business or assets or shares of Pavilion Financial Corp or a subsidiary thereof in order for you to continue to receive the same products and services from the third-party acquirer.
We shall protect your Personal Information by security measures appropriate to the information we collect. These may include:
- Adopting policies and procedures that put in place physical, electronic and other safeguards to keep your personal information safe;
- Limiting access to personal information to those employees who need it to perform their job duties;
- Requiring third parties that perform services for us to agree to keep your information strictly confidential;
- Protecting information of our former clients to the same extent as our current clients.
At any time, you may also access your file and the personal information held by us, review it, modify it, correct it or request that we delete it by sending a written request to the attention of the General Counsel at 1001 Corydon Avenue Suite 300 Winnipeg, Manitoba, R3M 0B6 Canada. . You may also contact the Chief Compliance Officer of any subsidiary directly as it relates to a subsidiary. Please refer to www.pavilioncorp.com/contact-us/ for mail addresses.