AGF Privacy

In accordance with current federal and applicable provincial legislation, AGF has adopted privacy practices to prote

Founded in 1957, AGF Management Limited is an independent and globally diverse asset management firm and trades on the Toronto Stock Exchange under the symbol AGF.B. AGF Investments Inc., a wholly owned subsidiary of AGF Management Limited, manages and advises on a variety of investment solutions managed by its fundamental and quantitative investing teams. The firm’s investment solutions, extend to a wide range of clients, from financial advisors and their clients to high-net worth and institutional investors including pension plans, corporate plans, sovereign wealth funds, endowments, and foundations.

AGF Management Limited and AGF Investments Inc. (together, referred to as “AGF”) are committed to protecting your privacy and safeguarding the confidentiality of the personal information that we collect and maintain in the course of conducting our business. This privacy notice contains important information about AGF’s privacy policy and practices. It describes what personal information we collect from you, how we collect it, and how we hold, use and disclose it.

Personal Information

Personal information refers to information that identifies you. It may include information such as your age, marital status, employment history, social insurance number, credit history, home address, personal email address and telephone number.

What information do we collect?

If you are an investor, depending on the investment or service, the personal information we collect may include your name, mailing address and phone number(s), social insurance number, birth date, account holdings and transactions and the name, address and social insurance number or your spouse and/or beneficiary. If you have established a pre-authorized payment plan, we will maintain your financial institution account number. Where you provide personal information about another individual, you represent to us that you are authorized to disclose such information to us.

If you are a financial advisor who uses the sections of our website restricted to financial advisor, we collect your name, email and contact information, as well as information on the types of tools, products and services that may interest you based on your use of our website.

If you are a member of the public, AGF will collect your name and contact information so that you may subscribe to receive educational and marketing materials from us.

When you use calculators and planning tools on the site, you may need to enter information such as your age or the amount of money you wish to invest. We don’t collect or store this kind of information. It’s only used to perform the calculation you’re asking for.

Why do we need your Personal Information?

We require your personal information to establish a relationship with you and provide you with the best possible service – the better we know you, the better we can serve you. Your signature, financial history, current financial position, social insurance number, age and other similar personal information allow us to:

Establish your identity;
Understand and assess your eligibility for our products and services;
Provide you with the services you have agreed to obtain from us;
Protect you and us from error and fraud
Manage our business operations; and
Comply with the law.

How do we obtain your personal information?

Personal information is collected either directly from you or through a financial services professional such as a financial advisor. We obtain personal information when clients or financial advisors send us completed applications, agreements, forms, or other documents by paper or electronically. In servicing accounts, we may also generate personal information, including transaction information and account statements. We may also be required to collect personal information from a third party who is not a financial advisor, such as an executor or an estate or a third-party consultant) or an AGF affiliate.

How do we use your personal information?

We may use your personal information for the following purposes:

To identify you;
To ensure our records are accurate;
To establish and administer your account;
To execute your transactions;
To maintain, store, record and determine your account holdings and transaction records;
To verify previously given information when necessary;
To provide you and your representatives with account statements/information;
To provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
To provide you with quality customer service and support on your investment needs;
To protect the interests of AGF, such as the collection of a debt owed; and
To meet legal and regulatory requirements.

For financial advisors using restricted areas of our website, we collect your personal information to ensure that we can keep you informed of other products and services. In addition, we will use your personal information to identify you for the purposes of logging into password protected areas of our website and applications, to issue CE credits and to manage events.

When you use our website, read our emails, or engage with us through an electronic device, we and our third parties will automatically collect information about how you access content and about your device. We use this information to analyze the use of our service, improve our service offerings, and provide you with information and offers. This information is normally collected by us and our third-party partners via tracking technologies, including cookies, tracking pixels, and embedded scripts. We may also collect information regarding your IP address, location, network connection (e.g., Wi-Fi, Bluetooth, near field communication), Internet search provider, device identifier and advertising identifiers. We may combine such information with other personal information that we have obtained directly from you and may also use this information to create anonymized data and to compile aggregate data for internal and external business purposes.

Obtaining Your Consent

Before or at the time you open an account with AGF, you will be required to provide certain personal information to establish the account. The information may be collected via an AGF application form, in which case you will formally indicate your consent for AGF to collect and use the personal information when you sign the application. The information may also be provided by your financial advisor to AGF, in which case, by virtue of account opening, your consent is implicitly provided to AGF to collect and use the information. In this case, at the time of initial collection of your personal information by your financial advisor, you will have provided consent to your financial advisor to disclose your personal information for the purposes of effecting investment transactions, including the opening of accounts with AGF.

Who do we disclose your personal information to?

Your personal information will only be used for stated purposes to assist us in providing you with the best possible service. AGF may also provide your personal information to other third parties. This is done only to meet your service requirements or as may be required by any relevant law. Third parties that may be provided with your personal information include:

Your financial representative;
Other financial institutions, securities dealers and mutual fund companies;
Other AGF affiliates;
Third-parties who provide services for us, such as account statement preparation and mailing companies, courier companies, imaging companies and document storage companies, events and meeting platform management, marketing, surveys and market research, regulatory compliance and fraud prevention;
Canadian or foreign governments, government agencies and regulators; and
Any other legally required institutions.

Contracts between AGF and third-party service providers ensure appropriate controls and protections and are in place at the service provider level to protect your personal information. We may use third parties outside of Canada, including in the United States, to perform services for us involving personal information. When AGF transfers personal information to our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes set out in this notice and that the third party provides a comparable level of protection for that personal information.

Our service providers may also, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and require access to certain personal information to perform contracted services. In this case, AGF’s service providers are responsible for ensuring appropriate security measures and controls are in place to protect your personal information from unauthorized use, loss, theft, alteration, and destruction. Personal information available to service providers in foreign jurisdictions may be disclosed to local authorities as may be prescribed by law.

Disclosing your personal information when required or permitted by law

AGF may disclose your personal information to third parties where permitted or required by law, such as in response to a search warrant, court order or other legally valid request. We may also disclose your personal information to help us collect a debt owed by you or for government tax reporting requirements.

AGF’s third-party service providers may also be required to provide your personal information in response to local legal requirements, not unlike Canadian requirements.

AGF may be required to provide certain of your personal information to comply with foreign laws applicable to AGF or any of the products and services AGF may provide. Where required by law or legally valid request, AGF does not require your consent to disclose your personal information.

Withdrawing your consent

You may withdraw your consent for the collection and use of your personal information by contacting AGF at any time. As AGF is required by law to obtain and collect certain personal information about you to maintain an account, you may be prevented from withholding your consent without closing your account. In addition, certain services and products may no longer be provided to you, in the event you withhold consent to the use of information upon which such services and products are dependent and/or required by rules and regulations that govern them.

Access to and accuracy of your personal information

Upon request, AGF will provide you with reasonable access to your personal information we have on record at the time of the request. In addition, and if requested, AGF may provide you with a list of third parties, to whom your personal information was provided. We will provide you with the requested information within 30 days of receipt of your written request. In certain circumstances, AGF may not be able to provide you with access to specific pieces of information in the following instances:

information containing references to other individuals
proprietary information of your financial advisor, the dealership or AGF or its affiliates
information that has been destroyed
it cannot be disclosed for legal or regulatory reasons

If we are unable to provide you with access to your personal information, we will give you an explanation.

You may update your personal information at any time by contacting AGF. AGF is only required to collect and update personal information it requires to service your accounts. AGF is not obligated to collect personal information unrelated to the servicing of your account.

Where is your personal information kept?

Data is stored on secure servers, whether on-site or in cloud-based servers operated by third-party service providers selected for data security standards. Where necessary, we may also maintain physical copies of data using paper files, securely housed in monitored environments.

We acknowledge that, as part of our operations, your data may be processed by third-party service providers in jurisdictions outside Canada. International data processing may be necessary to deliver our services and support.

Protecting Your Information

AGF has developed a Cybersecurity program designed to implement the technical and operational controls as mandated by its Corporate Information Security Policy. Our program covers Governance, Risk Assessment and Information Risk Management, Physical Security, Network/Logical Security, Endpoint Security, Data Loss Prevention, Security Incident and Event Management, Infrastructure and Platform Security, Vulnerability Management, Mobile Device Management, Third Party/Vendor Risk Management and a Security Education and Awareness Program.

Our employees and service providers have access to your personal information only for the purposes set out in this notice to enable them to perform their duties in servicing you. Every AGF employee is responsible for ensuring the confidentiality of all personal information that they may access. Each employee annually signs off on AGF’s Privacy Policy and completes mandatory privacy and cybersecurity training to ensure that they understand their related responsibilities and obligations.

Despite AGF’s continued focus and investment in cybersecurity, there may be occasions when an attacker is able to circumvent an existing security control or identify and exploit a new vulnerability. In the event of a security-relevant incident, AGF will take all reasonable measures to contain and remedy the impact and duration of the incident. If a security-relevant incident results in the potential risk of harm, disclosure of sensitive information or risk of theft of identity and/or assets, AGF will contact you as soon as possible. At AGF, we take the responsibility of securing your personal information very seriously and we will exercise our duty of care to mitigate risks to this information.

How long do we keep your personal information?

In order to service your account and to meet regulatory and legal obligations, AGF may be required to maintain information related to you and your account for a certain period of time. Personal information may be destroyed or anonymized once it is deemed that your information is no longer necessary for the above-mentioned reasons. Personal information is destroyed in accordance with our records management and destruction policies.

How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.

Complaints

AGF is committed to treating you with respect and consideration in all dealings. From time to time however, a misunderstanding or error may occur regarding matters of privacy. In such circumstances, AGF will act diligently to resolve the problem and will contact you as soon as possible within 30 days of our receipt of your complaint.

Updating this Notice

If we find it necessary or desirable to make changes to this privacy notice in the future, we will post changes on our website as soon as they go into effect. You have a right to know at all times what information we collect, how it is used, and under what circumstances we can disclose it. Any change to this notice will become effective on the date the change is posted on our website. We recommend that you print a copy of the updated policy for your reference and revisit it from time to time to ensure you are aware of the changes.

Requests and Inquiries

If you have any questions or privacy related requests or concerns, please contact our Client Services Team at:

Client Services & Administration:

Phone: 1-800-268-8583 or 905-214-8203
Fax: 905-214-8243
Email: tiger@agf.com
Mail:
AGF Investments Inc.
Client Services
CIBC SQUARE, Tower One
81 Bay Street, Suite 4000
Toronto, Ontario M5J 0G1

We will respond to your requests and inquiries in a timely fashion. If speaking with us does not resolve your question or concern, you may contact our Chief Privacy Officer at:

Phone: 1-800-268-8583
Chief Privacy Officer: 416-367-1900
Fax: 416-865-4220
Email: agf_privacy@agf.com
Mail:
CIBC SQUARE, Tower One
81 Bay Street, Suite 3900
Toronto, Ontario M5J 0G1
Attention: Chief Privacy Officer

AGF will respond to your complaint in a timely fashion. Should you find that the proposed solution is unacceptable, you may contact the following institutions:

For more information about privacy, or if after contacting the Chief Privacy Officer your concern has not been resolved, you may contact the Office of the Privacy Commissioner of Canada or the Office of your provincial Privacy Commissioner if you are resident in Quebec, British Columbia or Alberta as follows:

Office of the Privacy Commissioner of Canada
www.priv.gc.ca
Commission d’accès à l’information du Québec
www.cai.gouv.qc.ca
Office of the Information and Privacy Commissioner for British Columbia
www.oipc.bc.ca
Office of the Information and Privacy Commissioner of Alberta
www.oipc.ab.ca

ct personal information as part of its overall service commitment to clients.

AGF Management Limited, AGF Investments Inc. and AGF Securities (Canada) Limited (collectively referred to as “AGF”) are committed to protecting the privacy of our customers and regard this as an integral part of the service we provide you. Every AGF employee is responsible for ensuring the confidentiality of all personal information they may access. Each employee annually signs off on AGF’s Privacy Policy and completes mandatory privacy training to ensure they understand their obligations and expectations as it relates to the activities they perform.

Personal Information

Why do we need your Personal Information?

We require your personal information in order to establish a relationship with you and provide you with the best possible service – the better we know you, the better we can serve you. Your signature, financial history, current financial position, social insurance number, age and other similar personal information allow us to:

Establish your identity;
Understand and assess your eligibility for our products and services;
Provide you with the services you have agreed to obtain from us;
Protect you and us from error and fraud; and
Comply with the law.

How do we obtain your personal information?

Personal information is obtained primarily from you, although we may also obtain information from other sources with your consent. These other sources may include, but are not limited to, your advisor or dealer, other AGF affiliates, your bank, other financial institutions, etc.

How do we use your personal information?

We may use your personal information for the following purposes:

To identify you;
To ensure our records are accurate;
To establish and administer your account;
To execute your transactions;
To maintain, store, record and determine your account holdings and transaction records;
To verify previously given information when necessary;
To provide you and your representatives with account statements/information;
To provide you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information that may be requested or needed to service your account;
To provide you with quality customer service and support on your investment needs;
To protect the interests of AGF, such as the collection of a debt owed; and
To meet legal and regulatory requirements.

Who do we disclose your personal information to?

Your financial representative;
Other financial institutions, securities dealers and mutual fund companies;
Other AGF affiliates;
Third-party service providers;
Canadian or foreign governments, government agencies and regulators; and
Any other legally required institutions.

Contracts between AGF and third-party service providers ensure appropriate controls and protections and are in place at the service provider level to protect your personal information. Our service providers may, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and require access to certain personal information to perform contracted services. In this case, AGF’s service providers are responsible for ensuring appropriate security measures and controls are in place to protect your personal information from unauthorized use, loss, theft, alteration and destruction. Personal information available to service providers in foreign jurisdictions may be disclosed to local authorities as may be prescribed by law.

Disclosing your personal information when required or permitted by law:

AGF may be required to provide your personal information in response to a search warrant, court order or other legally valid request. We may also disclose your personal information to help us collect a debt owed by you.

AGF’s third-party service providers may also be required to provide your personal information in response to local legal requirements, not unlike Canadian requirements.

AGF may be required to provide certain of your personal information to comply with foreign laws applicable to AGF or any of the products and services AGF may provide.

Where required by law or legally valid request, AGF does not require your consent to disclose your personal information.

Obtaining Your Consent

Before or at the time you open an account with AGF, you will be required to provide certain personal information to establish the account. The information may be collected via an AGF application form, in which case you will formally indicate your consent for AGF to collect and use the personal information when you sign the application. The information may also be provided by your financial advisor to AGF, in which case, by virtue of account opening, your consent is implicitly provided to AGF to collect and use the information. In this case, at the time of initial collection of your personal information by your financial advisor, you will have provided consent to your advisor to disclose your personal information for the purposes of effecting investment transactions, including the opening of accounts with AGF.

Withdrawing your consent:

You may withdraw your consent for the collection and use of your personal information by contacting AGF at any time. As AGF is required by Law to obtain and collect certain personal information about you in order to maintain an account, you may be prevented from withholding your consent without closing your account. In addition, certain services and products may no longer be provided to you, in the event you withhold consent to the use of information upon which such services and products are dependent and/or required by rules and regulations that govern them.

Access to and accuracy of your personal information:

Upon request, AGF will provide you with access to your personal information we have on record at the time of the request. In addition and if requested, AGF may provide you with a list of third parties, to whom your personal information was provided. In certain circumstances, AGF may not be able to provide you with access to specific pieces of information in order to ensure the privacy and confidentiality of information belonging to others. For example: (i) information containing references to other individuals (ii) proprietary information of your financial advisor, the dealership or AGF (iii) information that has been destroyed (iv) information that is too costly to retrieve.

Where is your personal information kept?

Your personal information may be kept in electronic or paper format in the offices of AGF and its affiliates, in secure off-site storage facilities provided by storage service providers and its third party (administration) service providers, who may themselves store it in multiple locations and forms (in and outside Canada).

Protecting Your Information

Policies, procedures, guidelines, and safeguards have been put in place at AGF to ensure your personal information is protected.

Our employees and service providers have access to your personal information to enable them to perform their duties in servicing you.

Any personal information collected from you will only be used for the purposes identified at the time of collecting the information and will be retained for as long as is necessary to fulfil the service, or as required by law.

Security measures including passwords, restricted access to our offices and records, physical access security, and file encryption have been put in place to protect your information against unauthorized access, modification, loss, theft or general misuse.

From time to time, sometimes beyond our control, there may be breaches in the controls we established to maintain your personal information confidential. In the event a breach occurs, AGF will take all reasonable measures to secure the personal information, including requiring any third party service providers to take such appropriate measures considered necessary to secure and remedy the breach. In the event a detected breach may result in the potential risk of harm, disclosure of sensitive information or risk of theft of identity and/or assets, AGF will contact you as soon as possible, as we would had you raised a privacy complaint with us directly, outlining the details and actions taken to reduce the risks identified. At AGF we take the responsibility of securing your personal information very seriously and will take measures we determine appropriate in the circumstances to mitigate any identifies risks to you.

Complaints

Resolving your complaints:

Should you have a complaint, please contact our Client Services Team at:

Client Services & Administration:

Phone: 1-800-268-8583 or 905-214-8203
Fax: 905-214-8243
Email: tiger@agf.com
Mail:
AGF Investments Inc.
Client Services
CIBC SQUARE, Tower One
81 Bay Street, Suite 4000
Toronto, Ontario M5J 0G1

If speaking to one of our Client Services team members does not result in a satisfactory resolution, you may contact our Privacy Officer.

AGF Management Limited:

Phone: 1-800-268-8583
Privacy Officer: 416-367-1900
Fax: 416-865-4220
Email: agf_privacy@agf.com
Mail:
CIBC SQUARE, Tower One
81 Bay Street, Suite 3900
Toronto, Ontario M5J 0G1
Attention: Compliance

AGF will respond to your complaint in a timely fashion. Should you find that the proposed solution is unacceptable, you may contact the following institutions:

Investment Funds Institute of Canada:

11 King Street West, 4th Floor
Toronto, Ontario M5H 4C7
Phone: 416-363-2150

The Privacy Commission of Canada:

112 Kent Street
Ottawa, Ontario K1A 1H3
Phone: 613-995-8210 or 1-800-282-1376

Or in Quebec:

The Commission d’accès à l’information :

575, rue St. Amable, Bureau 1.10
Québec, Québec G1R 2G4
Phone: 418-528-7741 or 1-888-528-7741

If you have question about how AGF handles your personal information, please contact AGF Client Services.