At AXCESS CAPITAL ADVISORS, we respect and are committed to your right to privacy. We believe that you should understand the way in which we collect, use, disclose and protect your personal information. We are responsible for your personal information that we collect, use and disclose.
Personal information is any information that identifies you, or by which your identity could be deduced. It does not include information contained in public records or the name, title, business address or telephone number of an employee of an organization.
We have policies, procedures and training within our organization to protect your privacy. Axcess Capital Advisors’s Privacy Policy is based on the Canadian Standards Association’s Model Code for the Protection of Personal Information. This Privacy Policy outlines how we manage your personal information, safeguard your privacy and the principles that we follow when collecting, using, disclosing and protecting your personal information.
Who Are We?
Axcess Capital Advisors Inc. (“Axcess Advisors”) is a private corporation registered under National Instrument 31-103 as an Investment Fund Manager (“IFM”) and a Restricted Portfolio Manager(“RPM”) in the province of Alberta and as an Exempt Market Dealer(“EMD”) in the provinces of Alberta, British Columbia, Saskatchewan, Manitoba, Nova Scotia and Ontario. The Firm commenced operations in 2011 and operates from its head office in Calgary, Alberta.
This Privacy Policy governs Axcess Capital Advisors, Inc. and its subsidiaries. Axcess Capital Advisors, “we”, “us” and similar terms as used throughout this Privacy Policy refer to Axcess Capital Advisors, Inc. and its subsidiaries. Axcess Capital Advisors may amend this Privacy Policy from time to time. Please visit www.axcesscapital.com or write to Axcess Capital Advisors, Inc., Suite 210, 221 – 62nd Avenue SE , Calgary, Alberta, T2H 0R5, Attn: Privacy Officer, for the most up to date version of this Privacy Policy.
Why Do We Collect Personal Information from You?
In serving your needs, it is important to have accurate information about you. We collect your personal information to:
- Establish your identity
Understand your needs for, and determine your suitability for, products and services
Provide services to you and process payments for your account - Protect you and us from error and fraud, including verifying your identity to:
- Establish your account profile
- Validate you
- Respond to your requests
- Communicate with you concerning your account
- Notify you of AXCESS CAPITAL and third party new products and services, special offers, AXCESS CAPITAL events and general industry information
- Adhere to applicable legal requirements
How Do We Collect Your Personal Information?
We collect your personal information at the time you become a new customer of Axcess Capital Advisors, at the time you acquire additional products and services from us and at other times when we communicate with you to administer your account with us. We may collect your personal information directly from you or from third parties with your consent (if required). We continue to collect and update personal information throughout our relationship with you. For example, we collect your personal information through:
- Our service agreements and written correspondence with you
- Your discussions with our sales representatives, dealing representatives, customer service centers and central monitoring centers (some of which may be recorded to ensure service quality and to maintain an accurate record of our communications with you)
- Your visits to our websites, including www.axcesscapital.com and other related websites. For more information on this, see below under “Our Web Sites”.
What Personal Information Do We Collect About You?
The type of information that we collect is based on our relationship with you. Such information may include:
- Contact information about you, such as your name, address, telephone number, or email address
- Contact information about others that you designate as your Contact List, such as their name or telephone
- Account information related to your payment method(s), such as credit card number, credit card expiration date, credit card type, bank account number, bank account type, or the name of your financial institution
- Your SIN number
Our Web Sites
Each time you visit our web pages, such as www.axcesscapital.com, we gather the date, time, browser type, name of the visitor’s Internet service provider, the site that referred the visitor to us, any pages that are requested, the navigation history and IP address of the visitor. The foregoing information does not generally contain anything that can identify users personally. If you object to this gathering of information, you should not use or access our web pages. We use this information for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use. This information may be shared with third parties in order to provide services to us or to analyze, store or aggregate the information.
Each time you provide any personal information such as your name, address, telephone number or other identifying information to us through our web pages, you consent to the collection, use and disclosure of this personal information in accordance with this Privacy Policy. We treat and safeguard personal information collected through our web pages the same way as personal information that we collect through other means, such as customer contracts.
Our web pages may employ the use of “cookies”. A “cookie” is a small line of data that is sent to your Internet browser from a web server and stored on your computer’s hard drive. Cookies can track how and when you use a site, and which site you visited immediately before. A cookie does not damage your system and identifies your browser, not you personally. We use cookies to identify which areas of our network you have visited, so the next time you visit those pages may be readily accessible. If you do not wish to receive a cookie, please set the options in your web browser accordingly. Although such changes to your web browser may provide you with enhanced anonymity, they make it very difficult to offer you customized services.
To the extent that our web sites contain links to other sites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.
How Do We Obtain Your Consent for the Collection, Use and Disclosure of Your Personal Information?
Where required, consent for the collection, use and disclosure of personal information may be obtained orally or in writing and may be expressly given or implied. Your express consent may be given in writing, verbally or through electronic means. Your implied consent may be given through an action you have taken, such as supplying your personal information for a specified purpose.
If you prefer that we not use or disclose your information for any of these purposes, you may notify us in writing at any time at Axcess Capital Advisors, Inc., ., Suite 210, 221 – 62nd Avenue SE , Calgary, Alberta, T2H 0R5, Attn: Privacy Officer or by emailing info@axcesscapital.com
If you do not notify us, we will consider you to have consented to our continued use and disclosure of your personal information. A notification that we not use or disclose your personal information for certain purposes may affect our ability to provide you with products and/or services.
What Do We Do With Your Information?
Your information will only be used by AXCESS CAPITAL for the purposes outlined above under “Why Do We Collect Personal Information from You?”. We will not disclose your personal information to any third party, except as set out below.
AXCESS CAPITAL Authorized Dealers
We may disclose your personal information to third party AXCESS CAPITAL Authorized Dealers to respond to your inquiry/request, in order to better service your needs. If you do not want your information to be disclosed to an AXCESS CAPITAL Authorized Dealer, you may notify us in writing at any time at Axcess Capital Advisors, Inc., ., Suite 210, 221 – 62nd Avenue SE , Calgary, Alberta, T2H 0R5, Attn: Privacy Officer or by emailing info@axcesscapital.com
Third Party Services
There are certain services supplied to us by third parties in Canada and the United States where the work involved requires the use of some of your personal information by the third party. Frequently but not exclusively, these third parties are our affiliates. For example, our affiliate, AXCESS CAPITAL PARTNERS, which provides AXCESS CAPITAL ADVISORS back office services for our customers, currently supplies some data storage services, some marketing services including the notification of new products and services special offers, some customer support services including the enrolment of new customers, processing of customer rebates and responding to customer inquiries and complaints. Third party service providers located in Canada that are not our affiliates also supply services to us. For example, these unrelated service providers currently supply some marketing and customer support services similar to those provided by AXCESS CAPITAL ADVISORS, Inc., and other services regarding our compliance with applicable legal requirements and protection of you and us from fraud and interference with our commercial relationship. In order to provide some of these services to our customers, personal information is required by AXCESS CAPITAL ADVISORS, Inc. and unrelated service providers. Whenever we engage a third party service provider to do work for us, we confirm that its privacy and security standards meet our requirements.
In the event that a third party service provider is located in the Canada or another foreign country, certain of your personal information may be processed and stored in the Canada or such other foreign country, and the governments, courts or law enforcement or regulatory agencies of that country may be able to obtain disclosure of your information through the laws of the foreign country.
Transactions
We may be involved, from time to time, in transactions to sell parts of our business or assets or merge with other businesses. Since our customer information may be part of such transactions, we may use or disclose this information to other parties involved in the transaction. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure.
Legal Requirements
There are exceptions where we may collect, use or disclose personal information without consent when required or permitted by law.
From time to time, we may be compelled by legal action to release information (e.g., statutory reporting obligation, search warrant, court order, bankruptcy or insolvency proceedings etc.). In certain circumstances, we may also be permitted by law to collect, use or disclose information without the consent of the individual concerned. For example, we may disclose personal information without consent if it is to be used in an emergency that threatens the life, health or security of the individual, or when collecting unpaid amounts owed or owing to us.
We protect your information
We limit access to your personal information, through physical, electronic and procedural safeguards, to those persons who require it to provide our services and products. The location and manner of storage and access depends on the nature of the information, which may be stored or accessed electronically or in hard copy in Alberta. Such information is subject to the laws of the country in which it is accessible or stored. When we provide access to your personal information, it is for a legitimate business purpose or reason and in accordance with this Privacy Policy. Our employees and outside suppliers that have access to your personal information are governed by standards and policies to ensure the security and confidentiality of your personal information.
If you think someone is impersonating AXCESS CAPITAL, that there has been a breach of your privacy or you believe that you are the victim of fraud with respect to an AXCESS CAPITAL matter, please write us at Axcess Capital Advisors, Inc., ., Suite 210, 221 – 62nd Avenue SE , Calgary, Alberta, T2H 0R5, Attn: Privacy Officer or email us at info@axcesscapital.com
Accessing and Keeping Your Personal Information Accurate
We make every effort to ensure the information in our records is accurate. We also rely on you to provide any updates to your information. Subject to certain limited exceptions, you have the right to access your personal information held by us. Whenever you want to review, verify or correct your personal information, write or contact your local AXCESS CAPITAL office or emailing us at info@axcesscapital.com. Please be as specific as possible with your request. There is no charge for verifying or correcting your information but, depending on the circumstances, there may be a charge if you want hard copies of records. We will let you know at the time of your request if there is a charge.
Resolving your questions and concerns
If there are any misunderstandings or you feel that your concerns regarding your privacy have not been resolved justly or you have questions about our Privacy Policy, please contact our privacy office at Axcess Capital Advisors, Inc., Suite 210, 221 – 62nd Avenue SE , Calgary, Alberta, T2H 0R5, Attn: Privacy Officer or by emailing info@axcesscapital.com
Changes to this Privacy Policy
This Privacy Policy was last updated in February 2020. We will occasionally update this Privacy Policy and revise the “last updated” date appearing in this paragraph.