NBC needs to collect personal information from our clients and prospective clients in order to provide services to you and fulfill our legal obligations. Understanding a client’s needs and wants, financial position and family issues enables us to ensure that all investment recommendations are suitable. This is both a regulatory requirement and good business. NBC is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This memorandum explains the measures we take to fulfill these commitments.
The “Know Your Client” information forms we ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers (for tax reporting purposes), asset holdings and values, investment knowledge and objectives. We also collect your chequing account information, transactional history, account balances/limits and optional beneficiary information (e.g. spouse’s name and occupation, children’s and dependents’ names and ages).
Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this Policy. We also collect your responses to a risk questionnaire and other regulatory questions that we are required by law to collect.
The personal information we collect when you open an account is used for the following purposes:
Referral Program: If you participate in our referral program (or other “Invite a Friend” features that may be available on our Websites), we collect the email address of the individual(s) who you wish to refer to NBC. We use this information to send the recipient a one-time email containing information about the referral program. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you.
Marketing Communications: From time to time, we may obtain your consent to send you email, SMS text messages and other communications about NBC products, services, or events that may be of interest to you. You can opt-out of receiving marketing and promotional email from us by following the unsubscribe instructions contained in each of our email communications. Please note that you will continue to receive email regarding your account and transactions with us. Alternatively, you can unsubscribe from any of our marketing communications by contacting us at support.
Customer Service/Relationship Manager: If you contact a customer service agent or Relationship Manager with a comment, question or complaint by email, text message, telephone or video chat, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and, product and service offerings.
Employment: If you inquire about or apply for a job with NBC, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
Gifting: If you send a gift (or “Contribute to an Account”), we collect the email address of the individual(s) who you send a gift to, and your payment information. We use this information to send the recipient a one-time email containing the information of your gift. We do not use the email addresses submitted in these circumstances for any other purpose without the consent of the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the email from you. We process your payment, and charge your method of payment at the time of purchase. No sensitive payment information data is saved on our servers.
Roundup: This program will access your linked accounts(s) on a weekly basis. We will use this information to round your purchase transactions to the nearest dollar and transfer this amount into your NBC account to be invested. If you change your mind you can unlink your account(s) at any time.
Overflow: Is an automated investing feature that accesses your linked chequing or savings account balance every month and automatically moves any extra cash over the limit you have set (up to a maximum, if you have one) into your NBC account. We will confirm funds are available and send you a reminder the day of the transfer. If you change your mind you can skip a transfer or unlink your account at any time. Because the formula is based on cash in excess of the limit you set, by turning on Overflow, you waive the right to receive a pre-notification of the Overflow amount before the debit is processed.
If you choose to participate in our “Roundup” program, we will collect information related to your account such as your name and address. Additionally, to calculate the eligible round-up amounts to invest in your NBC portfolio we will collect the types of transactions, vendors, amounts and dates of transactions on a weekly basis. We may also use this information to identify products and services, including financial planning services, that you may be interested in or benefit from. In order to ensure that this program will not result in non-sufficient funds in your account, we will also collect information related to your bank balance.
If you choose to participate in our “Overflow” program, we will collect information related to your account such as your name, address and account balance twice per month. Collecting your account balance will allow us to transfer your requested overflow balance, or determine if no transfer will occur that month.
We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.
NBC maintains reasonable administrative, technical and physical safeguards in an effort to protect personal information in our custody and control against unauthorized access, use, modification and disclosure of. We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information.
Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
Service Providers: We may transfer your personal information to our affiliates and other third party service providers who provide various services on our behalf such as identity verification, technology, administration, printing, marketing and advertising, hosting, data analysis, legal and accounting.
Broker: When you open a broker account with our custodian, we provide your account information to the respective brokerage in order to streamline the application process. We also notify them of any updates or changes to your account information.
Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of NBC or as part of a corporate reorganization or stock sale or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
Securities Regulations: We and/or our custodian may share your name, contact information and holdings with issuers of securities that you hold in your account and other persons/companies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations. We and/or our custodian may also disclose certain personal information, including the number of and purchase price of units purchased, to the applicable Canadian securities regulatory authority where required by law.
Legal: We and our Canadian, US and other affiliate and third party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other law (which may include lawful access requests by Canadian, US or other foreign courts, law enforcement or governmental authorities). We may also disclose personal information where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes. Your personal information may be maintained and processed by our affiliates and other third party service providers in the US or other jurisdictions. In the event personal information is transferred to the US or other foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with the laws of those jurisdictions.
Individuals have the right to access, update, and correct inaccuracies in his/her personal information in NBC’s custody and control, subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account and clicking “Settings”. Otherwise, an individual wishing to request access, updating and corrections of inaccuracies in other of his or her personal information in our possession or control may send a written request to this effect to NBC’s Chief Compliance Officer at the contact information below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.