(Updated February 2022)
Mawer Investment Management Ltd. ("Mawer", "we" or "us") is committed to protecting your personal information and to safeguarding its confidentiality. We have developed this Privacy Statement to inform you of our policy and practices with respect to the collection, use and disclosure of personal information of clients and for those who visit our website (www.mawer.com), the online client portal and mobile client application.
BY SUBMITTING PERSONAL INFORMATION TO MAWER AND/OR VISITING OUR WEBSITE, ONLINE CLIENT PORTAL OR MOBILE CLIENT APPLICATION, YOU SIGNIFY YOUR CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF SUCH INFORMATION IN ACCORDANCE WITH THIS PRIVACY STATEMENT.
If you do not agree to the terms of this Privacy Statement, please do not provide us with any personal information.
Collection and Use of Personal Information
You may choose to give us personal information in a variety of situations. For example, you may provide us your name, telephone number, address, or email address to correspond with you. More detailed personal information will be required to open an account with us or to process transactions within your portfolio. We may also collect personal information when you use or access our website, online client portal or mobile client application (see “Non-Identifiable Information Automatically Collected Through the Website” and “Cookies Used on the Website” below) or from third parties such as your financial advisor/dealer, our affiliates, and other financial institutions. We will only collect personal information required for, or related to, providing investment management services to you and better understanding our clients’ needs.
Mawer collects and uses personal information concerning our clients and prospective clients for purposes of providing the services requested by you as our client and in order to fulfill our legal obligations. We will only use or disclose your personal information for the reason it is collected or for other purposes you consent to, or when it is required by law. We keep your personal information only for as long as we need to, or as required by law. More specifically, we may collect, use, and disclose personal information from you for the following purposes:
- to provide investment management services to you, including the administration, operation and maintenance of your account(s), entering into and processing transactions within your portfolio;
- to transfer your account to or from another institution;
- to allow Mawer to comply with its legal and regulatory obligations, as well as its policies and procedures;
- for legitimate business purposes, such as the improvement of our operations and services provided to you through your contractual agreements with us;
- to fulfill any other purposes for which you specifically provide Mawer with personal information;
- to contact and correspond with you and your agents;
- to improve our website, its content and features; and
- such other purposes permitted or required by applicable law.
To the extent you provide us with personal information concerning another individual (such as a spouse, relative, director, employee, representative, agent or trustee), you represent to Mawer that you have obtained the informed consent of such individual to our collection, use, and disclosure of such information for the purposes set forth in this Privacy Statement.
Disclosure and Sharing of Personal Information
Mawer may, from time to time, disclose your personal information to the extent necessary to provide the services requested by you, including to our affiliates, employees, contractors, service providers and agents that assist us in the course of carrying out such services or to facilitate such services. If we share personal information with our affiliates, employees, contactors, service providers and/or agents, they will be required to adhere to equivalent confidentiality obligations and/or other restrictions or practices that maintain the confidentiality of such information while ensuring it is not improperly disclosed or accessed by unauthorized persons.
Mawer may also disclose personal information that we collect, or that you provide, as described in this Privacy Statement:
a) where Mawer has reasonable grounds to believe the information could be useful in the investigation of unlawful activity,
b) to comply with a subpoena, warrant, court order, law or legal process, including to respond to any government, regulatory or law enforcement request,
c) if we believe disclosure is necessary or appropriate to protect the rights and property of Mawer and its affiliates, or the rights and property of others, and/or
d) as otherwise required or permitted by law.
If Mawer intends to sell or transfer ownership or control of any or all of its business, operations, or services to a third party, including as part of a reorganization, merger, divestiture, or dissolution, it reserves the right to disclose personal information to a potential purchaser or resulting organization both prior to and after the transaction. In the event the transaction occurs, Mawer will require that the receiving party agrees that it only uses and discloses personal information as Mawer is entitled to use and disclose it under this Privacy Statement. In the event a transaction does not occur, Mawer will require the receiving party to not use or disclose such personal information in any manner whatsoever and will require verification that the receiving party has destroyed, disposed of, or permanently erased all such personal information.
Except as mentioned in this Privacy Statement unless Mawer has obtained your express consent, we will not disclose or share your personal information to/with any third party.
Online Client Portal and Mobile Client Application
Mawer has implemented reasonable and effective security controls to protect your personal information including the data collected through our client portal and mobile client application. Any improper use of the client portal or mobile client application by you or your failure to protect any usernames and passwords may lead to unauthorized access or disclosure of your personal information. Mawer shall not be responsible or liable for any harm that you or any other person may suffer in connection with any such breach of confidentiality or security.
Storage and Processing of Personal Information
Mawer stores and processes your personal information in our offices located at79 Wellington Street West, TD South Tower, Suite 3410, Box 276, Toronto, Ontario or at Centre 10, 517-10th Avenue SW, Suite 600, Calgary, Alberta. Mawer may also store or process your personal information at the offices of our affiliates and/or service providers located in Canada, Singapore or other jurisdictions, including the United States. As such, personal information may be subject to foreign laws that may not be as comprehensive as Canadian laws. Personal information which is stored outside of Canada may be accessible by foreign governments, courts, law enforcement and regulatory agencies through the laws of the foreign country. Additional information about our policies regarding service providers outside of Canada are available by contacting our Privacy Officer at firstname.lastname@example.org.
The security of your personal information is very important to us. Mawer has implemented a number of physical and electronic security measures and processes to help protect against the loss, theft, and unauthorized access of the information under our control. Only Mawer's employees, contractors and authorized third parties who have a legitimate business need or legal requirement to access and/or process your personal information will be permitted to do so. General entry to our offices is secured and cannot be accessed by unauthorized personnel without permission.
Please be careful whenever sending personal information to us via email. Email is generally not a secure means of transferring information. We encourage the use of email encryption to communicate with us. Any transmission of personal information is at your own risk and the security of personal information submitted to us through email, our website, online client portal or mobile client application cannot be guaranteed. Where a user ID and password are required to access certain parts of our website, online client portal or mobile client application, you are responsible for keeping that user ID and password confidential.
Children's Information (Children’s Online Privacy Protection Act)
We respect the privacy of your children and do not knowingly collect or retain personally identifiable information from children under the age of 13 through the website, online client portal and mobile client application.
Notice to California Users Required by State Law
California residents please refer to the Privacy Statement for California Residents set forth below.
Accessing Personal Information and Withdrawing Your Consent
Individuals may request access to their personal information by contacting our Privacy Officer at email@example.com. Subject to certain exceptions prescribed by applicable law, individuals will be given reasonable access to their personal information and will be entitled to challenge the accuracy and completeness of such information and, if shown to be inaccurate, to have it amended as appropriate. Before we are able to provide you with any information or make any requested changes, we may ask you to verify your identity and request other details to help us confirm your right to access such information and to respond to your request. Where you have provided your consent to the collection, use and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. You may withdraw your consent, if applicable, by contacting our Privacy Officer at firstname.lastname@example.org. Please note that if you withdraw your consent, we may be limited in our ability to provide you with services you have asked for.
Non-Identifiable Information Automatically Collected through the Website
Like many other websites, Mawer’s website, online client portal and mobile client application may automatically collect certain nonidentifiable information regarding Website visitors, such as the Internet Protocol (IP) address of your computer, the IP address of your internet service provider, the date and time you access the website or mobile client application, the internet address of the website from which you linked directly to the website, the operating system you are using, the sections of the website you visit, the website or mobile client application pages read and images viewed, and the materials you post to or download from the website. This non-identifiable information is used by Mawer to maintain and improve our website and our operational systems. Your non-identifiable information may be disclosed to others and permanently archived for future use.
Cookies Used on the Website
Mawer's website, online client portal and mobile client application may use "cookies", a technology that installs information on a website visitor's computer to permit the website to recognize future visits using that computer. The cookies used by our website, online client portal and mobile client application do not contain any personal information regarding visitors, and do not retrieve any information from visitors' personal computers (other than your IP address and other similar information retrieved or retained in order to facilitate your use of the website or mobile client application). Cookies are used only to enhance the visitor's experience, and to collect anonymous traffic data to enable us to provide a better web experience for the viewing public in general. You may choose to decline cookies if your internet browser permits but doing so may affect your use of the website, online client portal or mobile client application and your ability to access certain features of the website, online client portal or mobile client application.
If you have any questions or concerns about this Privacy Statement, you can send an email to our Privacy Officer at email@example.com. You can also contact our Privacy Officer if you have any questions about the privacy practices of Mawer, its affiliates and/or its service providers in respect of the collection, storage, use and disclosure of personal information.
Change of Privacy Statement
Privacy Statement for California Residents
(Updated August 2021)
This Privacy Statement for California Residents supplements the information contained in Mawer’s Privacy Statement and applies solely to residents of the State of California (“consumers” or “you”). We adopt this statement to comply with the California Consumer Privacy Act of 2018 (“CCPA”), as amended, and any terms defined in the CCPA have the same meaning when used in this statement.
Please note that certain exemptions apply to your rights and Mawer’s obligations pursuant to the CCPA. These rights and requirements may not apply in certain situations depending on your relationship with Mawer, Mawer’s other legal obligations, and as otherwise provided for in the CCPA.
Mawer reserves the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will post the updated notice on the Website and update the statement’s effective date. Your continued use of our services, website, online client portal and mobile client application following the posting of changes constitutes your acceptance of such changes.
Collection and Use of Personal Information
Mawer collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer. Consumers have the right to request this information for a 12 month “look back” from the date the request was made. Personal Information collected from consumers can fall into the following categories:
- Personal identifiers (name, alias, postal address, email, SSN, or other);
- Protected classifications under California or federal law (age, race, gender, origin, status of citizenship, military status, religion);
- Commercial information (property records, purchase history, consumer tendencies);
- Biometric information (DNA, fingerprint, behavioral tendencies, physical patterns, retina scans);
- Internet (cookies, browsing history, advertisement history);
- Geolocation data (GPS, movement history);
- Employment related information (employment history, performance); and
- Education related information (non-public records, grades, schedules, financial information).
We will collect the personal information described above from one or more of the below sources:
- directly from you throughout our relationship, including when you sign up for, and/or use, our products, services and website, or when you visit our offices or attend a Mawer event;
- indirectly from you, for example, from observing your actions on our website, online client portal or mobile client application;
- from our affiliates;
- from third parties that are authorized to share your information with us, such as intermediaries, broker dealers, our institutional clients and service providers; and
- from publicly available sources of information.
No Sale of Personal Information
Mawer does not sell your personal information. Under California law, sharing information for advertising purposes may be considered a “sale”. To the extent that Mawer ever changed its policy and were to choose to sell personal information, you would have the right to opt-out of the sale of your personal information.
Access to Specific Information Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that Mawer disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The categories of personal information that each recipient received.
- The specific pieces of personal information we collected about you.
Deletion Request Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that Mawer delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records.
Exercising Access and Deletion Rights
To exercise the access, and deletion rights described above, please submit a verifiable consumer request by sending an email to our Privacy Officer at firstname.lastname@example.org.
You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with at least two or more pieces of personal information to match against personal information about you that we may or may not maintain and which we have determined to be reliable for the purpose of verification.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.