Global Privacy Policy of Fiera Capital Corporation

Effective date: February 15, 2021

Fiera Capital Corporation and the Fiera Capital entities (collectively, “Fiera Capital,” “we,” “our,” or “us”) are committed to respecting and protecting your privacy and the confidentiality of the information with which you have entrusted to us and which we collect about you.  The purpose of this global privacy policy (the “Policy”) is to explain how and for what purposes we collect, use, share or otherwise process your personal information and how we safeguard the confidentiality of your personal information, whenever you interact with Fiera Capital.

Table of Contents

1. Scope and application
2. What is “personal information”?
3. What categories of personal information do we collect?
4. How we collect your personal information?
5. How we use your personal information?
6. When do we share your personal information with other organizations?
7. What are your privacy choices?
8. How do we protect your personal information?
9. How long do we keep your personal information?
10. Cross-border transfers of personal information
11. Accessing and correcting your personal information
12. EU notice
13. California notice
14. Changes to the Policy
15. Contact us
 

1. Scope and application

Fiera Capital Corporation is a Canadian domiciled publicly traded company that, through its various affiliates, operates primarily as a global investment management business, offering a diversified suite of solutions to institutions, organizations, companies and individuals in North America, Europe and key markets in Asia.

This Policy applies to Fiera Capital’s operations globally, and the products and services we offer. It applies, for instance, if you are a client that invests through our products and services, if you visit our websites (including our client portal), or if you apply for a career opportunity with Fiera Capital. It also applies with respect to personal information we may collect about the contacts required to administer your account including but not limited to your named beneficiaries, agents, trusted contacts, consultants, partner and/or spouse.

In this Policy, we describe our policies and practices with respect to the collection, use and disclosure of personal information and the measures taken to ensure its continued protection.  We also describe the rights and choices you have regarding your privacy. 

In some cases, at the time of collection of your personal information, we may provide you with additional information regarding the processing of your personal information. We may also, in certain circumstances, obtain your specific consent to the use or sharing of your personal information, including where required by law. 

The EU Notice section of the Policy applies specifically to personal information processed by Fiera Capital entities in the United Kingdom (“UK”) and European Union (“EU”). The California Residents section of the Policy applies to personal information of California residents processed by us and contains additional disclosures, our notice at collection, and a description of your rights.

This Policy supplements our Privacy Policy issued pursuant to Regulation S-P under the Gramm-Leach-Bliley Act which applies to individual investors of our U.S-based, SEC-registered affiliate, Fiera Capital Inc. The personal information we collect, process or disclose pursuant to such Act is not subject to the CCPA.

2. What is “personal information”?

In this Policy, “personal information” generally means information (regardless of its format) about an identifiable individual or natural person. This may include, for example, your name, contact information, home address, email address, birth date, tax identification number and information relating to your account with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

3. What categories of personal information do we collect?

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected.  

Depending on your interaction with us, we may collect personal identifiers, demographic data, commercial information, professional or employment–related information and Internet or other electronic network activity. We may also need to collect certain information about our clients to conduct money laundering, sanctions, financial crimes and fraud prevention checks. We collect personal information in a variety of ways detailed below under How we collect your personal information

We may collect the following personal information about you depending on your interactions with Fiera Capital (for instance, if you are a client, a named beneficiary of a client, a website visitor or a job applicant):

  • Personal identifiers, such as name, postal address, phone number, email address, national identity numbers, passport numbers, account number, username or Internet Protocol (IP) addresses, signatures. We may also collect other identifiers necessary to conduct “know your client” activities (for example, information about named beneficiaries and/or spouses and partners).
  • Demographic data, such as date of birth or gender.
  • Commercial information, such as investment objectives and amount available to invest, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  Where a client has established a pre-authorized chequing plan which enables them to make purchases at regular intervals or where a client has chosen to pay for their services in automated way, we maintain the client’s financial institution account number.
  • Information collected for money laundering, sanctions, financial crimes and fraud prevention checks, such as actual or alleged criminal convictions and offences. This information may qualify as “special categories” of personal information under the General Data Protection Regulation (“GDPR”).
  • Internet or other electronic network activity information, such as browser type, Internet service provider (ISP), referring/exit pages, pages viewed on our site and on our client portal.
  • Professional or employment-related information, such as your professional title and occupation.

You are not required to provide us with your personal information where it is requested but we may be unable to provide certain products and services or proceed with your business relationship with Fiera Capital if you do not do so.

4. How we collect your personal information?

We collect personal information in a variety of ways, including directly from you, from third parties and through our websites. Using information we have collected, we may also generate new information about you. 

We may collect personal information from the following general sources:

a. Directly from you

We may collect personal information directly from you or from your representative, such as when:

  • you open an account with us;
  • you subscribe to our newsletter;
  • you file forms on our websites (including information provided at the time of registering to use Fiera Capital’s websites, posting material or requesting services);
  • you provide identification documentation in response to “Know Your Clients” checking requests;
  • you apply for a career opportunity with us;
  • you contact us with an inquiry or to report a problem with our website; or
  • you agree to complete a research survey.

b. From third parties  

In certain circumstances, we may collect personal information from third parties, such as a consultant or a referral agent with whom we work with to provide products or services to you or the executor of an estate account. We may also collect personal information from our clients about their named beneficiaries.

c. Through our websites

Fiera Capital may collect certain types of information electronically through your contact with our websites using technologies (either our own or third party technologies) such as cookies and web beacons. We may collect your Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages and the pages you viewed on our site. 

For more information about the technologies we use to collect information through our websites and how you can manage your choices, please review our Cookie Policy.

5. How we use your personal information?

We may use your personal information for the following purposes or otherwise, with your consent or as permitted or required by law: 

a. General business purposes

We may use your personal information for general business purposes such as providing or delivering a product or service requested from Fiera, managing our business and websites, processing job applications, preventing or reducing commercial risk, as well as for purposes relating to information, system or network security. 

More specifically, we may use your personal information for the following general business purposes:

Providing or delivering our products and services. We use your personal information for activities that are necessary to provide or deliver our products and services, for instance:

  • Establishing and maintaining our discretionary portfolio management mandates. 
  • Managing any aspect of the products or services we offer.
  • Providing you with information about our products and services which may be of interest to you, including to determine whether you are eligible to invest in our products.
  • Assessing an application for a product or service, including to determine whether or not to offer you the product or service.
  • Establishing and administering client accounts which involves determining, maintaining, recording, and storing account holdings and transaction information in applicable client records.
  • Executing client transactions including transferring funds by electronic or other means.
  • Updating your personal information and records.
  • Ensuring information in our records is accurate and verifying previously given information when necessary.
  • Transferring your assets to or from another financial institution.
  • Sending you our investment-related information.
  • Providing you with account statements and other account related information, financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your client account, including through our online client portal.

Managing our business operations. We use your personal information for several reasons in connection with our business operations, which include:

  • Exercising due diligence to prevent or reduce our commercial risk, such as administering our good governance requirements and those of other members of the Fiera Capital entities or management and auditing of our business operations.

  • Ensuring the security of our information, system or network. 
  • Complying with legal and regulatory obligations, requirements and guidance (e.g. securities legislation applicable for opening an account and applicable legislation respecting money laundering, including respecting the identity of account holders and legitimacy of the asset base).
  • Facilitating the sale of one or more parts of our businesses, reorganizing our businesses and obtaining and submitting insurance claims.
  • Collecting a fee owed to Fiera Capital.
  • Satisfying regulatory audits, assessments, requests or requirements.

Managing our websites. When you visit our websites, we may use your personal information to manage and facilitate the use of our websites, which may include using cookies and other similar technologies (as further detailed in our Cookie Policy).

Processing your job application. When you submit a job application, we may use your personal information for the following purposes:

  • Verifying your identity.
  • Creating and administering your account.
  • Responding to your requests and communicating with you regarding your application.
  • Evaluating your application and making hiring decisions.
  • Concluding a hiring agreement.

b. Research and development purpose

We may use personal information to understand and assess your interests and changing needs with a view to improving our products and services and developing new ones, as well as to evaluate potential improvements or other modifications to the functionality of our websites. For instance, we may use third-party web analytics services, such as Google Analytics, to help us analyze how visitors use our websites (including our online client portal). When required by law, we will use de-identified information for these purposes.

c. Marketing purposes

We may use your personal information to provide you with personalised content and services, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels. 

We may also use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online client portal) about our programs, products, services, special offers, promotions, contests or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages. For more information on this topic, see What are your privacy choices?

6. When do we share your personal information with other organizations?

We may share your personal information within the Fiera Capital entities, with our service providers (companies that carry out activities on our behalf) and in the case of the sale or transfer of our business or another transaction. 

We may also share your personal information with your consent (for instance, with another financial institution, or similar organization such as your custodian, at your request) or in accordance with applicable law.  

We may share your personal information as set out below:

a. Among the Fiera Capital entities

The Fiera Capital entities may share personal information among themselves and use it for the purposes described in this Policy. This allows each entity to comply with applicable laws, regulations and requirements, and ensures that your information is consistent, accurate and up to date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with Fiera Capital through easier access to your information within the group.

b. Other financial institutions and similar organizations

We may disclose personal information with our clients’ custodians, financial institutions and securities dealers when necessary to carry out the client instructions, such as transferring funds.

c. Service providers

We may transfer personal information to our agents, vendors or other organizations that provide services to Fiera Capital, for the purposes set out in this Policy. Service providers who may be provided with personal information include account statement preparation companies, mailing and courier companies, imaging companies, document storage companies, backup and server hosting providers, IT software and maintenance providers, portfolio management systems, market intermediaries or archive services.

When Fiera Capital transfers personal information to our service providers, we ensure by contractual means that the transferred personal information is used only for the purposes for which the service provider is retained and is protected to the same degree as it is when in our possession. Our service providers may be located around the world, as further detailed in the Cross-border transfers of personal information section.

d. Sale or transfer of our business or other transaction

We may decide to sell or transfer all or part of our business to a third party, merge with another entity, secure our assets or proceed with any other financing or other strategic capital transactions (including insolvency or bankruptcy proceedings), restructuring, share sale or other change in corporate control. We may share your personal information when required for the purposes of such a transaction.

e. Other permitted reasons

We may share your personal information when permitted or required by applicable law, for instance:

  • With domestic and international governments, government agencies, law enforcement agencies and regulators when compelled by law, such as disclosure for tax purposes to the Canada Revenue Agency or to securities regulatory authorities in accordance with securities regulations.
  • With any person or organization, fraud prevention agency, regulatory or government body, the operator of any database or registry used to check information provided against existing information, or other insurance companies or financial or lending institutions for the purposes of detecting or suppressing financial abuse, fraud, criminal activity, protect our assets and interests, assist us with any internal or external investigation into potentially illegal or suspicious activity or manage, defend or settle any actual or potential loss in connection with the foregoing. For these purposes, personal information may be pooled with data belonging to other individuals and subject to data analytics. 

7. What are your privacy choices?

You have choices about the way Fiera Capital handles your personal information. 

a. Changing your communication preferences

You can always choose not to receive marketing or promotional messages from Fiera Capital by email by clicking on “unsubscribe” in any email you receive.

Please note that even if you have indicated your choice not to receive commercial messages from us, we may still communicate with you in connection with a service, in accordance with applicable law (for example, to send you a customer service message, important product information, service notification or recall). In addition, it may take up to ten (10) business days to register a change of preference across all our records.

b. Changing your browser settings on your device

We use technology to enhance your client experience and present you with offers, including personalised advertising. Through technologies such as cookies, our websites recognize you when you use or return to them and can provide you with a seamless experience. You can remove or disable some of these technologies at any time through your browser. However, if you do so, you may not be able to use some of the features of our websites.

Please refer to your browser instructions or help screen to learn how to block, delete and manage cookies on your computer or mobile device. You can also use the quick links below, depending on the type of browser that you are using: Internet Explorer, Google Chrome, Microsoft Edge, Firefox and/or Safari.

Please review our Cookie Policy for additional information.

c. Restricting collection, use and disclosure of your personal information 

You may withdraw your consent to the collection, use and disclosure of personal information in accordance with this Policy at any time upon reasonable notice to Fiera Capital in writing, subject to legal or contractual restrictions. 

The withdrawal of your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive because the continued use and disclosure of your personal information is a necessary part of making the product or service available to you. In some circumstances, legal requirements may prevent you from withdrawing consent, such as our obligation to report taxable investment income to your local tax authority.

8. How do we protect your personal information?

Fiera Capital takes appropriate measures and controls aimed at safeguarding your personal information. These measures include restricting physical access to our offices and records, restricting access to your personal information to only those employees or agents who require access to fulfill their responsibilities, restricting unauthorized access, disclosure, use and misuse of your personal information in our custody and control, having archival documents stored with reliable third parties offsite at secure premises, using firewalls, passwords and file encryption for online activities.  

Our goal is to prevent unauthorized access, loss, misuse, sharing or alteration of personal information in our possession. We also use these safeguards when we dispose of or destroy your personal information.

9. How long do we keep your personal information?

We store your personal information for as long as is necessary to provide our services to you, to manage our business operations, and to comply with our legal and regulatory obligations. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

10. Cross-border transfers of personal information

We may share personal information amongst the Fiera Capital entities, including in Canada, the United States, the United Kingdom, the Isle of Man and the European Union. Some of our service providers may also access, process or store your personal information outside of the country where we are located and where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

When we transfer your personal information outside your country of residence, we enter contractual arrangements between the Fiera Capital entities and with our service providers to ensure the adequate protection of your personal information. For instance, we rely on contracts that incorporate standard contractual clauses approved by the European Commission or other lawful mechanisms under the GDPR to transfer personal information related to our activities in the European Union to countries outside of the European Economic Area that are not covered by an adequacy decision

11. Accessing and correcting your personal information

You may be entitled to access your personal information and request the correction of inaccurate information, subject to limited exceptions set out in applicable laws. 

To access and correct your personal information, please contact us in writing using the relevant contact information listed in the Contact Us section below depending on the jurisdiction where you reside.  

Individuals in the UK, EU and California may have additional rights with respect to personal information processed by Fiera Capital entities in the UK, EU and the U.S. Please review the EU notice and California notice below for more information.

12. EU notice

This section applies to personal information processed by a Fiera Capital entity in the UK and EU, which is subject to the GDPR.

a. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal basis to process your personal information:

  1. Where it is necessary to enter into or to perform a contract between us.
  2. Where it is necessary to comply with our legal obligations.
  3. Where it is necessary for our legitimate interests to do so.
  4. Where you have given us your consent.

b. Your rights

In addition to the rights mentioned under Accessing and correcting your personal information, you have the following rights:

  • Delete your personal information: You can ask us to erase or delete all or some of your personal information (for instance, if it is no longer necessary to provide our services to you).
  • Object to or restrict our processing of your personal information: You can ask us to stop using all or some of your personal information (for instance, if we have no legal right to keep using it) or to restrict our use of it (for instance, if your personal information is inaccurate).
  • Right to portability: You can ask us to provide a copy in machine-readable form of the personal information that you have provided us.

If you wish to exercise any of these rights, please use the contact information listed in the Contact us section below. You also have the right to file a complaint with the supervisory authority in the EU Member State where you are located or where the relevant Fiera Capital entity is established. For instance, complaints about Fiera Capital (UK) Limited may be submitted to the Information Commissioner’s Office.

13. California notice

This California notice supplements the Policy set forth above with respect to specific rights granted under the California Consumer Privacy Act (“CCPA”) requires us to make certain disclosures about our to natural person California residents (“California Resident,” “you,” or “your”) with regard to “personal information .” If you are a California Resident, please review the following information about our privacy practices surrounding how and provides you additional rights related to the collection, why we collect, use, disclose and sharing ofshare your personal information about California consumers by Fiera Capital entities and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used in this California notice have the meaning ascribed to them in the CCPA. We are a “business.” “Personal information” for the purposes of this section has the same meaning as in the CCPA. For purposes of this California notice, personal information does not include deidentified information, aggregate consumer information, or publicly available information as those terms are defined in the CCPA.

Notice at Collection and Use of Personal Information

Information We Collect

Depending on how you interact with us, we may collect the categories of personal information listed above in the section What categories of personal information do we collect?.

How We Use Collected Information

We also may use personal information from California Residents for the business or commercial purposes described above in the section How we use your personal information?

For more information about our privacy practices, please review our Privacy Policy, which is available here: https://us.fieracapital.com/privacy-policy/.

Our Collection, Use, Disclosure, and Sharing of Personal Information

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section, What categories of personal information do we collect?  We may collect personal information from all or some of the categories of sources listed in the section, How we collect your personal information?  We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section, How we use your personal information?

Our Disclosure and Sharing of Personal Information

We do not sell your personal information. We do not knowingly sell the personal information of California residents under 16 years old.

In the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in What categories of personal information do we collect? above, to the following categories of third parties: (i) our clients’ custodians, financial institutions and securities dealers when necessary to carry out the client instructions, such as transferring funds; (ii) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (iii) other third parties as may otherwise be permitted by law.

We may also share your personal information with our affiliates and service providers such as our administrators, web analytics providers, tax and accounting providers, IT providers, or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by, the CCPA.

California Residents’ Rights under the CCPA

The CCPA provides California Residents with certain rights related to their personal information. This section explains those rights. If you are a California Resident and would like to exercise any of those rights, please see How to Exercise Your CCPA Rights? below for more information on how to submit a request, subject to certain exemptions and other limitations under applicable law.

  • Notice: You have the right to be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
  • Right to Know: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months.
  • Right to Delete: You have the right to request that we delete certain of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with federal, state, local and non-U.S. laws, rules and regulations.
  • Right to Non-Discrimination: We will not discriminate against you for exercising of any rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
  • Opt-Out of Sale: You have the right to opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations.  For more information about how we collect, use and disclose this information, please refer to our U.S. Privacy Policy. We also reserve the right to retain, and not to delete, certain personal information after receipt of a request to delete from you where permitted by the CCPA.

How to Exercise Your CCPA Rights

If you are a California Resident and would like to exercise any of the CCPA rights identified above, you may submit a request by writing to PrivacyUS@fieracapital.com or by calling us at 866 227-9925. ​

We are required to provide certain information or to delete personal information only in response to verifiable requests made by you or your legally authorized agent. When you submit a Right to Know or a Right to Delete request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.

You are permitted to designate an authorized agent to submit a Right to Know or a Right to Delete request on your behalf and have that authorized agent submit the request through the aforementioned methods.  We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf.  We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

We will deliver responses to verifiable consumer requests, free of charge, either through your online account with us, if you have such an account already, or, if you do not have a pre-existing online account, by mail or electronically, at your election. Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request.  We will inform you in writing if we cannot meet that timeline. Keep in mind that we are not required to provide information in response to Right to Know requests more than twice in a 12-month period and any response to a Request to Know will only cover the 12-month period preceding the verifiable request.

Additional California Privacy Rights

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our sites are not currently set up to respond to those signals.

 

14. Changes to the Policy

We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our websites. If we make any significant changes to the Policy, we will post a notice on our websites or contact you to inform you when required by law. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy. The “Effective Date” at the top of this Policy indicates when it was last updated.  The current version of the Policy can be found at https://www.fieracapital.com/en/privacy-policy/.

15. Contact us 

If you have any questions or complaints about how we handle your personal information, please contact us as indicated below or contact the relevant Fiera Capital entity:

Canada:

  • by telephone at 514 954-3300 or 1 800 361-3499;

  • by fax at 514 395-8752;

  • by email at privacy@fieracapital.com;

  • by mail:

    Person Responsible for Protection of Personal Information
    Fiera Capital Corporation
    1981 McGill College Avenue, Suite 1500
    Montreal, Québec H3A 0H5

UK, Isle of Man and European Union: 

Fiera Capital (UK) Limited

Queensberry House
3 Old Burlington Street
London W1S 3AE
United Kingdom

U.S.: 

Asia: 

  • by email at dpo@clearwatercp.com - Attention: ‘Data Protection Officer’

  • by mail Office address : 

Suite 38-03, Suntec Tower 4, 6 Temasek Boulevard
Singapore 038986 
Attention: ‘Data Protection Officer’