Privacy Policy

Brandes Investment Partners & Co. operating as Bridgehouse Asset Managers (“Bridgehouse”) is committed to safeguarding your privacy and protecting the personal information you provide to us. This Privacy Policy is designed to help you understand what information Bridgehouse collects, how Bridgehouse uses and safeguards that information, and with whom Bridgehouse shares that information.

By visiting our website, www.bridgehousecanada.com (the “Website”), you are acknowledging and accepting this Privacy Policy.

COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

What is personal information and how do we collect it?

We collect the information you provide to us on account application forms, paper and electronic instructions, and telephone instructions from you or your financial advisor, as well as information you submit to our Website. This information may include your:

• name and address
• financial advisor information
• contact information
• beneficiary name(s)
• Social Insurance Number
• banking information
• date of birth
• investment instructions

Some of what is collected depends on the services you request. For example, we require your banking information to set up automatic deposits or withdrawals on your account(s). Except as permitted or required by law, Bridgehouse limits its collection, use, retention and disclosure of your personal information to that which is reasonably necessary for the purposes described below.

If you are an advisor accessing parts of the Bridgehouse Website that are password protected, to ensure that we keep you informed of the other such products and services once you submit your password and enter, the Website will recognize who you are and collect all the information you submit including your name and the tools, products and services that your use of the Website indicates are of interest to you. Any information collected from this Website may be associated with other identifying information that we have about you.

How do we use your personal information?

Bridgehouse may use your personal information for the following purposes

  • identifying you
  • establishing and administering your account
  • processing your transactions
  • meeting legal and regulatory requirements
  • providing you and your Dealer with account statements, transaction confirmations, tax receipts, financial statements, proxy mailings and other information needed to service your account
  • communicating with you
  • contacting your financial advisor
  • tax reporting
  • ensuring our records are accurate
  • verifying previously provided information, if necessary
  • collecting a debt owed to Bridgehouse
  • engaging in the financing or sale of all or part of our businesses, reorganizing our businesses, and obtaining and submitting insurance claims

How do we protect your information?

Only Bridgehouse employees with a business need to know, or whose duties reasonably require it, are granted access to your personal information. Bridgehouse also shares your information with our third party service providers to maintain your account(s). We do not now (nor do we intend to) sell, rent or otherwise market your personal information to third parties.

Your personal information may be processed and stored in India. The Indian government, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your personal information through the laws of India.

We maintain physical, procedural and electronic controls appropriate to the sensitivity of your information, to protect it against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. These safeguards include secure office premises for authorized employees only, secure networks, and secure databases. All safeguards are tested and updated on a regular basis. Bridgehouse protects your personal information disclosed to third parties by ensuring that such parties have policies in place to protect the confidentiality of the information.

Bridgehouse maintains reasonable and systematic controls, schedules and practices for information and records retention, and the destruction of personal information that is no longer necessary or relevant for the identified purposes, or required by law to be retained. When documents containing such information are destroyed, erased, or made anonymous, Bridgehouse makes sure that any personal information contained in the documents is protected.

How do we protect your information online?

Bridgehouse assures you that the security and confidentiality of the personal information that you disclose while visiting Bridgehouse’ Website will be respected. In addition to the privacy measures taken above, Bridgehouse uses a number of protections to maintain your security online including the use of firewall barriers, encryption techniques, and user authentication procedures.

Bridgehouse may record certain usage information, including number and frequency of visitors to our Website. In addition, we may use cookies to recognize, measure, and track visitors to the Website, track usage preferences to customize aspects of the site to you, and to record when a visitor has viewed and accepted our terms and conditions or provided consent. This information may be used to alert you to software compatibility issues, improve our Website functionality, enhance security or provide you with customized services.

You may reduce or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. Please note that to make full use of the Website, your computer or mobile device will need to accept cookies, as the site will not function properly without them. In addition, cookies are required in order to provide you with personalized features on the website.

CONSENT

When you agree to use our services or submit personal information to Bridgehouse, either directly or through your financial advisor, you are consenting to our collection from, verification with, and communication to, any third party for the purposes described above. You also consent to the collection, use, disclosure and processing of your information by Bridgehouse agents and service providers for the purposes set out in the Privacy Policy. You may withdraw your consent for us to use your personal information at any time by calling us at 1-888-861-9998 or writing to the Chief Compliance Officer at Bridgehouse Asset Managers, 20 Bay Street, Suite 400, P.O. Box 62, Toronto, Ontario, M5J 2N8, subject to legal or contractual restrictions and reasonable notice. However, withdrawal of your consent may affect our ability to administer your account(s). Contact Bridgehouse for more information regarding the implications of a withdrawal of consent.

THIRD PARTY WEBSITES

Bridgehouse may establish links between this Website and one or more websites operated by third parties. Bridgehouse may also advertise our products and services on other websites not affiliated with Bridgehouse. Bridgehouse has no control over any such other websites, the contents therein or the products or services offered. Your access to and use of such websites is governed by the terms of use and privacy policies of those sites, and shall be at your own risk. Bridgehouse is not responsible for the privacy practices or content of such websites.

ACCESSING YOUR PERSONAL INFORMATION

You may access the personal information we hold about you at any time by contacting us with a written request. We may be unable to provide you with some information in certain circumstances, such as if the information also refers to other individuals, is subject to legal privilege, contains confidential information, cannot be retrieved using your name or account number, or is otherwise permitted or restricted by law. If you wish to notify Bridgehouse of any changes to your personal information, or if you believe that any information we hold about you is inaccurate or incomplete, please contact us at 1-888-861-9998.

CHANGES TO THIS PRIVACY POLICY

We have provided you with the complete Privacy Policy. You may also view it on our Website at www.bridgehousecanada.com. Bridgehouse reserves the right to modify or supplement the Privacy Policy at any time. If we make any material change to the Privacy Policy, we will post a notice on our website with a link to the updated Privacy Policy. Please read any such notice and the new policy. Your continued use of Bridgehouse’s services will constitute your acceptance of the new terms and conditions and grant Bridgehouse the right to use the information you previously supplied, and any new information, to service your Bridgehouse accounts. However, we will seek your consent if we want to use your personal information for purposes other than those to which you have previously agreed.

YOUR PRIVACY CONCERNS

If you have questions or comments about Bridgehouse’s privacy practices, please contact us at 1-888-861-9998 or at privacy@bridgehousecanada.com.