WISDOMTREE ASSET MANAGEMENT CANADA, INC.
Scope of Policy
Collection and Use of Personal Information
When direct clients of WisdomTree subscribe for Canadian ETF securities, WisdomTree collects information about such clients (“Personal Information”) including residential address, telephone number and e-mail address and certain other personal information, “know your client” information, identity verification information and other information required under applicable laws and under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (Canada), regulations and policies made thereunder and other applicable laws aimed at the prevention and detection of money laundering and terrorist financing. Personal Information is used for the following purposes:
conducting an analysis of the suitability of a proposed investment in Canadian ETFs;
processing the subscription for Canadian ETF securities, opening and servicing the account;
verifying identity and other information provided to WisdomTree (including bank account);
if applicable, reporting the investment to the relevant securities regulatory authority;
completing books and records information for the Canadian ETF;
detecting and preventing fraud and other unauthorized or illegal activities;
andmeeting legal and regulatory requirements or as otherwise required by applicable law.
WisdomTree may use Personal Information to send client communications by mail, email or telephone marketing or to promote Canadian ETFs or other products and services that may be of interest to clients. Clients can opt-out of these marketing communications at any time by clicking on the unsubscribe link included in marketing email communications or by contacting WisdomTree as set out under Contact Us below. Please note that clients will continue to receive certain transactional or informational electronic communications from WisdomTree after opting out.
How Personal Information is Collected
WisdomTree will not disclose, trade, rent, sell or otherwise transfer Personal Information, without consent, except as otherwise set out herein.
Exempt Trade Report: Clients’ Personal Information, including the number of and purchase price for Canadian ETF securities purchased, may be disclosed to the relevant Canadian securities regulatory authorities and become available to the public in accordance with the requirements of applicable securities and freedom of information laws. Clients authorize such indirect collection of the Personal Information and acknowledge that: (i) the Personal Information is being collected indirectly by the applicable Canadian securities regulatory authority under the authority granted to it in securities legislation; (ii) the Personal Information is being collected for the purposes of the administration and enforcement of applicable Canadian securities legislation; and (iii) clients have been notified that the title, business address and business telephone number of the public official in Ontario who can answer questions about the Ontario Securities Commission’s indirect collection of the Information is: Administrative Support Clerk, Ontario Securities Commission, Suite 1903, Box 55, 20 Queen Street West, Toronto, Ontario, M5H 3S8; telephone number: (416) 593-3684.
Service Providers: Personal Information may be transferred (or otherwise made available) to WisdomTree’s affiliates and other third parties in Canada and the United States who provide services on WisdomTree’s behalf. WisdomTree may use service providers to verify Personal Information (such as identity and bank account number), administer the Canadian ETFs, send email or other communications, or manage and analyze data. In the event Personal Information is transferred to the U.S. 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 those laws. Service providers are given the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
Legal/Compliance WisdomTree, its affiliates and other service providers may provide Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by applicable Canadian, U.S. or other law. Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Sale of Business: Personal Information may be transferred as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of WisdomTree’s business or as part of a corporate reorganization or stock sale or other change in corporate control.
Safeguards and Retention
WisdomTree has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in its custody and control against theft, loss and unauthorized access, use, modification and disclosure. WisdomTree restricts access to Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements. WisdomTree has record retention processes designed to retain Personal Information of its clients for no longer than necessary for the purposes stated above or to otherwise meet legal requirements (which may extend beyond the end of a client’s relationship with WisdomTree).
Access to Personal Information
Clients have the right to access, update and correct inaccuracies in their Personal Information in WisdomTree’s custody and control, subject to certain exceptions prescribed by law. Clients may request access, updating and corrections of inaccuracies in Personal Information in WisdomTree’s custody or control by emailing or writing to WisdomTree at the contact information set out below. WisdomTree may request certain Personal Information for the purpose of verifying the identity of the individual seeking access to his or her Personal Information records.
Access to Personal Information
Lara Misner, Privacy Officer
Tel: 416 304 9228