Northwood Family Office Ltd.
(hereafter referred to as ‘Northwood’)

We are committed to respecting and protecting the privacy and confidentiality of our clients’ personal information. We want you to know why we ask for your personal information, how we use your personal information in establishing and maintaining your relationship with us, how we keep your personal information confidential, and how you can inquire about the personal information we hold about you.

This Code applies to the operations of Northwood Family Office Ltd.

Any changes to our information handling practices shall be acknowledged in this Code on a timely manner. We may add, modify or remove portions of this policy when we feel it is appropriate to do so and, if the changes are material, will provide you with a revised code. Please refer to our website at www.northwoodfamilyoffice.com to obtain the most recent version of this Code.

Employee Responsibilities

Each and everyone one of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility which governs their actions, even if they leave or retire.

We keep our employees informed about our policies and procedures for protecting personal information and reinforce the importance of complying with them. All employees are required, as a condition of their employment, to conform to this Code.

What is Personal Information

The term “personal information” refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes information that you provide or that we collect from other sources with your permission, for example: your name and address, age and gender, personal financial records, identification numbers including your social insurance number, personal references, and employment records.

Why we ask for your Personal Information

We want to work with you to help you achieve your financial goals, to provide you with value-added service on an ongoing basis, and to establish a lasting financial relationship with you that will grow and change as your financial needs evolve.

The better we know you, the better we are able to serve you. We therefore ask you for your personal information for the following purposes:

  • to verify you identity and protect against fraud,
  • to understand your investment requirements,
  • to determine the suitability of products and services for you,
  • to offer you products and services that may be of interest to you,
  • to set up and manage products and services you have requested, and
  • to comply with laws and securities regulations.

Some of the information we will ask for and use, either at the time of account opening or on an updated basis is also required to satisfy the legal or regulatory requirements of federal and provincial governments and/or other regulatory authorities.

In general, you can choose not to provide us with some or all of your personal information. However, please understand that if you make this choice, we may not be able to provide you with the product, service, or information that you requested or that was offered to you, or is typically offered to clients.

Obtaining, Verifying and Accessing Your Personal Information

We obtain personal information about you primarily from you. We may also obtain financially-related information from other sources with your consent.

If you want to review or verify your personal information, or find out to whom we have disclosed it as permitted by this Code, direct your request to the Compliance Department.

At that time, we will need specific information from you to enable us to search for, and provide you with, the personal information we hold about you. If we are unable to provide you with access to your personal information, we will always explain the reason why.

Keeping Your Personal Information Accurate

We are committed to maintaining the accuracy of your personal information for as long as it is being used for the purposes set out in this Code, and provided that you keep us up-to-date. Prompt notification of any changes, such as your address or telephone number, will help us provide you with the best possible service. Should you discover, upon review of your personal information, that amendments are required, please advise us. We will make our best efforts to advise others of any important amendments to your personal information that we may have released to them.
If we do not agree to make the amendments that you request, you may challenge our decision. We will make a record of this challenge and, if necessary, disclose the challenge to third parties who also possess that personal information.

Releasing Your Personal Information

Northwood does not disclose your personal information to third parties other than in the following circumstances or for the following purposes:

  1. in connection with normal business operations to open, maintain, administer, or service your account, including, without limitation the mailing of product information materials, the provision of customer service (including services rendered by third party agents or affiliates), the provision of back office administrative services (including clearance and settlement services, the mailing of account statements and reports and record-keeping services), for audit or statistical purposes;
  2. to legal counsel for the purpose of obtaining legal advice;
  3. where we are required or permitted to do so by law, including to any law enforcement agency, securities regulatory or self-regulatory organization.

By opening or maintaining an account with us or using our services, you have consented to the disclosure of your personal information to a third party in the circumstances or for the purposes described above.

Keeping Your Personal Information Confidential

Personal information is protected at Northwood by safeguards that are reasonable to the sensitivity against unauthorized access, disclosure, copying, use or modification. Safeguards include physical protection (such as locked cabinets and restricted access to offices), organizational measures (such as security clearances) and technological measures (such as passwords and encryption).

In circumstances where we use third parties to provide services to you on our behalf, such as administrative functions or trade processing, they are given only the information needed to perform those services. We have contracts in place holding these companies to the same high standards of confidentiality by which we are governed and require that any information provided by us must be kept strictly confidential and used only for the purposes of the contract.

We have strict procedures in place when destroying, deleting, or disposing of personal information when it is no longer required for the purposes set out in this Code, or by law.

Retention of Your Personal Information

We only keep your personal information for as long as we need it to meet the purposes set out in this Code. The length of time we retain your personal information depends on:

  • the type of product or service you have with us, and
  • any legal or regulatory requirements we may have to meet.

For example, we must be able to respond to any concerns you may have, even if you are no longer a client of ours. We have retention policies in place that govern the destruction of personal information.

Your Options

You can choose not to provide us with some or all of your personal information. You can also withdraw your consent to our use of your personal information, as long as:

  • reasonable advance notice is given, requesting no further use or communication of personal information to which the privacy legislation applies;
  • there are no legal requirements for the use of your personal information; and we can continue to fulfill our contractual obligations to you.

Any questions, requests or complaints can be directed to the address below.

Northwood Family Office Ltd.
130 King Street West
Suite 2250, P.O. Box 245
Toronto, Ontario, M5X 1C8
Phone (416) 502-1245

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