DiBrina Sure Group Privacy Policy

Website Privacy Policy:

Our policy is to collect no personal information about you when you visit the DiBrina Sure web site, unless you affirmatively choose to make such information available to us.

When you visit the DiBrina Sure web site, the Web server automatically recognizes only the Internet domain and IP address from which you accessed the site. This information does not result in the identification of your personal e-mail address or other personal information. DiBrina Sure does not monitor your web-browsing activities with cookies. However, cookies may be used by some DiBrina Sure applications when necessary to complete a transaction, to process data submitted to us online or to pass information from one web page to another.

If you choose to share personal information, such as sending a message, or filling out an electronic form with personal information, this information will be used to fulfill the request for which the information was submitted. This information is not shared with or sold to any other organizations.

General Privacy Policy:

Introduction

DiBrina Sure Group ("the firm") collects, uses and discloses personal information in the possession, or under the control, of its clients to the extent required to fulfill its professional responsibilities and operate its business. The firm is committed to maintaining the privacy of personal information provided by its clients and protecting all personal information in its possession or control. This Privacy Policy sets out the principles and procedures that the firm follows in meeting its privacy commitments to its clients and complying with the requirements of federal privacy legislation.

Principle #1 - The firm is accountable for personal information in its possession or control.

The firm is accountable for all personal information in its possession or control. This includes any personal information that the firm received directly from clients who are individuals, or indirectly, through clients that are organizations (e.g., corporations, government entities, not-for-profit organizations).

The firm has:

  • Established and put into effect policies and procedures aimed at properly protecting personal information;

  • Educated its partners and employees regarding its privacy policy and their role and responsibilities in keeping personal information private; and

  • Appointed its Chief Privacy Officer to oversee privacy issues at the firm.

If you have any questions about the firm's privacy policies and practices, the firm's Privacy Officer can be reached by email at nathan@dibrinasure.com, by phone at 705-688-9393, or by letter at 7 Cedar Street, Suite 202, Sudbury, Ontario, P3E 1A2.

Principle #2 - The firm identifies the purposes for which it collects personal information from clients before it is collected.

The firm collects personal information from clients and uses and discloses such information, only to provide the professional services that the client has requested. The types of information that may be collected, and the purposes for which it is collected, are set out in under Principles 3 and 4 of this privacy statement.

Principle #3 - The firm obtains a client's consent before collecting personal information from that client.

All personal information is collected on various forms and applications required for financial transactions. Clients are required to sign the forms at the time of disclosing their personal information. The forms set out our responsibility to obtain any consents required under applicable privacy legislation, for collection, use and disclosure to us of personal information. By signing the forms, you are formally acknowledging this responsibility. The type of information collected includes, but is not limited to:

  • Basic information such as your name, address, telephone and fax numbers, e-mail address, birth date and marital status

  • Personal identification numbers (e.g., social insurance numbers)

  • Financial information (e.g. credit ratings, payroll information, personal indebtedness, assets, etc.)

  • Employment information

Principle #4 - The firm collects only that personal information required to perform its professional services and operate its business, and such information is collected by fair and lawful means.

The partners and staff involved in servicing your account need access to some or all of the types of personal information, noted under principle #3 above, to provide the various services offered by the firm. Such personal information will be a significant component of various transactions and events affecting the services offered by the firm.

Principle #5 - The firm uses or discloses personal information only for purposes for which it has consent, or as required by law. The firm retains personal information only as long as necessary to fulfill those purposes.

The personal information collected from a client during the course of a professional service may be:

shared with the firm's personnel participating in such engagement;

shared with external financial and insurance companies;

disclosed to partners and employees within the firm to the extent required to assess your ongoing needs for services and/or insurance and financial products.

The firm regularly and systematically destroys, erases, or makes anonymous personal information no longer required to fulfill the identified collection purposes, and no longer required by laws and regulations.

Principle #6 - The firm endeavours to keep accurate, complete, and up-to-date, personal information in its possession or control, to the extent required to meet the purposes for which it was collected.

Individual clients are encouraged to contact the firm to update their personal information.

Principle #7 - The firm protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.

Physical security (e.g., restricted access, locked rooms and filing cabinets) is maintained over personal information stored in hard copy form. Partners and employees are authorized to access personal information based on client assignment.

Principle #8 - The firm is open about the procedures it uses to manage personal information.

Up-to-date information on the firm's privacy policy can be obtained from the firm's Privacy Officer.

Principle #9 - The firm responds on a timely basis to requests from clients about their personal information which the firm possesses or controls.

Individual clients of the firm have the right to contact the partner in charge of providing service to them and obtain access to their personal information. Similarly, authorized officers or employees of organizations that are clients of the firm have the right to contact the partner in charge of providing service to them and obtain access to personal information provided by that client. In certain situations, however, the firm may not be able to give clients access to all their personal information. The firm will explain the reasons why access must be denied and any recourse the client may have, except where prohibited by law.

Principle #10 - Clients may challenge the firm's compliance with its Privacy Policy.

To challenge the firm's compliance with its Privacy Policy, clients are asked to provide an email message or letter to the firm's Privacy Officer (see contact information under principle #1 above). The firm's Privacy Officer will ensure that a complete investigation of a client complaint is undertaken and will report the results of this investigation to the client, in most cases, within 30 days.

The information in this communication is subject to change without notice. Investment Planning Counsel or DiBrina Sure Group will not be held liable for any inaccuracies in the information not maintained by Investment Planning Counsel or DiBrina Sure Group such as a linked site. This communication does not constitute an offer or solicitation by anyone in any jurisdiction in which such an offer of solicitation is not authorized or to any person to whom it is unlawful to make such an offer or solicitation. Prospective investors who are not resident in Ontario should consult with their financial consultant or mutual fund consultant to determine if these securities may lawfully be sold n their jurisdiction.

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