Privacy Policy

Privacy Policy

Sodhi Asset Management Inc. (SAMI) is required to collect private information from our clients and prospective clients in order to properly fulfill our duties. Understanding a client’s needs and requirements, financial position and family issues enables us to ensure that all investment recommendations are suitable. This is both a regulatory requirement and good business. SAMI is committed to protecting our clients’ privacy and the confidentiality of their personal information in our possession. This policy explains the measures we take to fulfill these commitments.

“Personal Information” is defined within the Federal Government’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), but in summary, personal information encompasses any personally identifiable information about an individual. Your personal information is protected by federal legislation under the Personal Information Protection and Electronic Documents Act (PIPEDA), or by provincial legislation that is “substantially similar” to PIPEDA.

PERSONAL INFORMATION Collected

We ask clients to complete elicit only the information we need for contractual, regulatory and income tax requirements, including: name, address, phone and fax numbers, email addresses, birth date, social insurance numbers, asset holdings and values, investment knowledge and objectives, spouse’s name and occupation, and children’s and dependents’ names and ages. Our application forms for registered retirement accounts elicit only the information needed to register these accounts with the government including: social insurance number, spouse’s or designated beneficiary’s name and birth date. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this policy.

LIMITed ACCESS TO CLIENTS’ PERSONAL INFORMATION

We record clients’ personal information electronically on computer servers to which only authorized persons have access. Relevant employees may only access information by means of secure passwords. We authorize employees to have access to clients’ personal information only on a “need to know” basis. We have installed hardware and software security to keep our servers clean and secure. We maintain a duplicate copy of our data at an offsite location for disaster recovery purposes. This data is password protected. We keep paper copies of clients’ personal information in filing cabinets. We keep the computers and filing cabinets in which such information is stored in areas of our business premises that are kept locked when not in use.

PREVENTion of UNAUTHORIZED DISCLOSURE OF CLIENTS’ PERSONAL INFORMATION

We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to sign our privacy document that obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information. We shred paper documents containing clients’ personal information before discarding such documents.

Access to Information

Our custodians National Bank Correspondent Network (NBCN) and Interactive Brokers have access to client informationand are required to keep client information confidential and to use it only to provide services on behalf of SAMI. Access to your personal information is available upon your written request.

Consent

Your consent to the collection, use and disclosure of your personal information is given at the inception of your relationship with SAMI. It is your right to withdraw full or partial consent. Please be aware that withdrawing your consent may prevent us from continuing to provide you with our services.