ZLC complies with British Columbia’s privacy legislation (the Personal Information Protection Act or ‘PIPA’). This act governs the collection, use and disclosure of personal information by all private sector organizations in the province. We maintain the confidentiality of all client information that we collect, use and disclose in our business.
Why we need access to personal information.
To provide financial services to our clients we need access to relevant facts and information that relate to their personal and business finances.
How we collect, use and disclose personal information.
Wherever practical we endeavor to collect personal information directly from the person to whom the information pertains. If necessary we may collect personal information from other sources. By using ZLC’s services, you consent to our necessary collection, use or disclosure of your personal information in order to properly serve you as our client.
What personal information we collect.
Identification and contact information, such as your name, address, telephone and fax numbers, email address, date of birth, social insurance number and other identification information required for money laundering and income tax compliance purposes
Financial information, such as your income, net worth, and investment profile
Employment information, such as your employer, industry and occupation
Transactional information made with or through us and other financial institutions
Health information, normally with respect to applications and requests for insurance products or services
Other information, such as citizenship, residency, marital status and spousal information that may be related to your account(s) or transaction(s).
As regulated entities, ZLC is required by law or regulation to obtain certain information about you in the course of providing products and services to you. For example, we ask you for your financial, employment, and other information to fulfill our securities regulatory “Know Your Client” obligation. As another example, we collect transactional and other information to meet our securities regulatory gatekeeper obligation and obligation to report suspicious transactions to anti-money laundering and anti-terrorist financing authorities. The choice is always yours as to whether or not to provide us with your information, however, if you decide to withhold certain information we may be unable or restricted in our ability to provide the products, services or information you have requested.
We do not rent or sell your personal information to third parties, but in limited circumstances your personal information may be shared with third parties with whom we have a business relationship. For example:
We may share your personal and account information with third parties who provide services to ZLC such as custodians and insurance product providers. Our third party service providers only have access to the information necessary to perform their services. The third party service provider will also be subject to the privacy laws of the jurisdiction in which they are located.
Personal and account information may be shared with product providers such as fund companies where you have instructed us to transact in on your behalf. Personal health information collected in connection with an application or request for insurance products is only shared with the insurance companies to which we apply on your behalf to process your application or service your policy(ies).
BC’s privacy Act deems that you consent to our collecting, using or disclosing your personal information if our purpose at the time would be considered obvious to a reasonable person. In these circumstances we will collect use or disclose personal information without obtaining your written or verbal consent. The Act also permits us to collect, use or disclose personal information in some circumstances without an individual’s consent. These include (but are not limited to) circumstances where:
The personal information is available to the public from a prescribed source
The collection, use or disclosure of personal information is required or authorized by law.
When we collect, use or disclose any personal information, we make reasonable efforts to ensure that it is accurate and complete.
Protecting the security of personal Information.
We recognize our professional and legal obligations to protect the confidential or personal information our clients provide to us during the course of our business. To that end we have made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.
Requesting access to personal information.
BC’s privacy Act permits you to submit written requests to us to provide you with:
Personal information under our custody and control.
Information about how we are using or how we have used personal information under our control
Names of individuals and organizations to whom we have disclosed personal information under our control.
If you request access to this information, we will respond in the time allowed by the Act and will make a reasonable effort to help you and respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits us to charge. Your ability to access your personal information under our control is not absolute. PIPA provides that we must not disclose personal information when:
Disclosing the personal information would reveal confidential commercial information that if disclosed could, in the opinion of a reasonable person, harm the competitive position of an organization.
Requesting corrections to personal information.
The law permits you to submit written requests to us to correct errors or omissions in your personal information that is in our custody or control. We will:
Correct the personal information and, if reasonable, send correction notices to any other organizations to whom we disclose the incorrect information, or;
Decide not to correct the personal information, but add a note to the information that a correction was requested but not made.
If you have any questions about our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:ZLC Financial Group and ZLC Private Investment Management Attention: Privacy Officer 1200 Park Place, 666 Burrard Street Vancouver, BC V6C 2X8 Tel: (604) 685-1096 Fax : (604) 609-7238
If you are dissatisfied with our handling of your personal information we invite you to contact our Privacy Officer in writing, telling us the reason for your concern. If, after our Privacy Officer has reviewed and responded to your concern, you remain dissatisfied, you may wish to contact the Office of the Information and Privacy Commissioner for British Columbia at:Office of the Information and Privacy Commissioner for British Columbia P.O. Box 9038, Stn Prov Govt Victoria, BC V8W 9A4 Tel: (250) 387 5629 Fax: (250) 387 1696 E-mail: firstname.lastname@example.org