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Privacy Policy

At Invesco Trimark, our mission is to be the premier provider of enduring solutions for investors and their advisors. In fulfilling our mission, we are committed to protecting your privacy and maintaining the confidentiality of your personal information.

What is personal information?

Personal information means any information about an identifiable individual, including information such as your home address and telephone number, date of birth, age, marital status, religious affiliation, employment history, Social Insurance Number and credit history.

How do we collect your personal information?

Personal information is collected directly from you or through your advisor when you open an account with us. The information is obtained by us when you send us a completed application form or when your advisor transmits information to us electronically. In servicing your account, we will also generate personal information, including transaction information. From time to time, we may be required to collect information from a third party who is not your advisor. The executor of an estate is an example of a third party who may provide information about you or your account to us.

What information do we collect?

The personal information in your client account may include your name, mailing address and phone number(s), Social Insurance Number, birth date, account holdings and transactions and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request. For example, where you have established a pre-authorized chequing plan which enables you to make purchases at regular intervals, we hold your financial institution account number. At times, we may request independent sources to verify and supplement information that you provide to us.

E-mail policy

In order to effectively communicate with the registered users of this website, we require a valid e-mail address. We do not sell or share our list of e-mail addresses with any third parties for marketing purposes.

How we use your e-mail address:

• If you subscribe to our e-option service you will receive an e-mail notification when information you request is available online. You may update your e-option settings at any time.
• We may need to contact you regarding your account at advisor.Invescotrimark.com. Please note that you will never receive an e-mail from Invesco Trimark asking you to provide your login id, password or any other sensitive personal information.
• In order to provide the best service possible, we may wish to contact you with information about Invesco Trimark that we feel is of interest to you. Should you receive an unwanted e-mail from Invesco Trimark you may opt out of future mailings at any time.

How do we use your personal information?

We may use your personal information for these stated purposes:

• Identifying you
• Establishing and administering your account
• Ensuring the information in our records is accurate
• Executing your transactions
• Verifying previously given information when necessary
• Providing you and your advisor/dealer with account statements and other account related information
• Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account
• Communicating with you and your advisor/dealer regarding service offering or products which may be of interest to you
• Meeting legal and regulatory requirements

We do not sell your information. We may use your information for general research in an effort to enhance our service and product offerings.

When is information disclosed to third parties?

We disclose your information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy and for no other purpose. Third parties who may be provided with your personal information include:

• Your advisor/dealer
• Other mutual fund companies, financial institutions and securities dealers when necessary to carry out your instructions such as transferring funds
• Other Invesco Trimark affiliates
• Governments, government agencies and regulators
• Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, imaging and document storage
• Entities to whom we are legally obliged to provide information

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At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information.

Disclosing your personal information when required or permitted by law

Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose your information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities.

We may disclose user information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets. In this case, we would ensure that the information disclosed continues to be used only for the purposes permitted by this Privacy Policy and by the entity acquiring the information.

How do we obtain your consent?

In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information.

How can you withdraw your consent?

You may withdraw your consent to our use of your personal information at any time by contacting us at 1-800-874-6275. If you withdraw consent, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.

How can you access and update your information?

Invesco Trimark will provide you with access to your personal information on your written request. Our verification procedures help to minimize risk that such information is released to anyone not authorized to receive it. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law. Except under limited circumstances, you may ask us to amend or update your personal information at any time. Invesco Trimark reserves the right to charge you for our costs incurred in providing the information requested.

Invesco Trimark may not be able to provide you with full access to your information if:

• It contains references to other persons
• We would have to disclose proprietary information confidential to Invesco Trimark or its affiliates
• It has been destroyed
• It is too costly to retrieve
• It cannot be disclosed for legal or regulatory reasons

If we are unable to provide you with access to your personal information, we will give you an explanation.

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How is your information protected?

Invesco Trimark is as concerned with protecting your personal and confidential information as you are. We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and file encryption for on-line activities.

Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your client account.

How long do we keep your information?

In order to service your account and to meet regulatory and legal obligations, Invesco Trimark may be required to maintain information related to you and your account for a certain period of time. Personal information may be destroyed once it is deemed that your information is no longer necessary for the above-mentioned reasons. Personal information is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.

Will we change this policy?

If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. You have a right to know at all times what information we collect, how it is used, and under what circumstances we can disclose it. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower right hand corner of this web page. We recommend that you print a copy of the updated policy for your reference and revisit it from time to time to ensure you are aware of the changes.

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Resolution of your concerns:

If you have any issues or concerns, please take the following steps:

Step 1. Your issue or concern may be easily resolved by contacting our Client Relations Group:
Telephone: 1-800-874-6275
Fax: 1-800-631-7008
E-mail: inquiries@Invescotrimark.com

Step 2. If speaking to our Client Relations Group does not resolve your issues or concerns, you may contact the Privacy Office at Invesco Trimark at privacy@Invescotrimark.com

Step 3. If after contacting the Privacy Office your issue or concern has not been resolved, you may contact the Privacy Commissioner of Canada:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa, Ontario K1A 1H3
Telephone: 1-800-282-1376 or (613) 995-8210
Fax: (613) 947-6850  

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