Privacy Policy Notice
Facts
WHAT DOES GMG PRIVATE COUNSEL ULC (“GMG”) DO WITH YOUR FINANCIAL INFORMATION?
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depends on the product or service you have with us. This information can include:
- Social Security number and income
- Account balances and assets
- Transaction history and investment experience
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons GMG chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information
For our everyday business purposes such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
Does GMG share?
Yes
Can you limit this sharing?
No
For our marketing purposes to offer our products and services to you
Does GMG share?
Yes
Can you limit this sharing?
No
For joint marketing with other financial companies
Does GMG share?
No
Can you limit this sharing?
Not Applicable
For our affiliates’ everyday business purposes information about your transactions and experiences
Does GMG share?
Yes
Can you limit this sharing?
No
For our affiliates’ everyday business purposes information about your creditworthiness
Does GMG share?
No
Can you limit this sharing?
Not Applicable
For our affiliates to market to you
Does GMG share?
No
Can you limit this sharing?
Not Applicable
For non-affiliates to market to you
Does GMG share?
No
Can you limit this sharing?
Not Applicable
Questions?
Call (416) 861-1998 or go to Gavingroup.ca
Who we are
Who is providing this notice?
GMG
What we do
How does GMG protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and building.
How does GMG collect my personal information?
- We collect your personal information, for example, when you:
- Open an account
- Deposit money
- Seek advice about your investments
- Enter into an investment advisory contract
- Tell us about your investment or retirement portfolio or earnings
We also collect your personal information from others, such as affiliates or other companies.
Why can’t I limit all sharing?
U.S. Federal Law gives you the right to limit only
- sharing for affiliates’ everyday business purposes – information about your credit worthiness
- affiliates from using your information to market to you
- sharing for non-affiliates to market to you
U.S. state laws and individual companies may give you additional rights to limit sharing.
Definitions
Affiliates
Companies related by common ownership and control. They can be financial and nonfinancial companies.
- Our affiliates include Gavin Management ULC, Gavin Wealth & Wellness ULC, Focus Operating, LLC, Connectus Group, LLC and Focus Client Solutions, LLC
Non-affiliates
Companies not related by common ownership and control. They can be financial or nonfinancial companies.
- We do not share with non-affiliates.
Joint marketing
A formal agreement between nonaffiliated financial companies that together market financial products or service to you.
- We do not jointly market.
Other Important Information
- This document is meant to also serve as our privacy notice under applicable Canadian federal and provincial law.
- Our privacy policy and the above disclosure may change from time to time. We will provide you notice of any material change to this disclosure before we implement the change.
- In addition to the prescribed information categories of information we collect found on page 1, GMG will also collect non-public identifying information including your name, address, e-mail address and telephone number.
- In addition to the prescribed definition of “For our everyday business purposes” found on page 1, GMG may also provide information to service providers assisting with accounting, auditing, legal and compliance obligations or general maintenance of industry standards.