1. PROTECTING YOUR PRIVACY.
- THE INFORMATION WE COLLECT AND HOW WE USE IT
- HOW WE COLLECT INFORMATION ABOUT YOU
- HOW WE DISCLOSE AND SHARE YOUR INFORMATION.
- OUR WEBSITE
- YOUR CONSENT
- INTERNATIONAL TRANSFER AND STORAGE OF INFORMATION
- ACCESS, CORRECTION, INQUIRIES, AND COMPLAINTS.
- CONTACT US
2. THE INFORMATION WE COLLECT AND HOW WE USE IT.
In general, we collect and use personal information for the following purposes:
Account Opening: When you are referred by your advisor to open an account with us, we collect personal information about you that is kept on file in accordance with industry regulations, including your name, date of birth, address, citizenship, income, investments, debts, marital status, dependents, and social insurance number.
Only authorized employees, authorized third-party service providers and regulatory authorities have access to this information. The information that we collect allows us to identify you, to assess your investment needs, to provide you with financial products and services requested, to protect you against possible fraud, to manage our risks and operations and to comply with legal and regulatory requirements.
If you are an individual, Harness is required to collect, use and disclose your Social Insurance Number for income tax reporting purposes. We may also share it with credit reporting agencies as an aid to identify you.
We also collect an email address, a password, and information for security questions to allow you to login into your account on our Website.
Marketing Communications: We may obtain your consent to use your information to send you marketing communications by mail or email that promote products and services that may be of interest to you. You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below. Please note that you may continue to receive certain transactional or informational electronic communications from us.
Customer Service: When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offerings.
Employment: If you apply for a position at Harness, we will collect the personal information contained in, and generated in relation to, your application package, such as your work experience, education information, and contact information in order to evaluate your application and assess whether to offer you a position at Harness. For candidates who are not offered or do not accept a position, we normally retain this information for a reasonable period in the event that an appropriate position becomes available or that you reapply to Harness. If you accept a position at Harness, the information will be retained in accordance with our privacy procedures applicable to the personal information of Harness Members.
Website: We also collect some personal information through cookies, tracer tags and web beacons on our Website. Please refer to the section 5 below for more information on our use of these technologies.
3. HOW WE COLLECT INFORMATION ABOUT YOU.
We typically collect personal information directly from you or through our interaction with you. We may however collect this information from third parties, including your advisor (who discloses your personal information only with your consent), credit reporting agencies, or other financial institutions.
4. HOW WE DISCLOSE AND SHARE YOUR INFORMATION.
Referring Advisors: If you open an account with us, Harness will, from time to time, share your personal information with your referring advisor for the purpose of opening, servicing, and maintaining the account(s). The personal information disclosed may include information related to accounts, investment performance, tax documents, transfers, account expenses, beneficiaries, deposits and withdrawals.
Service Providers: Harness may also transfer your personal information to our Service Providers used to administer or provide products, services or information on our behalf such as to host the Website, operate certain of its features, send marketing messages or other communications, or manage and analyze data and our advertising effectiveness. We use reasonable measures to require the organizations with whom we share your personal information for these purposes to use your personal information only to perform the services we have contracted them to provide.
Legal/Compliance: We and our Canadian, US and other service providers may provide your Personal Information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian, US or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspect loss or harm to persons or property.
5. OUR WEBSITE.
In general, you can visit the website without telling us who you are or submitting any personal information. However, as most websites do, we track usage patterns on our website Each time you visit our website, our server records your Internet service provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URLs you came from. We use this information to better understand and optimize our website service.
You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features and functionality of our website.
You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:
- https://policies.google.com/technologies/partner-sites and
Third Party Links: For your convenience, we may offer links from our website to other websites. However, Harness is not responsible for, nor do we accept any liability for, the personal information collection, use, and disclosure practices of other entities to which our website may link. You should consult the privacy policies of these other entities before providing any personal information on their websites.
6. YOUR CONSENT.
Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use, and disclosure of information about you, by contacting us via email at email@example.com. Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services. There are instances where Harness may collect, use, or disclose your personal information without your consent, for example, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.
You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below.
7. RETENTION OF PERSONAL INFORMATION
We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by Canadian privacy laws and securities laws and regulations.
8. INTERNATIONAL TRANSFER AND STORAGE OF INFORMATION
Harness has implemented reasonable physical, organizational, and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized Harness Members, agents, and mandatories have access to your personal information. You can generally visit the Harness website without providing any personal information. However, given that electronically submitted data is not one hundred percent (100%) secure, we make no warranties as to the security of any such personal information that you submit, which you do at your own risk.
10. ACCESS, CORRECTION, INQUIRIES, AND COMPLAINTS.
If you wish to request access to, or correction of, your personal information in custody or control of Harness, please make your request in writing to us at the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date. Please inform us as soon as possible of any changes to your personal information. If you have any questions, requests or complaints about our personal information practices, please contact us via email at firstname.lastname@example.org.
12. CONTACT US
Please contact our Privacy Officer if:
- you wish to access, update, and/or correct inaccuracies in your Personal Information, or
- you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.
You may contact our Privacy Officer by email at email@example.com or by mail at the following address:
1128 Yonge St., Suite 300
Last update: October 2021