Privacy Statement

Introduction

K.J. Harrison & Partners Inc. is committed to respecting the collection, use, protection and disclosure of our clients’ personal information. Your account is governed by the Managed Account Agreement and also by the New Client Application Form.  K.J. Harrison & Partners Inc. has appointed NBCN Inc. as its Custodian/Carrying Broker.

Personal Information Defined

Personal information refers to information that specifically identifies you as an individual and is provided to or collected by us. It includes, for example, your name and address, age and gender, personal financial records, identification numbers including your social insurance number (SIN), your employment history and banking information.

Collection and Use of Personal Information

When you open an account with us, we will obtain personal information about you that will be kept on file in accordance with industry regulations. Only authorized individuals and entities have access to this information. The information that we collect allows us to identify you, protect you against possible fraud, assess your potential investment needs, and to comply with legal and regulatory requirements.

Specific Personal Identification

We ask for a variety of information when you open an account with us. Securities industry regulations legally require that we obtain a minimum amount of information about you so that we can provide the proper level of service and supervision to your account.

If you are an individual, K.J. Harrison & Partners Inc. will collect, use and disclose your Social Insurance Number for income tax reporting purposes.

We will collect, use and forward a photocopy of your personal ID to the Custodian as proof of residency for U.S. withholding tax purposes.

Personal Information to External Sources

Your personal information will be disclosed to those external sources that provide services to us such as our Custodian, financial institutions and other parties. For example, service providers who we hire to undertake activities, such as processing trades for your account and sending monthly statements to you, will have access to certain account information including your name and address in order to perform their required functions. We require third party service providers to sign a Privacy Agreement to ensure that your information remains confidential.

We are also obliged to provide your information to regulatory bodies within the investment industry. We may also be required to disclose your information to government agencies or law enforcement agencies.

This Client Privacy Agreement also covers our release of your personal information to your personal accountant, as per your instructions.

Consent

Your consent is required before we may provide your information to any third parties. The consent that you provide to K.J. Harrison & Partners Inc. with regards to the collection, use and disclosure of your personal information may be cancelled at any time by providing written notice to us. We do not require your consent to the collection, use and disclosure of your personal information where such collection, use and disclosure are reasonably required:

By opening an account at K.J. Harrison & Partners Inc. you are providing consent to us to collect, use and disclose your personal information as set out in this agreement.
Protection of Personal Information

We will take appropriate steps to protect your information against unauthorized access and use. Our employees are required to sign a confidentiality agreement as a condition of employment.  We retain your information only as long as we require it to service your account, or as long as industry regulations require.

Retention of Personal Information

K.J. Harrison & Partners Inc. will retain your personal information on file after you cease to be a client of ours for as long as we require such information or as long as is demanded by regulatory requirements.

Access and Corrections to Personal Information

You may review the information you have provided to us and make corrections to it in a timely manner. We may request that you provide corrections in writing. We will take reasonable steps to ensure that your personal information is accurate and up-to-date.

Your Right to Withdraw Consent

By opening an account with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us.

Addressing Your Concerns

We will address and respond to any of your concerns about our handling of your information. You may address questions or privacy-related complaints to compliance@kjharrison.com or to Compliance, K.J. Harrison & Partners Inc., 60 Bedford Road, Toronto, Ontario, M5R 2K2.