Privacy Protection Notice

Consent for our collection, use and disclosure of your personal information can be given in a variety of ways.

• Consent can be express, such as when you provide your written consent through one of our application forms.
• Consent can be deemed if you are provided with information about our intended uses and disclosures of your personal information (such as through your receipt of this Privacy Notice), and you do not advise Mackenzie Investments, either verbally or in writing, that you do not consent.
• If you provide personal information to Mackenzie Investments for the purposes of seeking products or services from us, your consent will be deemed for our collection, use and disclosure of your personal information to provide those products and services to you.
• If you have existing products and services with us and you request changes to them, the consent which you gave to us when buying the original products and services remains in effect.
• We may rely on a third party to obtain your consent on our behalf.
• Your consent can be provided by your authorized representative, such as a legal guardian or power of attorney.

If you purchase Mackenzie Investments’ products or services through a Dealer, you are deemed to consent to the sharing of your personal information by the Dealer with us in order to obtain those products and services. Your “Dealer” refers to an individual or entity acting or representing that it acts in connection with your investments such as your investment advisor, broker, or dealer, or on behalf of your investment advisor, broker, or dealer.

We collect and use personal information about you and, if applicable, your spouse and/or beneficiaries, to:

• identify you;
• comply with legal, security, processing, and regulatory requirements;
• protect against error and fraud;
• provide ongoing service;
• offer you products and services to meet your needs; and
• communicate with you about products and services.

We may record your telephone calls with our representatives, and we may monitor live or recorded calls, for quality assurance and training purposes and to confirm our discussions with you.

Use of your Social Insurance Number (SIN)

We are required by law to use your social insurance number when submitting tax reports to the Canada Revenue Agency and may provide it to third parties to prepare and deliver tax reporting to you. We may also use your SIN as an identifier for reasons such as consolidating your holdings so that fees associated with your account are reduced or are not charged more than once, or that your mailings are delivered in one envelope or are not duplicated. We may also share your SIN as a unique identifier for the purposes identified in this Privacy Notice to third parties such as your Dealer, group plan sponsor, and third-party service providers. If you have any questions or concerns about the use of your SIN please contact us.

Use of Personal Information collected when you use our website

We use cookies, pixels and other similar technologies to collect information about your activity on our websites to enable us to improve your user experience and maintain the security and integrity of our websites. By continuing to browse our site, you are giving us consent to use cookies, pixels and other similar technologies. To find out more or to set your own preferences please read our Cookies Policy.

When you register to use InvestorAccess, you provide us with additional personal information and your registration for InvestorAccess constitutes your consent to such information being collected, held, used and disclosed by Mackenzie Investments in the ways and for the purposes identified in the InvestorAccess Conditions of Use. To find out more, please read the InvestorAccess Conditions of Use.

How we collect your personal information depends on how you do business with us. We may collect personal information directly from you when you complete an application form, complete other forms, or communicate with us by telephone, email, or online.

We may also collect personal information about you from a variety of sources including from:

• dealers, financial institutions, licensed agents, intermediaries and third parties with whom you have a relationship;
• government agencies; or
• your spouse or another Mackenzie Investments investor, for example if they designate you as a beneficiary on a registered plan.

We may also collect personal information automatically when you visit our website (please read our Cookies Policy).

Personal information collected from any of these sources may be used or shared as set out in this Privacy Notice.

The specific personal information we collect depends on how you do business with us and which products and services you request. We have categorized the personal information we collect and have provided examples of each category. We may not collect all categories or types of personal information listed for everyone, we only collect personal information needed for products and services that you request.

Identifying and Contact Information

• Full name
• Email address
• Home and mailing address
• Telephone number(s)
• Language preference
• Date of birth
• Gender
• Citizenship and/or residency
• Government identifiers (passport numbers, driver’s license numbers, etc.)
• Social Insurance Number (SIN)
• Taxpayer Identification Number (TIN)

Authentication Information

• InvestorAccess passwords
• Answers to security authentication questions

Financial Information 

• Banking information
• Information about your spouse and/or beneficiaries

Where we are acting as an Exempt Market Dealer:

• Information about your employment and source of income
• Net worth
• Account details and financial statements (including account numbers, account balances, deposits and transactions)
• Investor profile and risk tolerance
• Information about your lifestyle, expenses and liabilities

Digital Information 

• Information collected through cookies when you visit our website
• Browsing preferences
• IP address
• Device identifiers
• Information about your device, operating system or browser

Communications

• Preferred contact method
• Audio recordings of telephone calls with our contact centre
• Records of your communications and correspondence with us 

Mackenzie Investments may share your personal information with third parties for the purposes identified in this Privacy Notice.

Service Providers and Suppliers

We may share your personal information with our service providers and suppliers. For example, we may use service providers and/or suppliers for the following services:

• preparing and mailing account documents;
• cloud, web-hosting, and data-processing services; or
• document imaging and/or storage.

When we share personal information with service providers or suppliers, we ensure by contractual means that the shared personal information is used only for the purposes for which the service provider or supplier is retained. We only share personal information through secure channels, and we impose obligations on our service providers and suppliers for the safeguarding of that information. We may use service providers located in any province in Canada. We may also use service providers located outside of Canada, and where we do, personal information may be disclosed in accordance with the laws of the jurisdiction in which the service provider is located, including to the government in that jurisdiction and its agencies.

Your Financial Advisor and/or Dealer

We may share your personal information with your Financial Advisor and their Dealer as they are entitled to provide instructions and communicate with us on your behalf related to your investment holdings under their administration. If you are a client of a discount brokerage, your personal information will be shared with your brokerage (Dealer) and their employees.

Other Financial Institutions

We may share your personal information for the purposes identified in this Privacy Notice with other financial institutions, such as banks, other investment dealers and other mutual fund companies, with whom you have or have had dealings. We take steps to ensure that these entities have the right to receive the information from us.

Courts, Law Enforcement, Self-Regulatory Organization, and Government Agencies

Mackenzie Investments may share your personal information with government agencies, courts, or law enforcement where required by law to comply with legal, security, and regulatory requirements, including but not limited to: 

• the Canada Revenue Agency, for tax reporting purposes;
• a Self-Regulatory Organization or other authorized body to conduct an investigation;
• law enforcement to respond to valid warrants or court orders; or
• other government agencies.

Your Joint Account Holders and Representatives

We may share personal information with joint account holders if the information was collected for the purpose of establishing or the ongoing operation of the joint account. All joint account holders have consented to such a disclosure of personal information.

We may also share your personal information with an authorized representative, such as a legal guardian, power of attorney, or lawyer, that has a valid legal authority to request your personal information.

Our Affiliates and Subsidiaries

Mackenzie Investments is a subsidiary of IGM Financial Inc. We may share your personal information with our affiliates and subsidiaries where they provide operational, administrative, and support services through shared business resources or on our behalf to administer your accounts with us.

Access to your personal information is limited to Mackenzie Investments employees and authorized contractors who need access to perform their duties for a purpose identified in this Privacy Notice. Our employees commit annually to protect the confidentiality of the personal information they access while performing their duties and must regularly complete privacy and security training.

We have established record retention policies and record retention periods so that your personal information is retained for as long as it is required to fulfill the purposes described in this Privacy Notice, and to comply with legal and regulatory requirements. We are subject to laws and regulations, such as securities, tax, anti-money laundering, and other applicable legislation, which require us to retain certain information about current and former investors for varying specified minimum periods of time.

You may withdraw your consent for Mackenzie Investments to collect, use, and disclose your personal information at any time upon reasonable notice, subject to contractual and legal restrictions. Deciding to withdraw your consent may affect our ability to continue to provide you with the products and services that you have or would like to receive. If you withdraw your consent, your personal information will be retained in accordance with applicable retention periods. Please review the “How long is your personal information stored by Mackenzie Investments?” for more details.

If you wish to withdraw your consent to the collection, use, and disclosure of your personal information or discuss the implications of such a withdrawal, please contact the Chief Privacy Officer through one of the means listed at the end of this Privacy Notice.

We protect your personal information using security safeguards appropriate to the sensitivity of the information. These safeguards are designed to protect against loss, theft, unauthorized access, use, disclosure, copying, or modification of personal information, regardless of the format in which it is held.

We take steps to safeguard your personal information using several methods, including but not limited to: 

• Physical safeguards, such as securing our premises and locking cabinets.
• Technological safeguards, such as encryption, access controls, password best practices, data loss prevention tools, and email security protocols;
• Organizational safeguards, such as annual privacy and data security training, and vendor management processes.

Your personal information may be stored and processed in any province in Canada and outside of Canada. 

Right to Access

You have the right to request access to the personal information we maintain about you, and to receive information about how we have collected, used and disclosed your personal information. You may also have the right in certain circumstances to request that we provide you or another person with a copy of the personal information that you have provided to us in a structured, commonly used technological format. These rights are subject to contractual and legal restrictions. To make any of these rights requests, please write to the Chief Privacy Officer as indicated below. The request should be as specific as possible and provide information that allows us to identify and contact you (full name, phone number, email address or home address). As a security precaution, we may need to take additional steps to validate your identity before sharing your personal information. 

By mail

Mackenzie Investments
Attn: Chief Privacy Officer
180 Queen Street West
Toronto, ON M5V 3K1
Canada

By email

privacy@mackenzieinvestments.com

Right to Rectify

You also have the right to correct and update any inaccurate or incomplete personal information we have on file. To correct or update your personal information, please contact your Advisor or our Client Relations department.

Call Client Relations

1-800-387-0614
Monday to Friday 8:30 a.m. to 6 p.m. (ET)

Write to us

Mackenzie Investments
180 Queen Street West
Toronto, ON
M5V 3K1 Canada

Fax us

1-866-766-6623

If you are unable to correct your personal information and you believe there could still be inaccurate or incomplete personal information, please submit a written request to the Chief Privacy Officer by email at privacy@mackenzieinvestments.com.

If you have any questions or concerns about the treatment of your personal information, please take the following steps:

Step 1. Your question or concern may be resolved by our Client Relations team:
1-800-387-0614
service@mackenzieinvestments.com
Monday to Friday 8 a.m. to 6 p.m.  (ET)

Step 2. If speaking with us does not resolve your question or concern, you may contact the Chief Privacy Officer as follows: 
E-Mail: privacy@mackenzieinvestments.com
Fax: 416-922-7062
Mail: Chief Privacy Officer, Mackenzie Investments, 180 Queen Street West, Toronto, ON, M5V 3K1

Step 3: If after contacting the Chief Privacy Officer your concern has not been resolved, you may contact the Office of the Privacy Commissioner of Canada or the Office of your provincial Privacy Commissioner if you are resident in Quebec, Alberta, or British Columbia as follows:

• Office of the Privacy Commissioner of Canada 
  www.priv.gc.ca
• Commission d’accès à l’information du Québec 
  www.cai.gouv.qc.ca
• Office of the Information and Privacy Commissioner of Alberta 
  www.oipc.ab.ca
• Office of the Information and Privacy Commissioner for British Columbia 
  www.oipc.bc.ca

If you make a complaint or report that requires an investigation, and have requested that the complaint be anonymous, we will endeavour to keep your identity confidential, to the extent permitted by law, consistent with the need to conduct an investigation.  We will inform you if it is not possible to maintain your anonymity for the purpose of conducting the investigation. 

We may amend our Privacy Notice from time to time to reflect changes to how we handle your personal information. If we do, the updated Privacy Notice and the effective date of the changes will be posted on our website. We may also notify you of any changes by posting a banner on our website advising that changes have been made to the Privacy Notice.