1. Purpose and Scope

At Institutional Shareholder Services Canada Inc., we respect your privacy. Our privacy policy (“Privacy Policy”) summarizes what personal information we collect, and how we use and disclose this information. This Privacy Policy also describes other important topics relating to your privacy.

By using the Institutional Shareholder Services Canada website at https://investoreconomics.com/ (the “Site”), or by choosing to submit personal information to Institutional Shareholder Services Canada Inc., you signify your consent to all of the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use this Site or submit any personal information to Institutional Shareholder Services Canada.

Institutional Shareholder Services Canada reserves the right to modify this Privacy Policy at any time. We will reflect any such modifications to this Privacy Policy on our Site and will indicate the date this Privacy Policy was last amended. Your continued access to and/or use of the Site, or provision of personal information to us after any such changes, constitutes your acceptance of, and agreement to this Privacy Policy, as revised. Please periodically review this Privacy Policy so that you know what personal information we collect, how we use it, and with whom we may share it.

2. What Personal Information Institutional Shareholder Services Canada Collects

Personal information is information about an identifiable individual, such as a name, address, telephone number, email address or payment information (“Personal Information”). We collect Personal Information when you voluntarily provide it through our Site, or when you provide it to us through other means. Participation in survey research is always voluntary. When you agree to participate in a survey, you give consent to the interview by participating. For example, we may collect Personal Information when you:

Provide us with information on or through our Site;

  • Complete one of our surveys for the purposes of quantitative or qualitative marketing and social research;
  • Contact us through e-mail, telephone, mail, or other correspondence; or
  • Otherwise provide us with Personal Information.

We also receive Personal Information when it is provided to us by one of our clients. In such cases, the client must ensure they have secured the informed consent of the individual to the uses and disclosures of the Personal Information they ask us to make.

  • The Personal Information we may collect will be limited to that which is necessary for the purposes identified and may include:
  • First and last name, and contact information, such as address, telephone number, or e-mail address;
  • Non-identifying information regarding financial matters including product preferences and decision-making and demographic information including age, gender and location;

Any other Personal Information that you voluntarily submit to us or that we are provided with by one of our clients.

3. Cookies and How Institutional Shareholder Services Canada Collects Information Through Technological Means

When you visit our Site, we may collect information that is automatically sent to us by your web browser or your internet service provider. This information may include your domain name and your numerical IP address. We may also collect other general information (such as the type of browser you use, which pages you view, and the files you request). We use this information to better understand how visitors use our Site, and to improve our Site to better meet your needs. The amount of information that is sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this.

To enhance your experience on our Site, we may use a feature on your Internet browser called a “cookie” and/or other similar devices. Cookies are small files that your web browser places on your computer’s hard drive. They are used for a variety of reasons, such as tracking click streams, and for load balancing. Information obtained through these mechanisms may include, but is not limited to: (i) your IP address; (ii) the type of web browser and operating system being used; and (iii) the pages of the Site a user visits. By using cookies, we can deliver faster responses, and a better experience on our Site. Your browser gives you the option to reject cookies. However, setting your browser to reject cookies generally hinders the browser’s performance and will adversely affect your experience while using our Site.

4. How Institutional Shareholder Services Canada Uses and Discloses Personal Information

The Personal Information we collect may be used by Institutional Shareholder Services Canada for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and to which you consent. For example, we may use your Personal Information to:

  • Operate our Site in accordance with its terms and conditions;
  • Respond to your questions or inquiries;
  • To conduct market research and surveys;
  • To improve our products, services and Site;
  • To send you informational or promotional communications that you have agreed to receive;
  • To carry out other purposes that are disclosed to you and to which you consent;

To carry out any other purpose permitted or required by law, such as meeting legal and regulatory requirements.

If you have provided us with your Personal Information, but later decide you no longer want us to send you any information from us, you may unsubscribe by using the unsubscribe message in our commercial communications.

We may transfer your Personal Information to third party service providers that assist us with carrying out these purposes. For example, we may use a data processing contractor to operate computer systems on our behalf or to process payments for us. When Personal Information is transferred to a such a third party service provider, that party will be contractually bound to use such Personal Information only to carry out the services we have requested, and to provide adequate protection for the Personal Information.

We reserve the right to transfer any Personal Information we have about you in the event that we merge with or are acquired by a third party or should any such transaction be proposed. We may also use, or disclose your Personal Information to third parties, if we have reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; or (iv) to protect our rights, safety or property. Lastly, we may disclose your Personal Information for any other purpose to which you Consent.

Personal Information collected online may also be combined with information you have provided to Institutional Shareholder Services Canada through other sources such as over the telephone or in a survey.

Note, we may provide our clients or other third parties with information from any survey, in aggregate anonymized form. Institutional Shareholder Services Canada may use or disclose aggregated, anonymous information for any purpose. In some cases you may voluntarily choose to include your name with your survey response in which case your information would no longer be anonymized.

5. How we Protect Personal Information

The security of your Personal Information is important to us. We protect your Personal Information by maintaining physical, organizational and technological safeguards intended to help protect against unauthorized use, disclosure or access. Personal Information may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law. Personal Information we collect is managed from our offices located at Toronto, Canada.

Although we have taken measures to help protect our Site, computer systems and any Personal Information that we have collected from unauthorized use, access, disclosure, misuse, alteration or destruction, no security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

6. Access and Rectification

You have a right to request access to your Personal Information and to request a correction to it if you believe it is inaccurate. If you have submitted Personal Information to Institutional Shareholder Services Canada and would like to have access to it, or if you would like to have it removed or corrected, please contact us using the contact information provided below. We will use reasonable efforts to comply with your request; however, in some cases we may not be able to allow you to access certain Personal Information in certain circumstances, for example if it contains Personal Information of other persons, or for legal reasons. In such cases, we will provide you with a reasonable explanation of why it is not possible to grant access to your Personal Information.

7. Children and Parents

Institutional Shareholder Services Canada does not knowingly collect Personal Information from children. If a child has already provided us with Personal Information, his or her parent or guardian may contact us for the purpose of deleting this information.

8. Third Party Websites

The Site may contain links to other third party websites. These other websites may have their own privacy policies and terms and conditions that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any website(s) owned and operated by any such third parties. Other websites may collect and treat information collected differently, so we encourage you to carefully read and review the privacy policy for each website you visit. Any links from this Site to other websites, or references to products, services or publications other than those of Institutional Shareholder Services Canada, do not imply the endorsement or approval of such websites, products, services or publications by Institutional Shareholder Services Canada.

9. How to Contact Us

If you have any questions regarding this Privacy Policy, any Personal Information you have submitted to us, or if you would like to:

  • access Personal Information that you have already provided to us so that you can correct or update it, or request that it be deleted;
  • request the deletion of Personal Information regarding your minor child; or
  • report any violation of this Privacy Policy;

Please advise us by contacting our Privacy Officer by emailing Brooks.Herman@strategic-i.com.