Fidelity Canada privacy policy

We limit the collection of personal information to what is reasonably required to fulfil the purposes for which it was collected.

We may collect the following personal information about you depending on the services you request or your interactions with Fidelity (e.g., if you are an investor, advisor, investment professional, website visitor or mobile app user):

• Identifiers and contact information, including your full name, email address, phone number, mailing address, account number and language preference;
• Background information, including your date of birth, gender, banking and investment information, and government issued ID, such as social insurance numbers (SIN). If you are an advisor, we may also collect information about your designations (CPA, CFA, MBA, etc.), hobbies, recreational interests, dietary information and health information (disabilities), information about your employer/dealer and subjective information, such as comments, opinions and remarks; 
• Information used to identify you, such as your email address and/or phone number (for the purpose of sending you a code to authenticate your identity so that you can log into password protected areas of Fidelity Sites), answers to security questions and, if you choose to enroll in our voice biometrics program, your voiceprint (i.e., various characteristics unique to your voice);
• Records that reflect our interactions with you, such as when you call us through our call centers (e.g. complaints, errors and problems), when you contact us online or in-person, or when you use your accounts with us or conduct transactions;
• Information automatically collected when you visit Fidelity Sites or interact with electronic communications from us, including device identifiers, IP addresses, location information, browser information, network connection information (e.g., Wi-Fi, Bluetooth, near field communication), Internet search provider information, advertising identifiers, website or mobile app usage information (including content visited and average time spent on our websites or mobile apps), as well as email or text message click-throughs; and 
• Any other information you provide to us, such as when you contact us for customer support, create an account or otherwise interact with us online or in-person.

We may collect this information in several ways, including:

• Directly from you: We may collect identifiers and contact information, background information, and other personal information you provide when you interact with us, such as when you fill out paper, online or digital forms or applications, enrol in our programs, or otherwise communicate with us. This may also include recordings or live monitoring of telephone or online discussions with our representatives, which we use for our mutual protection, to enhance customer service, for training purposes, and to confirm our discussions with you, in accordance with applicable law. It may also be used to better provide you with more relevant information, offers, products and services.
• From advisors or investment professionals: If you are working with an advisor or investment professional, we may collect personal information from them that is necessary to provide you with our services. This may include background information, financial information, and other personal information related to your investment profile. For example, we may collect information about your investment goals, risk tolerance, and other information that is relevant to your investment portfolio.
• Through cookies and similar technologies: We may collect information automatically when you visit a Fidelity Site, or interact with electronic communications from us, including email, text message or digital advertising. This is done through the use of cookies, tracking pixels, Flash objects, web beacons, embedded scripts, and other similar technologies. This information may be used, for example, to alert you to software compatibility issues, to measure the performance of our ads and other online content, to improve our web design and functionality, or to provide you with personalized products and service offerings on third party websites, social media platforms or Fidelity digital platforms. More details can be found in the “Cookies and Similar Technologies” section.
• From advertising partners: We may receive information about you from the digital advertising companies with whom we work (see Targeting or Advertising section below) to help us deliver ads that may interest you across different browsers and devices. This may include pseudonymous advertiser identifiers that digital advertising companies share with us. We may work with our digital advertising company partners to match their identifiers to our own, to enhance data points about a unique browser or device. We may also receive information about you from experience-based partners holding virtual or in-person events that we may sponsor or have a partnership with, when consent is given by you to participate in the event(s) or consume content in connection with the event(s).
• From other sources: We may collect personal information that you provide about your family members and other individuals, such as your legal representative or joint account holder. You are responsible for obtaining consent from these individuals and informing them that their information will be provided to Fidelity. By providing such information to Fidelity, you represent that you have obtained such consent in a manner that is satisfactory to Fidelity. 

No matter how we collect your personal information, we try to ensure its accuracy and completeness to the extent required for our use of the information. In order to maintain the accuracy of your information, please make sure we know about any changes as soon as possible.

We collect information to better serve you. We may use your personal information for the following purposes or otherwise, with your consent or as permitted or required by law:

General Business Purposes

If you are an investor, we collect your name, contact information, Social Insurance Number, banking information and other information necessary to provide you with portfolio management services, to comply with our legal and regulatory obligations and to manage our business operations. This includes complying with our contractual, legal and regulatory obligations, including record keeping and tax reporting obligations, preventing error and fraud, providing you reports, making payments to you by way of electronic funds transfer and responding to inquiries from you or your advisor or investment professional, if you have one.

If you are a member of the general public or are an investor with us, you may subscribe to receive educational and marketing materials from Fidelity, as well as targeted advertising. Fidelity will collect and use your name, contact information and consent for these purposes, and this information and consent may be collected online or over the phone by calling Fidelity

If you are an advisor who uses the section of the fidelity.ca website restricted to advisors, we collect your name, as well as information on the types of tools, products and services that may interest you based on your use of our website, so as to ensure that we can keep you informed of other such products and services, and to support your use of our online tools, products and services

In addition, we will use your personal information to identify you for the purpose of logging into password protected areas of Fidelity Sites. For example, when you provide us with your email and/or phone number, we may use them to send you a code for the purposes of authenticating your identity.

If you call Fidelity and consent to enrolling in Fidelity’s voice biometrics program, we will collect and store a sample of your voice to create your voiceprint (i.e., various characteristics unique to your voice) to allow you to authenticate your identity on future calls without having to respond to a series of security questions. The voiceprint will be used to verify your identity when you call us and try to access your accounts or information. We will only use your voiceprint for the purpose of validating your identity on calls. You may withdraw your consent and unenroll from the program at any time by contacting us as indicated below, in which case you will still be able to verify your identity on calls by responding to security questions.

Research and Data Analytics Purposes

We may use personal information to understand and assess the preferences and interests of our clients to improve our products and services and develop new ones, and to evaluate potential improvements or other modifications to the functionality of the Fidelity Sites, and to our product and service offerings. When required by law, we will use aggregated or anonymized information for these purposes.

Examples of research and data analytics include:

• Measuring the performance of our ads and other content on the Fidelity Sites and on third-party websites or platforms.
• Using third-party web analytics services to analyze how users interact with the Fidelity Sites to improve their display, appearance or functionality.
• Segmenting, classifying and personalizing messaging in connection with predictive marketing tactics.

Marketing and Promotional Purposes

We may use your personal information to communicate with you in a variety of ways (for example, by email, telephone, text message, Fidelity digital properties (including Fidelity Sites), digital advertising, direct mail or through our online customer support services) about our programs, products, services, offers, promotions, contests or events that may be of interest to you. You may unsubscribe from receiving these communications from us at any time, by following the unsubscribe procedure included in each of these communications or by contacting us. For more information on this topic, see the “What privacy rights and choices do you have?” section.

We may also use your personal information, including information collected through cookies and similar technologies, to provide you with personalized content and services, including information and offers that may be of interest to you. We have included additional information about tracking technologies below (see Targeting or Advertising below), and we have provided you with “opt-out” options.

We may share your personal information with the following third parties:

Affiliates and Related Entities

We may share your personal information with other Fidelity companies, including our parent company, subsidiaries and affiliates, for the purposes described in this Policy. This may include managing operational risks, coordinating the provision of shared IT or other business resources, platforms or infrastructure, marketing our products or services to you, providing you with the products and services you request, having visibility and the ability to service you across lines of businesses, and complying with legal and regulatory requirements.

We may combine the personal information we collect across business lines with other demographic information about you, your investment profile, and your online and offline interactions with Fidelity, to create an integrated profile of you so that we may keep you informed of products and services that may be of specific interest to you.

We may share your personal information with third-party service providers to perform services on our behalf. These service providers may include financial institutions, accounting, law and other professional service firms, technology companies (which includes information technology services and software companies), mailing, courier, imaging, document storage, marketing and advertising firms and platforms (see below) and other vendors. We may share your personal information with these service providers for the purposes described in this Policy, including:

• security and fraud prevention.
• setting up and maintaining client accounts and trades.
• preparing and mailing client statements and other relevant documents.
• processing payments and facilitating electronic payment/collection of monies.
• document delivery, storage, including cloud storage and hard copy storage of documents.
• satisfying regulatory obligations, including identity verification, screening, filing, reporting and legal and regulatory analysis.
• research and data analytics.
• understanding the client to provide better products and services, including marketing and promoting products and services as follows: 
  We may use your personal information within digital marketing platforms licensed by Fidelity and its partners to help us market our products to you or provide you with services, such as email, text, website, app, customer relationship management, customer data platforms, demand side platforms, and other software suites. We may also share your personal information with service providers who help us market and promote our products or services to you. For example, we may work with a digital advertising agency to provide you with relevant online ads or with a direct mail service to send you marketing communications.

When we share your personal information with service providers, we take steps to ensure that your information is protected. We use contractual means to provide the information with an appropriate level of protection, and we require our service providers to use your personal information only for the purpose for which it was shared and to handle it in accordance with applicable laws.

Advisors or Investment Professionals

If you are an investor with an advisor or investment professional, we may share your personal information with your advisor or investment professional for the purpose of providing services to you, fulfilling your requests, or as otherwise described in this Policy. We will only share information with that advisor or investor professional that is relevant to your relationship and will not share information collected from Fidelity or other Fidelity business lines outside the context of that relationship, without your consent.

Governmental and Regulatory Authorities and Self-Regulatory Organizations

We may disclose your personal information to governmental and regulatory authorities and self-regulatory organizations, including the Canadian Investment Regulatory Organization and provincial securities commissions, as required or permitted by law, such as to comply with legal and regulatory obligations (such as tax reporting) or in response to a search warrant, court order or other valid request. Please note that when the information is disclosed to these entities, they may in turn disclose it to other governmental and regulatory authorities in accordance with their own policies and practices and applicable laws.

Other Third Parties

Fidelity may also share your personal information with certain government entities or other third parties as permitted or required by law, such as where there is reasonable cause to believe your personal information has been compromised and reporting to such an entity may reduce or mitigate the risk of significant harm to you. We may also share your personal information when necessary for a business transaction, including the sale or transfer of all or part of our business to a third party, in accordance with applicable law.

We have always considered the protection of personal information to be a foundation of customer trust and a sound business practice. We employ extensive physical, electronic and procedural controls, and we regularly review these controls to determine whether they need to be adapted to respond to changing requirements and advances in technology. Within Fidelity and among our service providers, we aim to restrict access to personal information to those who need it to provide products and services to you.

We implement a combination of security measures to protect your personal information, including:

• Internal policies and procedures that govern the protection of personal information throughout its life cycle. These include policies and procedures that define the roles and responsibilities of our personnel when handling personal information, establish a process for handling complaints about the protection and processing of personal information, and govern the retention and destruction of such information;
• Physical, technical and organizational measures to limit access to personal information on a “need-to-know” basis and protect against loss or unauthorized access, use or disclosure of personal information, including firewall barriers, encryption techniques and authentication procedures;
• Employee privacy training courses;
• Designation of a Privacy Officer to oversee compliance with applicable privacy laws.

The transmission or storage of information via electronic means can be compromised or exposed to unauthorized parties. While Fidelity has taken steps to protect your information, we encourage you to take precautions to ensure your information is kept secure and only transferred to us via secure means.

We retain your personal information for as long as necessary to provide our services to you, to manage our business operations, to comply with our legal and regulatory obligations, to fulfill the purposes described in this Policy or as otherwise required or permitted by law. When your information is no longer needed, we will securely destroy or anonymize it (so that the information can no longer be used to identify you) in accordance with applicable law.

At times, we may use other Fidelity companies located outside of Canada, including in the European Union, the United Kingdom, and the United States, to perform data storage and processing services for us, and may use third-party service providers located outside of Canada. This may involve the transfer of your personal information to these entities. In such cases, the information may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. In all cases, we require that our service providers protect your information and only use it for the limited purpose of providing their services to us.

Cookies are small amounts of data that a website sends to a web browser on a visitor’s computer. We use cookies and similar technologies to support the operation of Fidelity Sites, as well as to promote products and services that may be of interest to you.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Fidelity Site, or if you delete cookies, you may experience some inconvenience in your use of Fidelity Sites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device or your online preferences.

Website cookies

Our cookies help us to collect information about visitors to Fidelity Sites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Fidelity cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

These cookies are collected via Google Analytics, which is a web analytics service provided by Google Inc. that provides statistics about visitors to our Fidelity Sites.

Email cookies

Fidelity also uses cookies and similar technologies in the emails that we send. We will gather information such as your IP address and geographical location, as well as whether you open the email, which links you click on within the email and any Fidelity Sites you subsequently visit. We will have the ability to link any activity on Fidelity webpages and emails we send to your email address. This is done by matching your IP address, as opposed to storing any personal information about you. Please note this does not track any activity on non-Fidelity pages. You can remove these cookies from your device at any time by clearing your cookies and cache.

Third Party Functionalities

Our Fidelity Sites will from time-to-time use YouTube’s API services in connection with embedding video thumbnail images and descriptions provided by YouTube LLC (“YouTube”). As such, you acknowledge and agree that by accessing the videos linked through the embedded video thumbnail images and descriptions, you are also bound by YouTube’s Terms of Service and Google’s Privacy Policy. Using YouTube’s offering requires a connection to be established to YouTube’s servers. During this process, certain information is transmitted to YouTube. We do not control the collection, storage or use of any of your information by YouTube and do not have access to any information collected. You should review Google’s and YouTube’s Privacy Policies carefully before you use any YouTube features. Further information about how your data is collected and used by YouTube and your rights in relation to this can be found in YouTube's privacy policy at www.youtube.com.

We participate in various forms of targeted advertising (interest-based advertising) and use third-party analytics and advertising companies to provide you with targeted advertising and offers. Specifically, we permit third-party online advertising networks and services, social media companies and other third-party services, to collect information about your use of Fidelity Sites over time so that they may display advertisements on Fidelity Sites, or on other websites, applications or services that you may use, and other devices that you may use.

Typically, targeting or advertising cookies will be used to deliver advertisements relevant to you. They are also used to limit the number of times you see an advertisement, as well as to help measure the effectiveness of the advertising campaign. Such cookies or tracking technologies may recognize the device you are using and collect click stream information, browser type, time and date or your visit to Fidelity Sites or elsewhere online, and similar information. Targeting cookies are used to

•  understand what Fidelity advertisements you might be interested in on our site

•  understand what Fidelity advertisements you might be interested in on other sites

As part of this, we use several third-party services to help us understand what advertisements you might be interested in. These cookies hold information about your computer, and they might hold a record of what other websites you've looked at, so that we can show you promotions while visiting other websites.

We may also use advertising cookies to link to social media networks such as Facebook,  LinkedIn, Instagram, Twitter and other widgets. They will use any information about your visit to Fidelity Sites to recognize you, set a cookie or employ other tracking technologies, then deliver targeted advertising to you. 

You can opt-out of these cookies at any time by checking your settings with the relevant social media platform or within your browser. Your interactions with these features are governed by the privacy policies of those companies. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences; for example:

• Facebook advertising preferences
• LinkedIn advertising preferences
• Instagram advertising preferences
• Twitter advertising preferences

We may also share certain anonymized information with our third-party advertising partners (such as a hashed email address or other anonymized and encrypted “remarketing” lists) to help identify you across sites and across devices and to show you relevant ads, generate similar audiences and to show dynamic ads. As noted above, for social media companies, you can adjust your advertising preferences within the social platforms themselves. The social media companies that interact with our site, and all of the other third-party advertising services that we use, are detailed in the chart that is available at the end of this Policy. We endeavour to keep this chart up to date but may remove or add service providers from time to time. Please contact us if you have any questions about our current services.

We, and our third-party service providers, use cross-device linkage so that the content that you view on one device can result in you receiving relevant advertising on another device, and also to allow us to perform analytics on our products and services and assess the effectiveness of our advertising. We do this by collecting information about each device you use when you visit Fidelity Sites. We may also work with third-party partners who employ tracking technologies, or the application of statistical modelling tools, to determine if two or more devices are linked to a single user and/or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices.

Fidelity has engaged the following service providers, who may use advertising or targeting cookies; you can opt-out of vendor-specific cookies by clicking on the relevant links below:

You may request access to your personal information and request that it be corrected if it is inaccurate, incomplete or not up-to-date. In some cases, you may also request that we delete your information if its collection, disclosure or retention is not authorized by applicable law. We will respond to your request within 30 days of receiving it, in accordance with applicable law. You can exercise these rights by contacting us as described in the “How to contact us about privacy?” section.

You may withdraw your consent for us to use your personal information for secondary marketing purposes, either by using the unsubscribe option that we provide in electronic communications, or by contacting us at any time to request that we do not use your personal information for this purpose.

We use cookies and similar technologies to manage and improve Fidelity Sites and personalize your experience, to serve targeted advertisements, and to measure the performance of our ads and other online content. You may delete or disable some of these technologies at any time via your browseror by clicking here. However, if you do so, you may not be able to use some of the features of Fidelity Sites. You can learn more about these practices and related privacy choices in the “Cookies and Similar Technologies” and “Targeting or Advertising Through Interest Based Advertising” sections.

You may also withdraw all or part of your consent for us to use or disclose your personal information, subject to certain legal or contractual restrictions. For example, we may be required or permitted by law to retain your personal information to comply with our legal or regulatory obligations, to establish, exercise or defend our legal rights or interests, or to protect you and others against fraud and other harmful activities. We may also need your personal information to provide you with the products or services you request. If you withdraw consent in these cases, we may be limited in the services or products that we provide to you. Please contact us to learn more.

Protect your data: Be aware of look-alike websites and other scams. If you suspect that a website or email claiming to be from Fidelity is fraudulent, please report it to cyber.defence.canada@fidelity.ca.

We may make changes to this Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on the Fidelity Sites or contact you to inform you when required by law. If we make any material changes to the Policy, we will update the Last Updated date on this Policy. We encourage you to look for updates and changes to this Policy when you access the Fidelity Sites. By continuing to interact with us after the modified version of the Policy has been posted, you are accepting the changes to the Policy, subject to any additional requirements that may apply. It is your responsibility to ensure that you read, understand and accept the latest version of the Policy.

We welcome your privacy questions.

Email: FICCustService@fidelity.ca
Telephone: 1 800 263-4077

If you are not satisfied with the results of your email or phone call, contact

Chief Privacy Officer
privacy@fidelity.ca

Telephone: 1 800 263-4077
Fax: (416) 307-5349

or by mail at:

Attention Chief Privacy Officer
Fidelity Investments
483 Bay Street, Suite 300
Toronto, ON
M5G 2N7