Last Updated: August 31, 2023
Commitment to Privacy
Key Terms of this Policy:
- Your consent
- What personal information does Dimensional collect and how do we collect it?
- How does Dimensional use your personal information?
- Why does Dimensional disclose your personal information?
- How do you change your privacy choices?
1. Your Consent
In addition, where permitted by applicable law or regulation, Dimensional may collect, use, disclose and retain your personal information without your consent.
2. Personal Information Collected
In this policy, “personal information” means information about an identifiable individual (a natural person) but does not include (to the extent permitted by applicable law or regulation) information that is publicly available that enables an individual to be contacted at a place of business, and other kinds of information that are not subject to regulation by Canadian personal information protection or privacy laws.
Dimensional collects personal information about individuals in the course of carrying on Dimensional’s business. For example, Dimensional may collect (directly or indirectly) as applicable for any individual:
- information that an individual provides directly to Dimensional or to the individual’s investment dealer, financial advisor or other intermediary in connection with the individual’s investment or potential investment in a Dimensional Fund, such as that person’s name, address, telephone number, email address, social insurance number or taxpayer identification number, income, financial information (e.g., assets and liabilities), and identification documents;
- information that Dimensional obtains in the course of handling transactions for a client or investor in a Dimensional Fund or other Dimensional products and services, such as account balance information, investment activity, transaction information and securities held on behalf of the client or investor;
- information Dimensional is legally obligated to generate or collect, such as information for legal compliance or record-keeping obligations;
- the fact that an individual is or has been a client of Dimensional or an investor in a Dimensional Fund, or has used or received services provided by Dimensional;
- information collected through Dimensional’s website; and
- information provided by an individual applying for employment with Dimensional, including contact information and education and employment history.
Dimensional may combine your personal information collected by or on behalf of Dimensional from various sources.
3. Use of Personal Information
- to assess your investment account application or associated onboarding materials;
- to manage and track your investments and process your transactions;
- to provide your account statements or related information;
- to comply with and assess compliance with applicable laws, rules and regulations, and Dimensional’s policies and procedures (including tax or other business reporting purposes);
- to contact and correspond with you regarding your account or related transactions and your use of our services and to provide you with client care services;
- to process and respond to your inquiries, requests and other communications (including to process your job application);
- to provide you with information (including by email and other electronic messages) regarding Dimensional and its business that might be of interest to you;
- to maintain, protect, analyze and improve our business and services, and to develop new services;
- to develop, deliver and improve Dimensional’s advertising and marketing; and
- to protect and enforce Dimensional’s (and its affiliates) legal rights, interests and remedies and to protect the business, operations and clients of Dimensional, its affiliates or other persons.
4. Disclosures of Personal Information
Dimensional may also disclose your personal information in accordance with additional consents (express or implied) that you give during your interactions and transactions with Dimensional or other third parties.
Dimensional may disclose your personal information to your investment dealer, financial advisor or other authorized intermediary in order to service a client account, process transactions, or as otherwise required or permitted by law or regulation.
(c) Investments and Transactions
Dimensional may disclose your personal information to: (i) organizations (including Dimensional’s affiliates) that manage, administer or otherwise operate investment funds and other investment products in which you invest or transact through your Dimensional account or an account with a third party; and (ii) issuers of securities in which you invest or transact through your Dimensional account; in each case in connection with the investments and transactions and as otherwise required or permitted by law or regulation.
(d) Law Enforcement/Legal Disclosures
(e) Business Transactions
Dimensional may disclose your personal information in connection with a prospective or completed business transaction (e.g., a merger or acquisition or the sale or transfer of some or all of Dimensional’s business or assets) to which Dimensional is a party, but Dimensional will require the information recipient to agree to use, disclose and retain the disclosed personal information in accordance with applicable law or regulation.
5. Location of Personal Information
Dimensional and its service providers may use, process and store your personal information at facilities in Canada, the United States, Australia, Germany, Hong Kong, Ireland, Japan, the Netherlands, Singapore, and the United Kingdom. The personal information protection laws or regulations of those other countries might be different from the laws or regulations of the jurisdiction in which you reside, and might permit the government, government agencies, courts, law enforcement agencies and security authorities in those countries to access your personal information without notice. By providing your personal information to Dimensional, you consent to the transfer of your personal information to facilities located in other countries and the use, processing and storage of your personal information at those facilities.
6. Retention of Personal Information
7. Protection of Personal Information
Dimensional maintains policies and practices to protect your personal information, including:
- a designated Chief Privacy Officer to monitor Dimensional’s compliance with applicable privacy laws or regulations;
- internal policies and procedures that define the roles and responsibilities of Dimensional’s personnel throughout the information life cycle;
- technological safeguards (e.g., encryption, firewalls, user authentication, endpoint detection and response software and similar measures) to help protect personal information collected or stored by Dimensional in electronic format;
- privacy and data security training for Dimensional’s employees;
- procedures for receiving, investigating and responding to complaints or inquiries regarding Dimensional’s information handling practices; and
- policies governing the retention and destruction of personal information.
8. Your Right to Withdraw Consent
You may withdraw your consent to Dimensional’s collection, use, disclosure and retention of your personal information at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to purposes that are integral to the provision of our services, then you might not be able to proceed with your intended interactions or transactions with Dimensional or otherwise receive the full benefit of our services. If you withdraw your consent to purposes that are not integral to the provision of our services, then withdrawing your consent for those purposes will not affect our provision of services to you.
You can choose to not receive electronic marketing or promotional emails from Dimensional by clicking on “unsubscribe” in an electronic marketing or promotional email you receive from us. It may take up to ten (10) business days to register a change to your communication preferences. Please note that even if you have indicated your choice not to receive electronic marketing or promotional emails from us, we may still communicate with you by email regarding your account with us and your use of our services and as otherwise permitted by applicable law or regulation.
9. Accuracy and Access to Personal Information
Depending on the jurisdiction where you reside, you may also be entitled to request the rectification of your personal information under Dimensional’s legal control if our collection, disclosure or retention of the information is not authorized by law.
10. Non-Personal Information
Dimensional may use your personal information to create and collect aggregated or anonymized data, so that the information no longer relates to an identifiable individual. Dimensional may use, disclose, transfer and retain non-personal information in accordance with applicable law or regulation.
11. Other Websites and Businesses
12. Disclaimers, Liability Exclusions/Limitations and Disputes
14. Consent to Email Notices
15. Contacting Dimensional