Privacy Policy
Last Updated: August 31, 2023
Commitment to Privacy
Dimensional Fund Advisors Canada ULC (“Dimensional Canada”) considers client privacy to be fundamental to our relationship with our clients. Since Dimensional Canada was founded, Dimensional Canada has been committed to maintaining the confidentiality, integrity, and security of its clients’ personal information entrusted to us. This Privacy Policy explains how Dimensional Canada and each fund managed by Dimensional Canada (each a “Dimensional Fund”) handles personal information about Dimensional Canada’s current and former clients, investors in a Dimensional Fund, financial advisors to investors in a Dimensional Fund, independent contractors engaged by Dimensional Canada, applicants for employment with Dimensional Canada, and other individuals. In this Privacy Policy, “Dimensional” means Dimensional Canada and each Dimensional Fund, as applicable.
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
By providing your personal information to Dimensional, directly or indirectly (including through intermediaries, such as your investment dealer or financial advisor), you signify your consent to Dimensional’s collection, use, disclosure and retention of your personal information in accordance with this Privacy Policy and as otherwise permitted by applicable law or regulation. Dimensional may also obtain your specific consent in certain circumstances to collect, use, disclose or retain your personal information for specific purposes.
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 obtain personal information about individuals from various sources, such as: (a) information provided in connection with account opening or associated client onboarding procedures; (b) direct communications in connection with a client’s or prospective client’s account; (c) indirect communications through intermediaries (e.g., investment dealers and financial advisors) and service providers; (d) information in connection with a job application; and (e) information collected through Dimensional’s website (including information collected through “cookies” and other technologies, as explained at Cookie Policy | Dimensional).
Dimensional may combine your personal information collected by or on behalf of Dimensional from various sources.
3. Use of Personal Information
Dimensional may use your personal information for various purposes in connection with its relationship with you and the operation of its business, including processing transactions with you or on your behalf, and as otherwise described in this Privacy Policy or permitted by applicable law or regulation, including:
- 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.
Dimensional may transfer your personal information to its service providers (including Dimensional’s affiliates) to assist Dimensional to operate its business and provide its services, and to assist Dimensional to use your personal information as described in this Privacy Policy and as otherwise permitted by applicable law or regulation. Dimensional’s service providers include third-party professional advisors, accountants, auditors, transfer agents, custodians, proxy solicitation firms, printers or mailers (including report distribution), recordkeepers, lawyers and legal service (including class action settlement service) providers, marketing, analytics and risk management service providers, human resources-related support (including recruiting services), data distribution service providers, transaction processing service providers and information technology service providers.
4. Disclosures of Personal Information
Dimensional does not sell personal information. Dimensional discloses your personal information to various persons and organizations for the purposes described in this Privacy Policy and as otherwise permitted by applicable law or regulation. Dimensional has no control over, or responsibility or liability for, the handling of your personal information by any of the persons and organizations to whom Dimensional discloses your personal information. The handling of the disclosed information by those persons and organizations is not subject to this Privacy Policy but is subject to the privacy policies of those persons and organizations.
(a) General
Dimensional discloses your personal information for purposes relating to or arising from your relationship with Dimensional, your use of Dimensional’s services, your investments and transactions, and as otherwise described in this Privacy Policy or permitted by applicable law or regulation.
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.
(b) Intermediaries
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
Dimensional may disclose your personal information as required or authorized by applicable law, regulation or competent authority or at the request of a competent regulator. Dimensional may also disclose your personal information to law enforcement agencies, regulators or other independent organizations if Dimensional reasonably believes the disclosure is necessary or appropriate in connection with national security, law or regulatory enforcement or other issues of public importance (including tax and regulatory compliance), or if Dimensional reasonably believes the disclosure is necessary or appropriate to protect and enforce Dimensional’s legal rights, interests and remedies or to protect the rights, interests, business, operations or clients of Dimensional, its affiliates or other persons (including to detect and prevent fraud and other illegal activities, to enforce any of the terms of use, terms of service or other agreements that govern access to or use of any of Dimensional’s services or for tax purposes of Dimensional or its affiliates).
(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
Dimensional retains your personal information for as long as is reasonably necessary for the purposes set out or referenced in this Privacy Policy, to comply with Dimensional’s legal obligations and to enforce or protect Dimensional’s legal rights and interests, or a longer period required or permitted by applicable law or regulation. Dimensional will then delete or destroy records of your personal information, or anonymize the information, in accordance with applicable law or regulation.
7. Protection of Personal Information
Dimensional uses reasonable safeguards appropriate to the sensitivity and amount of personal information under Dimensional’s legal control to help protect the personal information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and Dimensional cannot guarantee that your personal information will not be accessed, used, disclosed or deleted in ways not described in this Privacy Policy.
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.
Information about how you may manage or withdraw your consent to Dimensional’s use of website cookies to collect information is available at Cookie Policy | Dimensional.
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
You are responsible for ensuring that the personal information Dimensional may have obtained about you, whether directly from you or from a third-party intermediary (e.g., your financial advisor), is as accurate, complete and up to date as necessary for the purposes for which Dimensional uses the personal information. You must promptly notify Dimensional, directly or through the relevant third-party intermediary, of any changes to your personal information necessary for the purposes for which Dimensional uses the personal information as set out in this Privacy Policy.
Subject to applicable law and regulation, you may reasonably request access to your personal information under Dimensional’s legal control and information about Dimensional’s use, disclosure and retention of your personal information by submitting a written request to Dimensional’s Privacy Officer using the contact information in section 15 of this Privacy Policy. Subject to exceptions and limitations prescribed by applicable law or regulation, you will be given reasonable access to your personal information and you will be entitled to verify the accuracy and completeness of your personal information and have the information corrected as appropriate. You might be required to pay a reasonable fee for access to your 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
Websites operated by independent businesses might include links to our website. Dimensional has no responsibility or liability for, or control over, those independent businesses, their websites, products or services, or their handling of your personal information. This Privacy Policy does not apply to the handling of your personal information by independent businesses or through independent websites or online services. If you have questions about how those independent businesses or their websites or online services handle personal information, please contact the owner or operator of the independent businesses, websites and services.
12. Disclaimers, Liability Exclusions/Limitations and Disputes
Your agreements (including terms of service), if any, with Dimensional contain important provisions, including provisions disclaiming, limiting or excluding the liability of Dimensional and other persons and organizations and provisions determining the applicable law and jurisdiction for the resolution of disputes. To the extent permitted by applicable law, each of those provisions applies to any dispute that may arise in relation to this Privacy Policy or Dimensional’s collection, use, disclosure and retention of your personal information. Nothing in this Privacy Policy amends any of those other agreements.
13. Changes to this Privacy Policy
Dimensional may change this Privacy Policy from time to time. Dimensional will post each revised privacy policy on our website at www.dimensional.com/privacy-policy-ca, and will provide additional notice of changes to this Privacy Policy if required by applicable law or regulation. All changes to this Privacy Policy will be effective when Dimensional posts the revised privacy policy on our website, unless the revised privacy policy states otherwise. Dimensional’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time.
14. Consent to Email Notices
You consent to Dimensional sending you emails (to the email addresses you provide to Dimensional) regarding this Privacy Policy and related matters and as otherwise permitted by applicable law or regulation.
15. Contacting Dimensional
If you have any questions about this Privacy Policy or how Dimensional handles your personal information, or if you wish to withdraw your consent to Dimensional’s handling of your personal information, please contact Dimensional’s Privacy Officer by email at [email protected] or by postal mail to: Privacy Officer c/o Legal, Dimensional Fund Advisors Canada ULC, 745 Thurlow Street, Suite 2110, Vancouver, British Columbia, Canada, V6E 0C5.