Definitions you need to know.
"We, our and us" mean, as applicable, any Sprott Inc. group member or the collective Sprott Group.
"Sprott Group" means, collectively, Sprott Inc. and all of its affiliates and subsidiaries including, but not limited to, Sprott Asset Management LP, Sprott Capital Partners LP, Sprott U.S. Holdings Inc., Sprott Resource Lending Corp. and Sprott Resource Streaming and Royalty Corp., as well as any formal partnership program or joint venture any of these parties participates in.
"Service" means any brokerage or financial product or service offered by us.
"You and your" means each person, whether an individual, corporation or trust, who has made an application to us for or signed an application in respect of any Service offered by us, including any co-applicants, guarantors or personal or corporate representatives such as directors.
"SROs" refers to self-regulatory organizations, including the Investment Industry Regulatory Organization of Canada (IIROC), the Mutual Fund Dealers Association of Canada, the exchanges and other regulated marketplaces and the Canadian Investor Protection Fund.
"Data Protection Legislation" means all applicable data protection and data privacy legislation including the Personal Information Protection and Electronic Documents Act (Canada) and, where relevant, the General Data Protection Regulation EU 2016/679, the UK Data Protection Act 1998 and all equivalent, associated and similar legislation which applies to us from time to time.
What personal information do we collect?
The term “personal information” refers to any information about you (or other identifiable people) including information that may specifically identify you or them. We collect personal information that you provide to us (or that your financial advisor or dealer provides to us on your behalf), which may include the following:
- Your full name, address, occupation and date of birth, as required by law;
- Identification, such as a valid driver's license or passport;
- Your social or national insurance number for ID or income tax reporting purposes, as required by law;
- Your financial information including annual income, assets and liabilities, and banking information;
- Your employment history and credit history;
- Information about third parties such as your spouse if you are applying for certain Services, where this information is required by law or necessary for us to perform a contract with you.
For legal entities such as businesses, partnerships, trusts, estates or investment clubs, we may collect the information referred to above from each authorized person, partner, trustee, executor and club member, as appropriate. Each member of the Sprott Group may be a controller of personal information that we collect and each will comply with this policy.
How do we collect your information?
We collect your personal or business information directly from you or through your financial advisor or dealer in order to provide you with Services and perform contracts with you, to meet legal and regulatory requirements and to comply with our legal obligations, for the purpose of our own legitimate business interests (where these are not overridden by your rights and freedoms) such as to keep in contact with you, and for any other purposes to which you consent. Your information may be collected from a variety of sources, including:
- Applications, questionnaires or other forms that you (or your financial advisor or dealer) submit to us or contracts that you enter into with us;
- Your transactions with us;
- Meetings and telephone conversations with you;
- Credit reference checks, identity checks and money laundering checks; and
- Our websites.
We may also monitor or record any telephone call we have with you. The content of the call may also be retained (and these recordings will be stored for a fixed period of time in accordance with our own internal policies and Data Protection Legislation). We may inform you prior to proceeding with the call of this possibility. This is to establish a record of the information you provide, to ensure that your instructions are followed properly and to ensure customer service levels are maintained.
How do we use your information?
We collect and use your personal or business information in order to give you the best possible service and for the purposes set out in your agreement(s) with us, such as:
- To establish your identity and verify the accuracy of your information;
- To confirm your corporate status;
- To understand your needs;
- To determine the suitability of our Services for you;
- To determine your eligibility for our Services;
- To set up, administer and offer Services that meet your needs, including fulfilling any reporting or audit requirements;
- To provide you with ongoing Service, including executing your transactions;
- To provide you and your financial advisor or dealer with confirmations, tax receipts, proxy mailings, financial statements and other reports;
- To meet our legal and regulatory requirements;
- To manage and assess our risks; and
- To protect us from error and to prevent or detect fraud or criminal activity.
We collect, use and disclose your social or national insurance number, social security number or other government-issued personal or business identification number for ID verification purposes and for income tax reporting purposes, as required by law. In addition, we may ask you for your SIN to confirm your identity. This allows us to keep your personal information separate from that of other customers, particularly those with similar names, and helps maintain the integrity and accuracy of your personal information. You may refuse to consent to its use or disclosure for purposes other than as required by law.
We will store your personal information for no longer than it is needed and our retention of the information will be in accordance with our internal policies and the Data Protection Legislation.
How do we obtain your consent (where needed)?
Who do we share your information with?
We may share your personal or business information within the Sprott Group for the purposes set out above. We do not provide directly all the services related to your relationship with us. We may use third party service providers or agents such as:
- Your financial advisor or dealer;
- Other financial service providers such as investment dealers, custodians, banks and others used to finance or facilitate transactions or operations on your behalf;
- Transfer agents, portfolio managers, brokerage firms and similar service providers; and
- Other service providers such as accounting, legal or tax preparation services and credit reference or identity check providers.
Our service providers and our agents process or handle your information on our behalf and assist us with various services such as printing, imaging, document storage and shredding, mail distribution and marketing. Some of these third parties may be located outside of Canada. As a result, your information may be accessible to regulatory authorities in accordance with the laws of these jurisdictions, including the United States of America and the United Kingdom. When information is provided to our service providers and to our agents, we will require them to protect the information in a manner that is consistent with Sprott Group privacy policies and practices and which accords with the Data Protection Legislation (which may involve the use of contracts containing the EC approved "model clauses" contract for data transfers). You are entitled to request a copy of the relevant provisions of these contracts by contacting us at the email address below.
We may also be required by law to disclose information to government regulatory authorities. For example, we may be required to report your income to taxation authorities. We may also be required to disclose your personal and business information to SROs. SROs collect, maintain and use such information for regulatory purposes, including trading surveillance, audits, investigations, maintenance of regulatory databases and enforcement proceedings. SROs may, in turn, disclose such information when reporting to securities regulators or when sharing information with other SROs and law enforcement agencies.
Sprott Group may be involved in the sale, transfer or reorganization of some or all of its business at some time in the future. As part of that sale, transfer or reorganization, we may disclose your personal and business information to the acquiring organization.
We may share non-personal information collected though our websites in a number of circumstances for a number of purposes, including within the Sprott Group and with our service providers (for example, Google Analytics).
How do we use your information for marketing purposes?
We may share your personal or business information within the Sprott Group for the purpose of marketing products and services that we believe may be of interest to you. This would only be done with your consent. We may ask you for your contact information, such as your telephone number, residential address, e-mail or other electronic address, and keep and use this information as well as disclose it to other members of the Sprott Group so that we or any of these companies may contact you directly through these channels for the purpose of marketing including telemarketing. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see below).
How do you withdraw your consent?
Subject to legal, regulatory and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact on our ability to provide you or continue to provide you with some Services or information that may be of value to you. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.
How do you update your information?
As we make decisions based on the information we have, we encourage you to help us keep our information accurate and complete. Contact us at any time in writing at Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada Attention: Privacy Officer if you wish to update the information we have about you.
How can you access your information?
You may request access to the personal information we hold about you at any time to review its content and accuracy and to have it amended as appropriate. To request access to such information please contact us in writing at Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada Attention: Privacy Officer.
We will respond to your written access request promptly. We may be unable to provide you with access to all or some of the information we hold about you (the Data Protection Legislation may in some cases require us to withhold some information, for example if it is legally privileged).
Residents of the State of California, see our California Consumer Privacy Act Disclosures here.
Who do you contact if you have any questions or concerns?
If you have any questions about our privacy policies and practices and how they relate to you, please contact our Privacy Officer by telephone at 855.943.8099, by e-mail at firstname.lastname@example.org or by mail to Sprott Inc., Royal Bank Plaza, South Tower, 200 Bay Street, Suite 2600, Toronto, Ontario M5J 2J1 Canada Attention: Privacy Officer.
If you are still not satisfied, you can contact The Office of the Privacy Commissioner of Canada. Complaints to the Office of the Privacy Commissioner must be submitted in writing to 112 Kent Street, Ottawa, Ontario K1A 1H3 Attention: The Privacy Commissioner of Canada. There are other privacy regulators who may also be able to assist you.
If you have any questions regarding this Policy, please contact us at:
Royal Bank Plaza, South Tower
200 Bay Street, Suite 2600
Toronto, Ontario M5J 2J1
Toll Free: 855.943.8099
Last updated as of January 20, 2022.