Privacy Policy
As of May 15, 2023
Phoenix Horizon Investments Corp.’s utmost commitment is to ensure the protection, confidentiality, and security of your personal information. Before you entrust us with your personal information, we strongly encourage you to thoroughly review this Privacy Policy. Whenever we mention PHIC, we are referring to PHIC Management Inc. and its subsidiaries.
Our Privacy Policy articulates our fundamental principles concerning the collection, utilization, disclosure, and retention of your personal information. It also provides insight into how we uphold the security of your personal information and respect your right to access it.
Individual Data. We define Personal Information as data that can be used to identify an individual, encompassing financial, lifestyle, or health information. It does not include information such as name, business title, address, telephone number, or email. Irrespective of its form or characteristics, whether it’s in written, visual, audio, graphic, computerized, or any other format, personal information is held to the highest standards of protection. Information Collection. Collecting information about you is fundamental to delivering top-tier services. The nature and sensitivity of the information we collect may vary depending on the services we offer and legal requirements, such as those related to taxation. We explicitly identify the purposes of collecting your personal information either at the time of collection or beforehand. For example, we may gather information when you submit an application, open an account, or file a claim. The usual reasons for collecting this information include delivering requested products or services, verifying your identity, preventing fraud, or addressing issues relating to our relationship.
Approval. To collect, use, or disclose personal information, we require your initial consent. If we intend to use or disclose your information for additional purposes or if the purpose changes, we will seek your consent. We generally seek express written consent to collect, use, or disclose personal information. In appropriate circumstances, verbal consent may be accepted. On rare occasions, consent may be inferred from your actions or inaction. Consent should be provided by you or your authorized representative, such as a legal guardian or an individual with power of attorney. You retain the right to withdraw your consent at any time, subject to legal or contractual constraints. We will apprise you of the consequences of such withdrawal, which could affect our ability to provide a product or process a request. If consent is withdrawn, we will document this decision in our records. In exceptional situations, personal information may be collected, used, or disclosed without your knowledge and consent due to legal, medical, or security constraints that make obtaining consent impossible or impractical. This may also apply when information is collected for investigations related to potential contract breaches, fraud prevention or detection, or law enforcement purposes.
Restrictions on Gathering, Utilization, and Sharing. We exclusively collect personal information directly from you or with your consent from third parties. We cannot use your personal information for purposes beyond those to which you have consented, nor can we disclose it without your consent. However, personal information may be collected, used, or disclosed without your consent as permitted or required by law. We limit the collection, use, and disclosure of your personal information to the purposes we have communicated to you. Access to your personal information is granted exclusively to authorized individuals who require it for their responsibilities. We may share your personal information with service providers or agents on occasion to ensure the proper administration of products or to provide the services you require. In specific circumstances, we may engage service providers located outside of Canada, including the United States. It is our responsibility to ensure that these service providers adhere to privacy legislation and maintain a level of personal information protection equivalent to our standards. You have the right to know, upon request, to whom we have disclosed your information. In rare cases, legal restrictions may prevent us from making such disclosures. We keep meticulous records of the recipients of personal information and the circumstances under which it was disclosed.
Sharing Personal Data. We may compile a list of clients, including names, addresses, and telephone numbers, and share this list with companies within PHIC. If you wish to be removed from this list, please contact the Privacy Officer at the provided address. With your consent, we may also share your personal information with companies within PHIC to enhance our understanding of you, better meet your needs, and provide an outstanding service and client experience. If you prefer not to receive offers for products and services, you have the choice to withhold your consent. We do not trade your personal information with third parties.
Data Accuracy. We exert every effort to ensure that your personal information is accurate and complete, as required for the purposes for which it is collected, used, or disclosed.
Retention. We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected. The disposal of information is conducted in accordance with the law and our file retention guidelines, ensuring confidentiality and safeguarding against unauthorized access during the destruction process.
Responsibility and Oversight. We hold ourselves accountable for the personal information under our control, even when it is transferred to third parties for processing. We require these third parties to adhere to rigorous privacy and protection standards. We adhere to legislated and self-imposed regulations designed to protect your privacy. Oversight of this Privacy Policy and the procedures we employ to protect your personal information is the responsibility of the Privacy Officer. Additional regulations are outlined in a code of conduct, market conduct standards, industry guidelines, and applicable laws. Our staff is trained in these processes and procedures and is knowledgeable about privacy laws.
Security Measures. We have implemented and continue to employ robust safeguards to maintain the strict confidentiality and security of your personal information, preventing loss, theft, unauthorized use, disclosure, access, copying, or modification. Our security measures include organizational protocols such as security clearances, limiting access to a “need-to-know” basis, physical security measures (e.g., building access cards, visitor registration, off-site backups), and technological measures (e.g., passwords, encryption, firewalls).
Request for Information Access and Changes. You have the right to know whether we possess personal information about you and to access that information. You may also inquire about how your information was collected, used, and to whom it may have been disclosed. We will provide this information within a reasonable timeframe from the date we receive your written request, and we may charge a reasonable processing fee in certain cases. In specific and limited situations, we may refuse to provide specific information. Exceptions include data containing references to other individuals, information prohibited for legal, security, or proprietary reasons, information obtained during the investigation of potential contract breaches or fraud, prohibitively costly information, or information subject to litigation or privilege. In cases where we hold medical information about you, we may deny direct access and instead request that a designated health care professional provide the information to you. You have the option to challenge the accuracy and completeness of your personal information, and we will respond to amendment requests within a reasonable timeframe.
For any information access requests or amendment requests, please contact:
Privacy Officer
By Email: privacyofficer@phic.ca
By Mail: Chief Privacy Officer Phoenix Horizon Investments Corp. 9327 63, AVE NW Edmonton, AB T6E0G2
Complaints and Addressing Concerns. Our employees and representatives are well-prepared to address your questions or concerns regarding personal information. If you are dissatisfied with the response from our employee or representative, you may contact the Privacy Officer at the address mentioned above.
Furthermore, any complaints regarding the protection of personal information should be directed to the Privacy Officer.
Review of this Policy. This Policy will undergo review every three years, and it will also be reviewed whenever substantial changes occur in legislative or regulatory requirements.
Click here to download PHIC’s full privacy policy.
