Regulatory Information

Caldwell Securities Ltd. is regulated by the Investment Industry Regulatory Organization of Canada (IIROC) and is a member of the Canadian Investor Protection Fund (CIPF). As a registered firm we are bound by high standards of regulated and ethical conduct. Below we describe how we comply with some of these regulations.

National Instrument 24-101
TRADE MATCHING AND SETTLEMENT
Trade-Matching Statement

To: All trade-matching parties providing trade orders to,
Acting on behalf of, or executing a trade with:
Caldwell Securities Ltd.

This Trade-Matching Statement is being provided in accordance with National Instrument 24-101 – “Institutional Trade Matching and Settlement” and Companion Policy 24-101CP (this “National Instrument”).

It applies to all trades that are subject to the National Instrument.

We confirm that we have established, maintain and enforce policies and procedures designed to achieve matching in accordance with the National Instrument.

Sally Haldenby Haba
Vice President
PDF Download: Trade Matching Statements

Fees

Caldwell endeavours to keep the rates and fees posted on this website current. However, rates, fees and related information are subject to change at any time with prior notice to users and the posted rates and fees at this website may not reflect such changes.

Confidentiality

This website is not a secure medium for e-mail (electronic) communications. Any confidential, proprietary or sensitive information transmitted by a user by means of this website through e-mail may be read and/or copied by unauthorized persons.

Security

Users are solely responsible for the actual password(s) chosen by them. Users of this service are solely responsible for maintaining the security of their logon id and password(s), and ensuring that only the user uses the logon id and password(s). User agrees not to disclose their logon id and password(s) to any other person. Caldwell shall not be responsible for the unauthorized use of the service by any other person with user's logon id or password(s), and Caldwell is under no obligation to confirm the actual identity or authority of any user of the logon id or password(s). User shall notify Caldwell immediately upon becoming aware of any known or suspected unauthorized use of the user's logon id or password(s) to gain access to the service, or any other breach of security involving user's logon id or password(s).

Virus Checks

When using this website, it is up to you to take reasonable precautions to scan for computer viruses and other items of a destructive nature. It is also up to you to ensure that you have a complete and current backup of the information contained on your computer system prior to using this website.

This website is intended to permit clients of Caldwell Financial Ltd. (“CFL”) and its affiliates, Caldwell Securities Ltd. (“CSL”), and Caldwell Investment Management Ltd. (“CIM” and collectively with CFL and CSL referred to as “Caldwell”) to view their account balances and access related information, which may vary from customer to customer depending upon level of access granted. [Some of the services on this website are provided free of charge, but Caldwell reserves the right to charge for these services in the future.]

No portion of the content of this website may be reproduced, other than for personal, non-commercial use, in any form, or by any means, without prior written permission from Caldwell. All other trademarks, service marks, registered trademarks, or registered service marks mentioned in this website are the property of their respective owners.

The information in this service is provided "AS IS" with all faults. While Caldwell believes the information to be correct when posted on this website, it makes no warranty as to the correctness, currency, timeliness, quality, content or completeness of the information. Changes may be made at any time to this service and the information contained therein without prior notice. If you are a Caldwell client, please consult your Investment Advisor.

This website is not intended to provide legal, accounting or tax advice and should not be relied upon in that regard.

CSL is licensed to provide services as a dealer to residents of British Columbia, Alberta, Saskatchewan, Ontario, New Brunswick, Nova Scotia and Newfoundland. CIM is licensed to provide services as an adviser to residents of Ontario. Information from this website regarding services and products of Caldwell is intended for use only in jurisdictions where such services or products may lawfully be offered for use and/or for sale and neither use nor sale is intended where prohibited by law.

Information provided by Caldwell and information provided by other sources on this website is not subject to any guarantee as to its accuracy or completeness or as to its currency. Neither Caldwell nor any third party owner, licensor or supplier of information used or made available through this website, including market data, quotation information and databases, and including news, articles, text, graphs, audio clips, video clips, broadcasts and seminars ("Data") makes or is liable for any representation, warranty or condition, whether express or implied, concerning the Data or the use thereof including, without limitation, that (i) the Data will meet your needs, or that the Data will be available for use at any particular time or for any particular purpose or will be error free, or (ii) the Data is up-to-date, accurate, in sequence, reliable, complete or suitable for any purpose.

Without limiting the foregoing, "real time" quotes viewed on this website, particularly in times of high volumes of trading and market volatility, may not be reflective of a current trading price of a security. Further, all express or implied, direct or indirect, representations, warranties and conditions in respect of Data arising or implied by statute, common law, custom, usage of trade, course of performance, course of dealing or otherwise, including but not limited to any warranties or conditions of merchantable quality and fitness for a particular purpose are expressly excluded.

All the Data is protected by copyright and each supplier of the Data reserves all proprietary and intellectual property rights therein. You shall not reproduce, retransmit, disseminate, sell, rent, distribute, publish, broadcast, circulate or commercially exploit the Data provided through this website in any manner or furnish it to any other person without the prior written consent of Caldwell and the relevant supplier. The user of this website shall use the Data accessible through this website only for the user's individual use.

Caldwell expressly disclaims any liability for losses or damages, whether direct, indirect, specific or consequential incurred by any user of this website and whether by contract, negligence or otherwise.

Links in this website to other websites or references to products, services or publications other than those of Caldwell should not be construed as an endorsement, recommendation or approval of such websites, products, services or publications by Caldwell. Any information, data, opinions or recommendations provided by third parties through links to other websites or otherwise made available through this website are solely those of the third party and not of Caldwell.

Caldwell endeavours to offer customers an electronic service that is easy to use, reliable, secure and capable of meeting their customers' investment information needs. From time to time, however, interruptions, errors or other deficiencies in service may occur. This may be due to a variety of factors, some of which are outside the control of Caldwell, including interruptions in the accessibility of the Internet, a system outage in facilities of a third party service provider (including stock exchanges, Data providers and back office service providers), and market conditions that may result in general market volatility, volatility affecting a particular security or class of securities, or heavy demand and high volumes of trading activity.

All products and services of Caldwell are subject to the terms of any agreement by which they are normally made commercially available. Information in this website does not constitute a solicitation or offer to sell products or services of Caldwell or mutual funds normally distributed by them, or the securities or financial instruments of any issuer.

PDF Download: Legal Disclaimer

Best Execution and Multiple Marketplace Disclosure

Caldwell Securities Ltd (“Caldwell”) is committed to make reasonable efforts to ensure clients achieve the most advantageous execution terms reasonably available under the circumstances when executing transactions on behalf of a client, considering factors such as execution price, speed of execution, liquidity, price improvement opportunities, certainty of execution and overall cost of the transaction.   

Caldwell has established practices in accordance with Best Execution and Order Protection regulations such as Investment Industry Regulatory Organization of Canada (“IIROC”) Universal Market Integrity Rule (“UMIR”)5.1, Dealer Member Rule 3300 and National Instrument 23-101, Parts 4 and 6.

Best Execution refers to the obtaining of the most advantageous execution terms reasonably available under the circumstances. Caldwell pursues the execution of each order as expeditiously as practicable under prevailing market conditions.  Orders are routed to the marketplace that will provide the best execution.

Structure of the Canadian Equity Market

There are currently several marketplaces in Canada for the trading of listed securities, including traditional exchanges and Alternative Trading Systems (“ATS”).  The exchange where a company’s stock is listed is referred to as the “primary listing marketplace” for that stock.  Market makers may be appointed by an exchange in order to provide a two-sided market for a security on a continuous basis.  Exchanges set requirements governing the conduct of marketplace participants.

Equity exchanges in Canada used by Caldwell where quotes are protected under current Canadian Order Protection Rules, include:

The Toronto Stock Exchange (“TSX”);
The TSX Venture Exchange (“TSXV”); 
The Canadian Securities Exchange (“CSE”); and
NEO Exchange (“NEO”).

ATS provide automated trading systems to bring together orders from buyers and sellers of securities which are listed on other marketplaces (e.g. exchanges).  Unlike an exchange, ATS do not provide directly, or through one or more subscribers, a guarantee of a two-sided market for a security on a continuous or reasonably continuous basis, do not set requirements governing subscriber conduct, and do not discipline subscribers beyond exclusion from participation.   ATS used by Caldwell where quotes are protected under current Canadian Order Protection Rules include:

Nasdaq CXC;
Nasdaq CX2 (formerly CHI-X Canada);
Omega ATS;
Pure Trading (operated by CSE);

Dark Pools, which are a form of ATS, are private exchanges not accessible by the investing public.  They primarily facilitate block trading by institutional investors who do not wish to impact markets with large orders, though some have expanded to include orders of all sizes. Often used to protect proprietary trading information, they are used to take advantage of possible price improvement for liquidity seeking orders (typically smaller sized orders) and potentially incur lower trading fees.  In some cases, Dark Pools enable dealers to internalize order flow. They are referred to as “dark” due to the lack of transparency, as there is no order-book visible and trade details are released after a delay.  The lack of transparency has the opportunity to work in favour of obtaining a better realized price than through an exchange when there is limited liquidity on the exchange of a particular issue of securities.  Dark pools may be broker-dealer owned, agency broker or exchange owned or electronic market makers.  In Canada, they are generally regulated as an ATS, and are registered dealers with IIROC.  Examples of ones used only occasionally by Caldwell include:

Aequitas NEO Book;
LP MatchNow (TriAct Canada);
Nasdaq Canada –CXD

Best Execution Factors 

Caldwell considers price (bid and ask), speed, certainty of execution, overall cost of the transaction and any other factor relevant to the execution of the order.

Caldwell uses an electronic Smart Order Router (“SOR”) to direct all Canadian equity orders in seeking best execution and order protection.  The SOR seeks the best price across all Exchanges and visible ATS simultaneously, filling as much of the order as possible.   Best execution is determined by the consolidated market view or by other price discovery mechanisms, whether the security trades on a listed marketplace or whether it trades Over the Counter (“OTC”).   Unfilled portions are booked on the Default Exchange, which for Caldwell, is the TSX, as it has the highest volume of orders in its book.

The SOR is programmed with parameters to seek the best possible outcome in consideration of prevailing market conditions, the size of the order, the specific security and liquidity.  In the case of a sell, the SOR will route order to the marketplace with the highest bid price, while in the case of a purchase, to the marketplace with the lowest ask price.

In seeking best execution, the SOR may break the order into multiple smaller orders, sending each to multiple execution venues either in parallel or in sequence, in keeping with client instructions on the handling of the order.

In the event not all marketplaces are available for trading, or the SOR is unavailable or limited, orders received are directed to the Default Marketplace or to ATS as determined by the circumstances in the marketplace at the time, consistent with the client best interest and the obligation to seek the most advantageous execution terms reasonably available in the circumstances.

In the event trading on a particular security has been halted in a particular marketplace, all orders for that security will be halted and will remain in that marketplace until the halt has been lifted.

In respect of US equities, Caldwell does not have direct access to exchanges or ATS.  Instead, Caldwell will direct orders to one of a couple of US broker dealer intermediaries for execution.   Such intermediaries also use SORs and are subject to the same requirements as they relate to best execution. 

Hours of Operation for Trading in Canadian Listed Securities

Caldwell trading staff and systems are available for order execution between 9:30 am EST and 4:00 pm EST (“Hours of Operation”), Monday through Friday, excluding Canadian statutory holidays. Staff may be available outside of marketplace hours; however, trade execution outside of the Hours of Operation is treated on a best efforts basis. 

Standard Handling of Orders

Immediately executable orders received for Canadian listed securities are routed to the marketplace with the best bid or offer and the remainder, if any, residing on the default marketplace.

Pre-Open

An order received prior to Default Marketplace opening (9:30AM EST) will be routed in the SOR to book to the pre-opening of the Default Marketplace defined for that security for execution upon opening, in accordance with the Default Marketplace calculated opening price protocol.

Continuous Session

Active orders, defined as any portion of a market order or a limit price order which is immediately tradable based on current market conditions, received during the Hours of Operation, will be routed by the SOR to the marketplace with the best price at the time of execution.  The SOR evaluates all Exchanges and visible ATS for best price when executing active orders.

Passive orders, defined as the unfilled balance of an active order or any limit price order which is not immediately executable, received during the Hours of Operation, are booked to the Default Marketplace for that security where it will remain until filled, changed, expired or cancelled.

Changes to an outstanding order, or portion of an outstanding order, will be handled in the same manner as a new order received, with an active order re-evaluated for best price execution across all Exchanges and visible ATS, and a passive order booked to the Default Marketplace for that security.

Post-Close

Orders received after the Default Marketplace closing (4:00 PM EST) will be queued in the SOR for routing to the pre-opening of the Default Marketplace on the following business day.

Order Execution

Certain types of orders have specific handling implications in a multiple marketplace environment. These have been addressed as follows: 

Day Orders

A Day Order is an order only valid for the day it is entered (between the marketplace hours) and handled as per the “Standard Handling of Orders” noted above.  Any unfilled portion of a Day Order will expire at the close of business of the marketplace where the order was last entered.

Good Until Cancel or Good Through Orders

Good Until Cancel orders are orders that will remain open until filled, cancelled or they expire.  Caldwell will, at the end of each month, cancel any open Good Until Cancel orders.  The system used by Caldwell will also only permit such order to be open for a maximum of 90 days.  The SOR will route any immediately unfilled portion of these orders to the Default Marketplace if they are not immediately executable at the time of entry. These orders will remain booked until executed, cancelled, changed or expired, whichever comes first.

Market Orders

A Market Order is an order to buy or sell a security immediately, at the best available price at the time the order is entered. Market Orders are routed with priority when received. In cases of extreme market volatility or liquidity imbalance, as a result of their being tagged with speed as a priority, a market order may trade at a price which is significantly different than the expected execution price.   Investors are advised to use aggressively priced limit orders in place of market orders to reduce the risk of the order trading at a price outside of a preconceived ‘acceptable’ range.  Any unfilled portion of a Market Order will expire at the close of business of the marketplace where the order was active.

Limit Orders

A Limit Order is an order for a security at a specific minimum sale price or maximum purchase price that is not to be exceeded, which on the one hand provides control over the execution price but on the other, reduces the certainty of execution. Limit Orders will be handled in the priority they are received.

It is possible for a limit order to miss the opportunity to buy or to sell a stock in a fast moving market. Aggressively priced limit orders, meaning an order with a higher/lower price than the prevailing offer/bid price, will trade much like a market order, increasing the certainty of execution without the risk of the order trading at a price outside of a predetermined ‘acceptable’ range.

Any unfilled portion of a Limit Order will expire at the close of business of the marketplace where the order was active.

Special Terms Orders

Special Terms Orders are orders with specific terms that are not executable in the regular marketplace. Special Terms Orders will only post to the Special Terms Market of the primary listing Exchange, unless they are immediately executable on an alternative marketplace at the time of entry. Any unfilled portion of a Special Terms Order will expire at the close of the primary listing Exchange.

Stop Loss Orders (Canadian Markets)

Stop Loss Orders are orders that become Market Orders or Limit Orders when a standard trading unit (referred to as a board lot) trades at or superior to the stop price on the marketplace in which the order has been booked. Stop Loss Orders are booked to the primary listing Exchange. A Stop Loss market order is filled at the best available market price once the stop price is activated. However, if the order enters the market when the stock or overall market is experiencing dramatic fluctuations including rapid declines, an investor may receive a price that is much different than expected.

Caldwell does not encourage the use of Stop Loss limits.  Stop Loss orders received notwithstanding, are reviewed by the Head Trader to ensure the size of the order is not at a level that would result in market volatility should the On Stop price be activated.

Crosses

A cross trade refers to a situation where Caldwell receives an order to buy and an order to sell the same security and approximately the same time.  Internal or intentional crosses are recorded on the market at the midway price between the bid and ask at the time the orders are received. 

Disclosure of Marketplace

Trade confirmations state that an order has been executed on one or more marketplaces or alternative marketplaces. Client may contact their Investment Advisor for further details regarding which marketplace or alternative marketplace a trade was executed.

The information contained herein is current as of May 31, 2019.

This disclosure has been modified since the prior posted disclosure (dated  December 2013) for the purposes of providing increased transparency regarding:

  • the marketplaces Caldwell’s Smart Order Routing (“SOR”) technology references, 
  • the SOR handling practices by order type, and how the SOR achieves best execution

Disclosure of Conflict of Interest

Urbana Corporation is a related entity of CSL, and owns 49% of the Canadian Securities Exchange (CSE). Thomas S. Caldwell, Chairman & CEO of CSL, is Chairman of the CSE and his role is to oversee strategy and governance.  

INTRODUCTION

Caldwell Securities Ltd. (“Caldwell”) respects your privacy and is committed to protecting it through our compliance with our policy, a copy of which is available upon request (email: privacy@caldwellsecurities.com)

We will only use your personal information in accordance with our policy unless otherwise permitted or required by applicable law. We take steps to ensure we only collect personal information required to provide you with the services you have obtained, ensuring what we collect about you is adequate, relevant, not excessive, and is used and disclosed for purposes of servicing you and as may be required by law.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

HOW WE OBTAIN YOUR CONSENT

You provide your consent for Caldwell to collect, retain and use your personal information in a number of ways:

  • Before or at the time you open an account with Caldwell, you will be required to provide certain personal information to establish the account. The information may be collected via a Caldwell New Client Application Form (commonly known as an “NCAF”), in which case you will formally indicate your explicit consent when you sign the application.
  • You may also consent to communications directly from a Caldwell investment advisor by providing your email, phone number, address or other contact details directly to that advisor, in which case you have implied your consent to be contacted.
  • By using our website, you consent to the collection of technical and website interaction information (see “Information we collect about you”) automatically through our website
WITHDRAWING YOUR CONSENT

You are always in control of your personal information and providing us with your information is always your choice, except where required by law.

You can withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent). If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect your decision in accordance with our legal obligations. However, your decision to withhold particular information or to stop processing your information may limit or prevent us from providing investment or financial advice based on your specific needs or providing products or services you have obtained. This may result in the closure of your account and you will be responsible for any fees and taxes associated with the disposition of your investments with us.

If you do not wish to receive promotional materials from us you may contact your investment advisor, or, if you are uncomfortable doing so, contact one of our privacy officers listed in “Contact Information”.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

  • Information establishing your identity such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address, user name or other similar identifier, social insurance number, date of birth.
  • Information you provide on an application for products and services (and subsequent updates), such as annual income, place of employment, investments, account holdings, beneficiary information, financial information, billing and account information and transaction history.
  • Information to authenticate your identity, such as knowledge-based information (i.e. username, password, security questions or account information) and signature.
  • Banking Information you provide to facilitate deposits and withdrawals to your account or to facilitate the settlement of fund purchases, redemptions, distributions and other similar transactions.
  • Information you provide during communication with us which may include telephone numbers, family details, life events, alternate contact details, goals and your opinions and issues you may have encountered.
  • Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment. Also, if you communicate with us via electronic means, you are providing us with your email details.
  • Information you provide to establish your eligibility for certain products. Certain investment products are only available to qualifying eligible investors, such as accredited investors. You must provide us the information to support and validate your eligibility before we are able to sell you these products.
  • Electronic mail and contact information, in order to receive any electronic messages from us which you may have subscribed to via our website, through completing an account application, or in speaking with a Caldwell representative.
  • Website interaction information, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our client service number.
  • Additional information may be requested to help us determine your eligibility for products and services that we offer.
HOW WE COLLECT INFORMATION ABOUT YOU

Most of the information is collected when you interact with us, for example when you:

  • apply for a product, service or account with us; or
  • communicate or interact with us in email, written or verbal communications;

We also collect financial, technical and other information about you from a variety of sources including through:

  • transactions you have made with us; or
  • third parties or publicly available sources, for example, references you provide to us, credit bureaus and reporting agencies, our business partners, other financial institutions, and from regulatory, government and similar authorities; or
  • automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies
HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

  • To provide you with products, services or information requested and otherwise service your account, which includes making tax payments or reports, meeting legal requirements to verify your identity, checking your credit history where required, recording beneficiary information and providing you with account statements, confirmations, tax receipts, notices about your account or other requested reports.
  • To execute securities transactions on your behalf and advise you concerning your securities transactions or send you communications of a transactional nature.
  • To meet regulatory, legal and governmental requirements and to carry out our obligations and enforce our rights arising from any contracts with you, including managing our risks and operations.
  • To verify your identity and to authenticate you when you contact us.
  • To inform you of the financial products and services that you may be eligible for, or communicate to you any updates, benefits, features and other information about products and services you have with us, or to better understand your financial situation and goals to determine your eligibility for products and services we offer and to manage your products and services with us.
  • To compile non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of clients using a particular service.
  • To present our Website and its’ contents to you, notify you about changes to our Website or any products or services for ongoing communications.
  • To fulfill any other purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide information and consent to its’ use.
DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users and clients, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide in order to fulfill our obligations. We may disclose to:

  • mutual fund companies, issuers or other intermediaries for securities where you wish to purchase units or for securities in which you hold shares for purposes of distributing shareholder information.
  • our regulators (including the provincial Securities Commissions, the Investment Industry Regulatory Organization of Canada, the Canadian Investor Protection Fund and federal and provincial governments). These regulatory bodies collect, use or disclose such personal information obtained from us for regulatory purposes, including surveillance of trading-related activities, regulatory audits, investigations of potential violations of rules or laws, enforcement or disciplinary proceedings, and information sharing with other regulatory organizations in connection with any of the foregoing.
  • our subsidiaries and affiliates, including Caldwell Financial Ltd., Caldwell Investment Management Ltd., and Caldwell Insurance Services Ltd. in connection with ongoing servicing of your accounts.
  • a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of Caldwell, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Caldwell about our clients and users is among the assets transferred (in accordance with applicable law).
  • contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in our policy.
  • fulfill the purpose for which you provide it or for any other purpose disclosed by us when you provide the information, and with your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
  • To enforce or apply our agreements with you, including for billing and collection purposes.
  • To protect the rights, property, or safety of Caldwell, our clients, or others (if we believe disclosure is necessary). This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit, financial or operational risk reduction.
TRANSFERRING YOUR PERSONAL INFORMATION

When engaging our service providers or through the use of new technology we may process, store, and transfer your personal information into the U.S.A., a jurisdiction with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to our policy and applicable Canadian privacy legislation.

You are welcome to contact us to obtain further information about Caldwell policies regarding service providers outside of Canada. See the “Contact Information and Challenging Compliance” section below. By submitting your personal information, engaging with the Websites, or using our products and services, you consent to this transfer, storage, or processing.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

Please be aware though that, despite these efforts, no security measures are perfect and no systems are impenetrable. Your privacy can be enhanced by taking care to use suitably strong passwords that others cannot guess, that are kept safe by you, and that are not re-used on other sites. Taking steps like avoiding dictionary words or proper names, and adding extra characters and punctuation marks can also help protect you. If you believe your password has been compromised, you should change it immediately.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures used by Caldwell.

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy and security policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy and security policies of every website you visit.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When you open an account with us, most information you provide is required to be retained for at least seven years from the date you close your account.

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. You may receive a copy of the personal information we have on file at minimal or no cost to you by contacting our privacy officers listed below.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may contact us using the contact information set out below. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

CHANGES TO OUR PRIVACY POLICY

We may update this privacy policy from time to time to reflect changes in our privacy practices and will post revised disclosure to our website (https://www.caldwellsecurities.com). Changes are effective immediately and you are to periodically review the privacy policy to see whether it has changed.

To ensure you receive important notices from us, you are responsible for providing us an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices.

Privacy Officers: Brandon Boyd or Sally Haldenby-Haba

150 King Street West Suite 1710 Toronto ON M5H 1J9

Telephone: 416-862-7755 Fax: 416-862-9438

Email: privacy@caldwellsecurities.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with our policy, and with applicable privacy laws. To discuss our compliance with our policy please contact one of our Privacy Officers using the contact information listed above.

In the event you find our proposed solutions unacceptable, you may escalate your complaint to the regulators directly:

The Privacy Commission of Canada
112 Kent Street Ottawa,
Ontario K1A 1H3
Phone: 613-995-8210 or 1-800-282-1376