Privacy statement and cookies

Russell Investments Canada Limited 2016

Russell Investments Canada Limited ("Russell Investments") has always been committed to maintaining the confidentiality, integrity and security of all personal information that we collect, use and maintain in the course of carrying on business. We are proud of our privacy practices and want you to know how we protect this information and use it to service your account.

Personal Information

In this policy, personal information means any information about an identifiable individual, including information such as home address and telephone number, date of birth, age, marital status, religious affiliation, employment history, social insurance number and credit history. It does not include business contact information of individuals that communicate with us in relation to their business, employment or profession.

Collection of Personal Information

Personal information is collected directly from you or through your advisor when you open an account with Russell Investments. This information is obtained by us when you or your advisor sends us a completed application form or when your advisor transmits information to us electronically. In servicing your account, we will also generate personal information, including transaction information. From time to time, we may be required to collect information from a third party who is not your advisor, such as an executor of an estate of a third party who may provide information about you or your account to us. We may also collect other personal information if it is provided to us by your financial advisor or dealer.

The personal information in your account with us may include your name, birth date, mailing address, social insurance number, phone number(s), account holdings and transactions and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request, and the types of communications that you have with us. At times, we may request independent sources to verify and supplement information that you provide to us.

Use of Personal Information

Russell Investments may use your personal information for these stated purposes:

  • Communicating with you and your advisor and dealer regarding service offering or products which may be of interest to you
  • Establishing and administering your account
  • Ensuring the information in our records is accurate
  • Executing your transactions
  • Meeting legal and regulatory requirements
  • Collecting a debt owed to us
  • Providing you and your advisor and dealer with account statements and other account related information
  • Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account
  • Setting-up and managing products and services you have requested
  • Verifying your identity and protecting against fraud
  • Verifying previously given information when necessary

From time to time, we may use personal information to create aggregated or otherwise non-identifiable data whose purpose is to help us better provide services or assist with research or educational tasks. We only do this if the non-identifiable data cannot be used to identify the personal information of any individuals.

Disclosure of Personal Information to Third Parties

Russell Investments discloses your personal information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy. Third parties who may be provided with your personal information include:

  • Entities to whom we are legally obliged to provide information
  • Governments, government agencies and regulators
  • Other mutual fund companies, financial institutions and securities dealers when necessary to carry out your instructions such as transferring funds
  • Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, imaging and document storage
  • Your advisor and dealer

At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information, and may be accessible by regulatory authorities in other jurisdictions. When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession.

Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose your information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities, and if such disclosure is not prohibited by law.

We may disclose user information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets. In this case, we would ensure that the information disclosed continues to be used only for the purposes permitted by this Privacy Policy and by the entity acquiring the information.

We do not sell your personal information to any third party.

Obtaining/Withdrawing Consent

In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information. When you provide us with personal information about another individual, you represent to us that you are authorized to disclose such information to us on the terms specified in this privacy policy.

You may withdraw your consent to our use of your personal information at any time by contacting us at 1-888-509-1792. If you withdraw consent, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.

Updating Personal Information

Russell Investments will provide you with access to your personal information on your written request. Our verification procedures help to minimize risk that such information is released to anyone not authorized to receive it. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law. Except under limited circumstances, you may ask us to amend or update your personal information at any time. Russell Investments reserves the right to charge you for our costs incurred in providing the information requested.

Russell Investments may not be able to provide you with full access to your information if:

  • It contains references to other persons
  • It has been destroyed
  • It is too costly to retrieve
  • It cannot be disclosed for legal or regulatory reasons
  • We would have to disclose proprietary information confidential to Russell Investments or its affiliates

If we are unable to provide you with access to your personal information, we will give you an explanation.

Please inform us promptly of any change in the personal information that you have provided, or if you become aware of any errors in the personal information that we have in respect of you.

Protection of Personal Information

We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and data encryption for on-line activities. We have policies and procedures, training programs and monitoring in place to ensure that these measures are followed.

Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your account.

Retention of Personal Information

We only keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). Once it is no longer needed, it is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.

Change of Russell Investments' Privacy Policy

If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower left hand corner of this web page.

If you have any concerns, queries or complaints in respect of this privacy policy, or our management of your personal information, you can contact our Client Services team by email at canada@russellinvestments.com by telephone at 416-362-8411 or toll-free at 888-509-1792, or by mail to the following address:

Security

This site has security measures in place to protect the loss, misuse and alteration of the information under our control.

Choice/opt-out

Our site provides users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor.

This site gives users the following options for removing their information from our database to stop future communications or to no longer receive our service.

You can send e-mail to canada@russellinvestments.com.

Correct/update

This site gives users the following options for changing and modifying information previously provided.

You can send e-mail to canada@russellinvestments.com.

Cookies

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, you should be aware that if cookies are rejected you will not be able to use some of the online services provided by Russell Investments. For more information on how to configure your browser preferences, please refer to the user guides:

A full list of all cookies Russell Investments uses can be found here:

Cookies for storing your preferences

We use various cookies to store some details you enter and choices you make so that we do not have to ask you for them every time you visit a page that needs them.

COOKIE NAME PURPOSE
ASP.NET_SessionId,
ASPSESSIONID********
Keeps a record of your current Russell Investmentssession so that we can provide consistent functionality across the site. It expires when you logout, close your browser or if you clear your cache of browsing history.

ASPSESSIONID******** will generate a random set of 8 letters that will change with every session.
ri.com This will remember your preferences from the russellinvestments.com so your preferences will persist on future visits. These preferences include: country selection; audience type selection; acceptance of cookies.
website#lang This will remember your language preference from the russellinvestments.com so your preference will persist on future visits.

Cookies for improving service by measuring traffic

We use Google Analytics, a web analytics service provided by Google, in order to find out how visitors interact with Russell Investments so we can improve it. Information is collected anonymously and website trends are reported without identifying individual visitors.

COOKIE NAME PURPOSE
__utma Keeps track of the number of times a visitor has been to the site, when their first visit was, and when their last visit occurred. It expires aftertwo years.
__utmb and __utmc The B and C cookies work together to calculate how long a visit takes.

__utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site.

__utmc has no way of knowing when a user closes their browser or leaves a website, so it waits 30 minutes for another pageview to happen, and if it doesn't, it expires.
__utmz Keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword was used, and where they were in the world when the website was accessed.
_ga Used by Google to distinguish users.
_gat_*** This cookie is used with Google Universal Analytics. This cookie is used to monitor and track visitors behavior on the site anonymously.
auto Used by Google to distinguish users.
ELOQUA, ELQSTATUS These cookies are used to collect information about how visitors use our site. This information is used to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. If you click through to our website from an email sent by Eloqua, we are subsequently able to identify the pages you visit on russellinvestments.com. This information is stored securely in Eloqua and never, under any circumstances, supplied to third parties.
VISITOR_INFO1_LIVE, PREF, YSC We use YouTube to embed videos. The VISITOR_INFO1_LIVE cookie attempts to estimate your bandwidth. The PREF cookie may be used by YouTube to store session preferences that relate to your activity when watching the embedded videos. These cookies don't gather information that identifies a user.
SC_ANALYTICS_GLOBAL_COOKIE This cookie is used to identify repeat visits from a single user

DoubleClick (A Google Company) cookies

We also may use DoubleClick cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (”interest based targeting”). The ads served will be targeted based on your previous browsing history. DoubleClick uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visiting http://www.doubleclick.com/privacy/dart_adserving.aspx

If you have any questions about this privacy statement, the practices of this site, or your dealings with this Web site, you can contact

Russell Investments Canada Limited
1 First Canadian Place
100 King Street West
Suite 4510, P.O. Box 476
Toronto, Ontario M5X 1E4
Attn: Client Services

November 20, 2015

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