PRIVACY POLICY

Customer Privacy Policy Notice

Echelon Partners USA Inc. (“Echelon Partners USA”) understands that trust is an important factor in our relationship, and we take this very seriously. Protecting your privacy and the confidentiality of your personal information is a fundamental part of our responsibility to you. Through our policies and procedures as well as state-of-the-art equipment and computer security measures, we ensure that your privacy and the confidentiality of your information are protected.

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to non-affiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. 

Echelon Partners USA is committed to safeguarding your confidential information. Echelon Partners USA holds all personal information provided by you in the strictest confidence and it is the objective of Echelon Partners USA to protect the privacy of all clients. Except as permitted or required by law, Echelon Partners USA does not share confidential information about you with non-affiliated parties. In the event that there were to be a change in this policy, Echelon Partners USA will provide you with written notice and you will be provided an opportunity to direct Echelon Partners USA as to whether such disclosure is permissible. 

Information We Collect

To conduct regular business, Echelon Partners USA may collect personal information from sources such as:

• Information reported by you on applications or other forms you provide to Echelon Partners USA
• Information about your transactions implemented by others
• Information developed as part of financial consultations and analyses

Information That We Share

To provide related services for client accounts, it is necessary for Echelon Partners USA to provide access to your information within the firm and to non-affiliated companies with whom Echelon Partners USA has entered into agreements. To provide the utmost service, Echelon Partners USA may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on behalf of Echelon Partners USA:

• Information Echelon Partners USA receives from you on applications (name, social security number, address, assets, etc.)
• Information about your transactions with others (account information, payment history, parties to transactions, etc.)

Since Echelon Partners USA shares non-public information solely to service you, Echelon Partners USA does not disclose any non-public personal information about its customers or former customers to anyone, except as permitted by law. However, Echelon Partners USA may also provide your information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas.

Confidentiality and Security

The security of your account information is important to us. Only those persons who need your information to perform their job have access to it. In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to protect your information. Our employees have limited access to your personal information based upon their responsibilities. All employees are instructed to protect the confidentiality of your personal information as described in these policies, which are strictly enforced.

We may store your information (in encrypted form where we believe it to be highly sensitive) in electronic databases or e-mail boxes hosted by us or our service providers, for periods of time and with safeguards that we believe are reasonable depending on the nature and sensitivity of the information. Access to the information is restricted to a select group of individuals, in accordance with our security protocols. 

Former Customer

If you end your relationship with Echelon Partners USA, we will continue to adhere to the policies and practices described in this notice.

Respecting and Responding to Your Privacy Concerns

You have the option to refuse or withdraw consent to the collection, use and disclosure of your information, and we will respect your choices. If you wish to exercise this option or if you have any questions or enquiries with respect to our privacy policies or procedures, please send a written request to: Chief Compliance Officer, Echelon Partners USA Inc., 181 Bay Street, Suite 2500, Toronto, ON Canada M5J 2T3. We will investigate and respond to your concerns about any aspect of our handling of your information.