Desjardins Trust

Privacy Policy

1. Description

The Privacy Policy of Desjardins Trust (the "Company") sets out rules and guidelines that the Company has established and will follow to ensure that all personal information it collects, holds, uses or discloses about its clients remains confidential and secure.

This Policy explains how the Company protects its clients' personal information when providing financial services. It also outlines the privacy principles used to protect clients' personal information when conducting business in Canada, both intra- and inter-provincially.

2. Purpose

In addition to being mindful of legal compliance, the Company takes privacy very seriously and is committed to taking the necessary steps to ensure and maintain the accuracy, confidentiality, security and privacy of its clients' personal information. The adoption and enforcement of this Privacy Policy demonstrates this commitment and should help foster client confidence in the Company.

3. Scope of application

All employees, officers and directors of the Company must abide by the Policy and the privacy process established by Desjardins Trust management.

4. Terminology

For the purposes of this Policy, the following words and expressions have the meanings set out below:

4.1 "Consent" means free and informed consent obtained in accordance with applicable laws. Clients may express their consent orally, in writing or electronically, as appropriate.

4.2 "Nominative list" means a list of names, addresses and/or telephone numbers of individuals, whether or not based on a common denominator.

4.3 "Direct marketing" means promotions targeting clients whose personal information suggests that a Financial Product or Service may be of interest to them. Direct marketing includes telemarketing and mail/email initiatives but excludes regularly issued statements, statement inserts, Desjardins ATM messages, electronic bulletin board announcements and websites.

4.4 "Client" means a person who uses or intends to use a Financial Product or Service of the Company.

4.5 "Desjardins Group" means all components of Desjardins Group.

4.6 "Financial products and services" includes, but is not limited to, deposits, personal financial services, trust and custody services and financial planning services.

4.7 "Personal information" means any client information that is submitted by a client to the Company, collected from a third party in accordance with this Policy and applicable law or provided by a Desjardins Group component.

4.8 "Third party" means an individual or organization other than a Desjardins Group component.

5. Collection, use and disclosure

5.1 Subject to the requirements of applicable law, the Company will collect, use and disclose a client's personal information only to:

(a) Understand the client's needs
(b) Determine whether the client's financial products and services are suitable for their needs
(c) Suggest products and services that better meet the client's needs
(d) Create and manage financial products and services that meet the client's needs
(e) Provide the client with everyday financial products and services
(f) Comply with laws and regulations
(g) Carry out direct marketing activities

5.2 The Company may use information about a client's deposits, investments, credit or other personal information in the Company's possession, including how the client uses Desjardins Group financial products and services, to further inform the client about Desjardins Group financial products and services.

5.3 Subject to legal and contractual restrictions and Section 8 of this Policy, the Company may share a client's personal information with other Desjardins Group components so these components can directly inform the client about their financial products and services. However, personal information can only be shared in this manner if the client has signed the "Desjardins Consent" form and has read the accompanying leaflet, "Desjardins Consent, I Benefit!"

6. Retention

6.1 The Company may, subject to applicable law, keep a client's personal information on file for as long as is necessary for the above purposes, even if the individual ceases to be a client.

7. Consent

7.1 Subject to any exceptions provided for or permitted by applicable law, the Company will not collect, use or disclose a client's personal information for the purposes listed in Section 5.1 or for any other purpose without the client's prior consent. Such consent is given by the client for various financial services.

7.2 If the Company collects personal information from or contacts third parties (e.g., credit bureaus or other agencies, employers, hospitals) to verify or supplement personal information, it will do so, subject to applicable law, only with the prior consent of the client concerned.

7.3 With the exception of the cases set out below, whenever the Company discloses information in accordance with this Policy, it will keep a record, to the extent it is reasonable to do so, of the nature of the information, the date on which it was provided and the identity of the third party or Desjardins Group component to which it was provided. The only exception to this rule is the disclosure of personal information for the following purposes: routine operations, such as forwarding information to companies acting as agents of the Company, producing statements and other documents for Revenu Québec and the Canada Revenue Agency, updating data with the relevant offices and communicating with third parties regarding NSF cheques.

7.4 Subject to legal and contractual obligations, clients may withhold consent for the collection, use or disclosure of their personal information or withdraw consent at any time. If a client doesn't want the Company to collect, use or disclose their personal information for any purpose or to contact them by mail or telephone, the client may take the necessary steps with the Company in this regard. However, if a client refuses or withdraws such consent, the Company may not be able to provide or continue to provide the client with certain products, services or information that may be of interest to or requested by the client.

8. Nominative lists

Desjardins Group components may compile and share with third parties and other Desjardins Group components a nominative list of their respective members and clients for commercial or philanthropic prospecting purposes. Clients of the Company may request at any time that the Company remove their names from its nominative lists.

9. Subcontractors and service providers

A client's personal information may be disclosed to agents and contractors of the Company and to service providers for services such as data processing, cheque or credit card printing, statement preparation or mailing, debt collection and claims processing. In such circumstances, the Company will require that this information not be used for any purpose other than to provide the Company with the service in question. Subcontractors and service providers must also agree to take all necessary steps to protect the personal information disclosed to them when services are being provided. These obligations are valid when services are being provided and continue to be valid thereafter.

10. De-identification

The Company may use and disclose client information for statistical, market analysis and segmentation purposes provided that clients can't be identified in any way and no connection can be made between clients and the information used or disclosed.

11. Accuracy of information

11.1 The Company will make every reasonable effort to ensure the currency, accuracy and integrity of the personal information it has on its clients. However, each client must promptly inform the Company of any change in name or address or any other relevant change in personal information.

11.2 If a client believes that any of their personal information is wrong or inaccurate, the Company encourages them to request access to their file so they can verify the accuracy of the information and make any necessary changes or updates.

12. Rights of access and correction

12.1 Subject to applicable legal restrictions, clients may request to be informed of the existence, use and disclosure of their personal information at any time. They can access their personal information by writing to the Company or coming in person. For security purposes, clients must prove their identity before accessing their personal information.

12.2 The Company will provide clients with the information it has on them within thirty (30) days of receiving an access request, unless an extension is granted in accordance with applicable laws, if any. If a fee is to be charged for retrieving the information, the client will be notified in advance and may choose to withdraw the request or challenge the reasonableness of the fee.

12.3 Clients with sensory disabilities may, upon request to the Company, have access to their personal information in a format that allows them to read or listen to it, if such a format is available. If no such format is available, the Company will convert the relevant personal information into the required format if it is reasonable to do so.

12.4 If a client's access request is denied, the Company will, subject to applicable legal restrictions, inform the client of the reasons for denying the request.

13. Protection measures

13.1 To maintain client confidence, the Company has put in place measures to keep clients' personal information confidential, secure and private.

13.2 Desjardins Trust employees must read this Policy and agree to comply with it and to keep our clients' personal information private. In addition to this Policy, Desjardins Trust employees must follow the applicable Code of Ethics and Professional Conduct.

13.3 As mentioned above, subcontractors and service providers contracted by the Company must agree to protect the confidentiality and privacy of personal information disclosed to them in connection with the services they provide.

13.4 The Company has also implemented significant security measures to protect its IT systems. Only authorized personnel have access to facilities where personal information is received, processed or stored. Computer systems and data processing are subject to appropriate security measures such as passwords, data encryption, application and database access controls, firewalls, antivirus software and intrusion detection systems, which are reviewed regularly to ensure the security of operations and the confidentiality of data. More details on the safeguards in place for online transaction services and application forms can be found at www.desjardins.com.

13.5 If the Company determines that personal information is no longer required for the purposes for which it was collected, the Company will destroy or erase the information, subject to applicable law and in accordance with the Company's internal retention and destruction policies.

14. Questions/complaints/recourse

14.1 If you have any questions, concerns or complaints about the handling of your personal information, you can:
Contact the person in charge of your file, an employee or a manager.

To reach us, please check your documents for the appropriate contact information.

You can also call
1-514-286-3100
1-800-361-6840

14.2 If you are dissatisfied with the response you receive, you may contact Desjardins Group Chief Privacy Officer at:

Office of the Chief Privacy Officer
100 rue des Commandeurs
LEV-100-6e-A
Lévis, QC G6V 7N5
cpo@desjardins.com

Please include your name and contact information, your reason for contacting us, the name of the department or person you dealt with and any other relevant information.

If you wish, you can also contact the appropriate provincial or federal privacy agency.

15. Changes to the Policy

The Company reserves the right to amend this Policy at any time. New versions of the Policy will be available upon request from the Company. The Company encourages clients to check its website regularly to ensure that they're aware of the latest version of this Policy at all times.