Privacy Policy

For individuals, personal information includes details such as your name; contact information (address, phone number, email etc.); information from an acceptable identification document (e.g.: driver’s licence, passport) such as date of birth, age, and signature; marital status, financial details, employment history, trading history, social insurance number (social security number if American, or other tax identification number if corporation or from another jurisdiction), reasons for engaging in business with us, language and communication preferences. Moreover, it encompasses information about your operations, including transaction history, account interactions, investment preferences, financial goals, risk tolerance, and credit history. If applicable, we may also require personal information about your spouse/partner, such as their name, employment details, and financial situation, as well as information about your account beneficiaries and trusted contact person(s) if any exist.

For business clients, private information encompasses the aforementioned data, along with tax identification numbers, officer and director names, beneficial owner details, ownership structure, shareholder information, financial particulars, and jurisdiction of incorporation.

In addition to the aforementioned data collection, Dorchester maintains internal records related to communication history with each client, whether written or verbal. These notes aid our portfolio managers in gaining a better understanding of your investment requirements and assisting you in achieving your financial objectives.

Dorchester collects personal information from you during your communications or interactions with us, as well as when you provide updates to your account details. This collection serves the purpose of establishing and managing your account(s), and it aligns with the Know-Your-Client (KYC) regulations of our industry. The obtained personal information will be utilized to gain insight into your financial requirements and to ensure adherence to the legal mandates imposed by the regulatory authorities.

We may also gather your information indirectly from other sources listed below (in cases where it is required, we will ensure to obtain your consent):

• Other individuals associated with your products and services;
• Brokers, dealers or other stakeholders in securities or related fields;
• Credit reporting agencies;
• Publicly available sources or records;
• Regulatory bodies and self-regulatory organizations;
• Custodians;
• Content generated through our website and social media platforms.

If you provide us with information about another individual, we will presume that you possess the requisite authorization to do so, and that you have obtained that individual’s consent for the collection, use or disclosure of that information for the purposes set out in this policy.

Note: Our information collection is confined to the essentials mandated by the securities regulations and what is deemed indispensable to facilitate our effective service to you.

We use your information to:

• Verify your identity, update your information, and verify the accuracy of the information;
• Assess your financial situation and creditworthiness;
• Assess your eligibility for products and services or ensure that the advice, products and services we offer, or you obtain are suitable for you;
• Establish your investor profile, your financial needs and objectives as well as your investment strategies;
• Establish, manage, administer, and provide the products and services suitable for you;
• Conduct research and data analytics to generate statistics, improve our products and services by analyzing the information collected;
• Personalize your client experience, get to know you better and understand your needs, provide you with better advice based on the analysis of your needs and preferences;
• Carry on our business and operations;
• Prevent, detect, and control fraud, as well as any unauthorized or illegal activities (money laundering, cyber threats, etc.);
• Manage risk, including credit and business risks, and comply with applicable laws and regulations;
• Communicate with you using the contact information you provided (by mail, email, text messages, phone calls, social media);
• Use and disclose specific information where we are legally required and authorized to do so.

Dorchester is committed to safeguarding the personal information of its clients and has instituted necessary security measures that are suitable for data protection. The majority of your personal information is contained within your account opening documentation. Digital copies of these documents, alongside other materials containing personal data, may be stored on Dorchester’s server or on cloud-based servers.

Within our computer system, we deploy firewalls, encrypted passwords, anti-virus software, intrusion detection software, file encryption, dual authentication mechanisms, and other appropriate measures to ensure the security of your personal information.

Dorchester fortifies its infrastructure through controlled access to our premises and secure locations for our equipment. Internally, our employees are granted access to your information based on a stringent ‘need-to-know’ principle. This signifies that only employees who require your information to fulfil their responsibilities have access to it.

To effectively manage your account and to fulfil regulatory and legal obligations, Dorchester might need to retain information related to you and your account for a certain period. Personal information will be securely and safely disposed once it is deemed that the information is no longer necessary. Your information could be retained beyond your status as our client, as long as it is legally necessary to maintain sufficient data to address any issues that may arise at a later date.

→ Right to refuse or withdraw your consent to provide your personal information

Your personal information belongs to you. Subject to legal, business, or contractual requirements, you have the right to decline or retract your consent for the collection, utilization, or disclosure of your personal information. At any time, you can refuse or withdraw your consent to use your personal information by reaching out to us through your portfolio manager, and we will promptly address your request.

However, some types of information are essential for us to deliver specific services to you. Should you opt not to share your personal information, it could potentially pose challenges, if not render it impossible, to establish or uphold a business relationship with you or provide some of our services.

Upon withdrawing your consent, you will continue to receive legally mandated account statements and communications. In addition, you can expect ongoing verbal or in-person communications about our services from your dedicated portfolio manager, who bears the responsibility of advising you and supplying essential information as needed.

You may also continue to encounter information about our company and our services on our website or on social media platforms. However, this information will not have been targeted based on the use of your contact information, but rather stem from your agreement to the utilization of cookies and comparable online technologies on specific websites.

→ Right to refuse the sharing of your personal information with third parties

Information obtained when you engage our services is shared with third parties or other service providers only with your consent, unless we are compelled to release information due to legal requirements, a court order, regulatory obligations, a successor trustee, or during a business sale or reorganization. In such circumstances, our approach is to disclose information only to the extent that we are legally required to do so.

We may share your information with:

• Your custodian or different brokers, for compliance purposes and to facilitate the ongoing management of your account(s);
• A party acting for you or at your request (e.g., an individual with Power of Attorney or a special mandate from you or dully authorized Trusted Contact Person);
• An individual holding a joint account with you or otherwise involved in your business association with us;
• Other third parties, in instances where we are required to disclose your personal information during legal proceedings;
• A regulatory or government authority or self-regulatory organization, when requested;
• An individual authorized by law to access such information;
• Service providers we may employ to carry out specific functions such as generating portfolio valuations and maintaining an accurate client and trading database.

You retain the right to decline or revoke your consent for sharing your personal information with our third parties at any point. However, it is important to be aware that opting to share your personal information contributes to enhancing our interaction and association with you, enabling us, among other things, to:

• better serve you;
• have a complete view of all the products you own with your custodian or broker;
• analyse your financial situation to verify your eligibility for certain products and services that are better suited to your investment needs.

→ Right to access your information

You have the option to request access to the information we possess concerning you, except in cases where legal restrictions apply. To review the information we hold, please contact us via phone or discuss this matter with your portfolio manager. We will promptly handle your request within the timelines mandated by law.

→ Right to have your information corrected

You can and are encouraged to rectify any inaccurate information we possess regarding you. Ensuring the accuracy and completeness of your information is essential for delivering a high-quality service. In this regard, we depend on your cooperation to help us maintain the integrity of the data we retain by promptly informing us of any changes. To make a correction please contact us via phone or discuss the matter with your portfolio manager.