At Pleco Capital, we understand that privacy is an important issue for all our clients. This policy
outlines the principles Pleco Capital applies when protecting clients’ privacy. This policy outlines
the principles and commitments we make to you, our client, to protect the privacy of your
This policy does not apply to the information collected, used or disclosed with respect to
corporate or commercial entities that are clients. However, Pleco Capital exercises the same
care and diligence in protecting the confidentiality of this information.
1. Pleco Capital is accountable for the protection of clients’ personal information. While senior
management is ultimately accountable for the protection of personal information, the day-to-day
monitoring for compliance may be delegated to other staff.
2. Pleco Capital is committed to ensuring that the appropriate security measures are employed
in the transfer of sensitive information. However, when using e-mail or wireless communication,
Pleco Capital advises clients that complete confidentiality and security are not assured.
3. Pleco Capital is not accountable for any damages suffered when a client transmits personal
information through e-mail or wireless communication or when Pleco Capital transmits
information at the request of the client.
4. Pleco Capital has developed policies and procedures to: protect personal information; receive
and respond to complaints and inquiries; train staff regarding the policies and procedures;
communicate the policies and procedures to our clients.
5. Pleco Capital collects client personal information for the following reasons only:
To provide financial services;
To understand their clients’ financial needs;
To facilitate the offering of third party complimentary products or services;
To broker and administer mortgage & loan agreements;
To develop, manage and deliver products and services to clients;
To develop and deliver marketing and promotional offers to clients;
To determine client eligibility for different products and services;
To ensure that clients receive a high standard of service;
To meet regulatory requirements;
To manage and transfer the assets and liabilities of Pleco Capital and those assets under its
To verify client’s identity.
Pleco Capital will only collect personal information for the purposes identified. Pleco Capital will
use methods that are lawful and will not collect information indiscriminately. Pleco Capital will
not use personal information for any additional purpose unless Pleco Capital seeks client
consent to do so.
6. Pleco Capital will obtain client consent to collect, use or disclose any personal information
except where detailed in this policy. Pleco Capital will make reasonable efforts to ensure that
clients understand how their personal information will be used and disclosed.
7. A client’s consent can be express, implied, or given through an authorized representative
such as a lawyer, agent or broker. Consent may be given orally, in writing, or electronically. For
example, depending on the sensitivity of the information, consent can be expressed over the
telephone when information is being collected; electronically when submitting an agreement,
application, or other information; in writing when signing an agreement or application form.
Implied consent exists when Pleco Capital can reasonably infer consent based upon the action
or inaction of the client.
8. Pleco Capital, however, may collect, use or disclose personal information without the client’s
knowledge or consent in exceptional circumstances:
When such collection, use or disclosure is permitted or required by law
When certain information is publicly available
When we require legal advice from a lawyer
When we need to collect a debt from a client
When we need to deal with an anticipated breach of law
When potential investors/stakeholders wish to ensure the quality and characteristics of an
9. Subject to contractual or legal arrangements, clients may withdraw or refuse consent
provided that Pleco Capital is given reasonable notice. Pleco Capital may decline to deal with a
client or person who will not consent to the use of such information.
10. Pleco Capital may periodically use client personal information to conduct client surveys in
order to enhance our provision of services or products. If an outside body is employed to
conduct research on behalf of Pleco Capital, or provide other services that require access to
client information, Pleco Capital will ensure that appropriate security undertakings, such as
confidentiality clauses in contractual arrangements, are employed to protect the transfer and
use of personal information.
11. Pleco Capital will retain client personal information only as long as necessary or expected to
be necessary for the identified purposes, or as required by legislation.
12. Pleco Capital may disclose personal information related to a financial asset of Pleco Capital
along with transfer of the financial asset.
13. Pleco Capital will make reasonable efforts to ensure that client personal information is as
accurate. In some cases, Pleco Capital relies on its clients to ensure that certain information,
such as the client’s address or telephone number, is current, complete, and accurate.
14. Pleco Capital will not routinely update information unless it is necessary to fulfill the
purposes for which it was collected or if it is required to maintain an active account.
15. Pleco Capital is committed to the safekeeping of client personal information in order to
prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification, and will
employ appropriate security measures to protect the information. The measures may include,
for example, the physical security of offices and data, and electronic security measures such as
passwords and encryption where appropriate.
16. Pleco Capital will use appropriate security measures when disposing of client personal
17. The development of Pleco Capital’s policies and procedures for the protection of personal
information is an ongoing process. Changes in technology necessitate that Pleco Capital
continually develops, updates, and reviews information protection guidelines and controls to
ensure ongoing information security.
18. Pleco Capital will make the following information available:
• The name, title and address of the person accountable for the policies and procedures and to
whom complaints or inquiries can be forwarded;
• A description of the type of personal information held by Pleco Capital, including a general
account of its use;
• A copy of any brochures or other information that explain the policies and procedures; and
An explanation of what personal information is made available to affiliated companies or
19. Clients have a right to access their personal information held by Pleco Capital. Upon
request, Pleco Capital will, within a reasonable time period, tell the client what personal
information it has, what it is being used for, and to whom it has been disclosed if applicable and
within the time period for which records are available.
20. Clients may be asked to be specific about the information they would like to access and to
submit their request in writing to Pleco Capital.
21. Clients will be required to provide personal information to identify themselves to enable
Pleco Capital to provide an account of the existence, use, and disclosure of personal
22. Pleco Capital will make the information available within 30 days, or provide written notice of
extension where additional time is required to fulfill the request. When information is not
provided within 30 days of the request, Pleco Capital will, no later than 30 days after the date of
the request, send a notice of extension to the client, advising of the new time limit, the reasons
for extending the time limit and of the right of the client to make a complaint regarding the
23. If a request is refused, Pleco Capital will notify the client in writing, documenting the reasons
for refusal and resources for redress available to the client.
24. The information will be made available at a cost that will vary with the type and amount of
information requested. Where the client will incur a cost, Pleco Capital will inform the client of
the cost and request further direction from the client on whether or not Pleco Capital should
proceed with the request.
25. In certain situations, Pleco Capital may not be able to provide access to any or all personal
information about a client. In such cases, Pleco Capital will explain the reasons it will not
provide the requested information, and identify resources for recourse available to the client.
The reasons for not providing information may include that it is unreasonably costly to provide,
information that would threaten the life or security of another individual, information generated in
a formal dispute resolution process, information that contains references to other individuals,
information that cannot be disclosed for legal, security, or commercial proprietary reasons, and
information that is subject to solicitor-client or litigation privilege.
26. If the information is demonstrated to be inaccurate or incomplete, Pleco Capital will amend
the information as required. Where appropriate, Pleco Capital will transmit the amended
information to Third Parties having access to the information in question.
writing to the Compliance Officer. At any point in this process the client may also write to the
28. Clients may withdraw consent at any time, subject to legal or contractual restrictions,
provided that reasonable notice of withdrawal of consent is given to the Pleco Capital. On
receipt of notice of withdrawal of consent, Pleco Capital will inform the individual of the likely
consequences of the withdrawal of consent, which may include the inability of Pleco Capital to
provide certain products or services, if the information is necessary to provide the products and
29. To improve the usability of our website at www.plecocapital.ca, we capture information about
how users interact with our site and what pages they visit. No personal information is collected
as part of this process. The data we collect is used internally to better understand and support
Pleco Capital Inc., Attention Compliance Officer
141 – 1140 Burnhamthorpe Rd W
Mississauga, ON, L5C 4E9
Office No: 1-844-753-2622