ATB Financial - ATB.COM

Customer Privacy Code

This Customer Privacy Code applies to Alberta Treasury Branches, its agents and its wholly owned subsidiaries, including ATB Securities Inc., ATB Investment Services Inc., ATB Investment Management Inc., and ATB Insurance Advisors Inc. hereinafter referred to for the purposes of this Customer Privacy Code as ATB Financial®.

ATB Financial is committed to protecting your privacy and the confidentiality of your Personal Information. Our commitment to protecting our customers’ privacy is set out in this Customer Privacy Code. ATB Financial's Customer Privacy Code is designed to comply with applicable privacy legislation including Alberta’s Personal Information Protection Act (“PIPA”).
We want you to know:

• Why we collect your Personal Information;
• How we use and disclose your Personal Information in establishing and maintaining your relationship with us;
• How we keep your Personal Information confidential; and
• How you can inquire about your Personal Information.

What is Personal Information?
Personal Information is any information that identifies you as an individual. It includes information that you provide to us or that we collect from other sources with your consent.

Personal Information may include, but is not limited to, your name, address, age, gender, personal financial records, unique identification numbers (including your social insurance number), personal references, or employment records.

Personal Information does not include business contact information used for business purposes.

We collect only the Personal Information we need in order to provide the product and or service you have requested as well as to advise you of other products or services that may be of benefit to you. When we request your Personal Information, you may opt-out of providing us with information that is not essential to your relationship with us or our ability to provide the product and or service to you. Please be advised that in some instances opting-out may prevent ATB Financial from being able to provide you with the product, service or information you have requested.

Using and Disclosing Your Personal Information
We require Personal Information from you in order to conduct business with you. Your request for, or use of, ATB Financial products and services is your acknowledgement that ATB Financial may use your Personal Information for the following:

ATB Financial will treat your Personal Information in accordance with its Customer Privacy Code and any written agreement between you and ATB Financial.

You certify that all Personal Information that you have provided to ATB Financial is true and complete. This certification applies to all Personal Information that you give in the future in connection with any application for products and or services.

You agree to help keep the Personal Information held by ATB Financial up-to-date through prompt notification of changes to your telephone number, address, or other Personal Information.

You consent to ATB Financial, from time to time, collecting Personal Information about you.  ATB Financial may collect your Personal Information from you as well as from any third party, including any credit reporting agency, personal information agent, insurance company, other financial institution, other credit grantor, and your current or former employer or any other person, corporation, organization, society or other entity.  Where applicable, ATB Financial may also collect your motor vehicle information from Alberta Registries (or any other provincial government department having jurisdiction in that area).

ATB Financial may use your Personal Information as follows:

a. To give it to credit reporting agencies, mortgage insurers, and other financial institutions provided they comply with PIPA or applicable privacy legislation, or where ATB Financial is required or permitted to do so by law;

b. To assess your initial and on-going eligibility for ATB Financial products and services you request;

c.  For any purpose related the provision of services you requested from ATB Financial.  ATB Financial may also give it to any third party contracted with or for ATB Financial, but only as needed for the provision of those services and provided they comply with PIPA or applicable privacy legislation;

d. To comply with legal and regulatory requirements. This may include income tax reporting, investigations pursuant to legislation and or law enforcement, or disclosure to self-regulatory organizations including Mutual Fund Dealers Association, the Investment Dealers Association, and regulatory authorities including the Alberta Securities Commission, and the Alberta Insurance Council (“Regulatory Bodies”). The Regulatory Bodies may use and disclose your Personal Information for investigation and enforcement purposes;

e. To confirm ownership or description of any collateral;

f.  To service, monitor or maintain your account;

g. To understand your needs and to offer other products and services to meet these needs;

h.  To report any account irregularities to any credit reporting agency; and

i.  To provide you with notices that serve the interests of customers of ATB Financial.

ATB Financial may on occasion contract with third parties or agents outside Canada for the purposes of managing your relationship with us, and or the products or services you request. Personal Information in the custody and control of a third party or agent in another province or country is subject to the laws of that jurisdiction.  As such your Personal Information may be collected, used, or disclosed without your knowledge or consent, or where required or permitted by law.

Marketing and Other Personal Information Use
ATB Financial may also use your Personal Information for the following purposes:

a. To assess your initial and on-going eligibility for products and services of ATB Financial;

b. To promote ATB Financial, or third party products and services;

c. To give it to third parties so it can promote products and services of ATB Financial, or the third parties;

d. To give to third parties contracted with or for ATB Financial so they can promote additional products and services to you; and

e. To use your social insurance number as an aid to identify you with credit reporting agencies and other financial institutions for credit history file matching purposes.

Where your relationship with us is governed by securities law, regulatory requirements, or contract, your express consent (meaning your written or verbal consent) may be required for the uses identified in points (a) to (e) above.  Where applicable ATB Financial will obtain your express consent.

If you are no longer a customer of ATB Financial or this Agreement terminates, ATB Financial may keep your Personal Information in its records for as long as it is needed for the purposes described above under “Using and Disclosing Your Personal Information” as well as to meet any and all legal, legislative and regulatory requirements.

ATB Financial will ensure you are aware of the purposes for which we collect and or use your Personal Information and with whom we may disclose the Personal Information when you apply for a product and or service.  Self-evident purposes should be clear.  However, if you have any questions, please ask us.  If a new purpose (not outlined in this document) for using your Personal Information develops, we will notify you, obtain the required consent or provide you with an opt-out option if applicable, prior to using your Personal Information.

Some of the products and or services ATB Financial offers are operated in cooperation with the provincial or federal government, municipalities and contracted third parties. In such cases, our contract with those entities usually requires that we share with them Personal Information we collect with respect to that particular product and or service. Personal Information we collect with respect to products and or services offered in cooperation with those entities is governed in accordance with applicable privacy legislation and where applicable, rules of the Regulatory Bodies.  If you wish to access your Personal Information, our Privacy Officer will direct you to the appropriate office and legislation.

Limiting or Withdrawing Your Consent
You may choose to not to provide ATB Financial with some or all of your Personal Information, or withdraw your consent for ATB Financial to use your Personal Information for marketing communications regarding products and or services as outlined above under “Marketing and Other Personal Information Use”. You should know that not providing certain Personal Information may result in ATB Financial not being able to provide you with products and or services you have requested.

Subject to where your relationship with us is governed by securities law, regulatory requirements, or contract, you may request that ATB Financial not use your Personal Information in the ways described above under “Marketing and Other Personal Information Use” at any time as long as:

a.  There are no legal requirements for ATB Financial to use your Personal Information;

b.  Withdrawing your consent does not result in our inability to fulfill your Agreement with us; and

c.  You give ATB Financial notice by:
     i.   Completing the secure online opt-out form at www.atb.com/optout
     ii.  Calling the Customer Contact Centre at 1-800-332-8383; or
     iii. Contacting your branch directly

It is important to note that withdrawing your consent will not preclude ATB Financial from providing you with notices, directly or via a third party, that ATB Financial believes serve the best interests of ATB Financial customers as it relates to your portfolio with us.

Accessing Your Personal Information
If you want to review or verify your Personal Information or find out to whom we have disclosed it, please write, our Privacy Officer by using the contact information noted at the end of this document. Our Privacy Officer may forward to you an access request form to fill out and return, which will provide us with the details we need in order to search for, and provide you with the Personal Information ATB Financial may hold about you.  ATB Financial may charge you a reasonable fee for your request, however; we will provide you with an estimate in advance.

There are a few instances, as outlined in applicable privacy legislation, including PIPA, where ATB Financial may not be able to provide you with some of the Personal Information we hold about you.  These include, but are not limited to, situations where the information contains references to other persons, the information is subject to solicitor-client privilege, the information is no longer retained by us, or the information cannot be disclosed for legal, enforcement or investigative reasons.  If we are unable to provide you with access to your Personal Information, we will explain the reason(s) why.

Keeping Your Personal Information Accurate
We are committed to maintaining the accuracy of your Personal Information for as long as it is being used for the purposes we have identified. To help keep your Personal Information accurate, up-to-date and complete, we encourage you to notify us of any changes. Notification of changes to your contact information including your name, address, telephone and or email information will help us provide you with the best possible service.

If, upon review of your Personal Information you discover any inaccuracies, please contact our Customer Contact Center at 1-800-332-8383 at your earliest convenience.

Request To Correct Personal Information
Where your request to correct your Personal Information requires formal processing under applicable privacy legislation including PIPA, ATB Financial may ask you to put your request for correction in writing, or to complete a form provided by our Office.  We will ensure the requested changes are reviewed, and where applicable will provide you with a copy of the corrected information, or the reasons for non-correction.  ATB Financial will also use our best efforts to inform third parties to whom we have disclosed the information of any relevant corrections.  If we do not agree to make the corrections you requested, we will record your request along with an explanation of why were not able to make the requested correction.

Complaint Resolution Process
ATB Financial has a complaint resolution process should issues arise respecting the collection, use and disclosure of your personal Information.  Please contact your branch directly with respect to any such issues.

Protecting Your Personal Information
Our employees are responsible for maintaining the confidentiality of Personal Information to which they have access.  As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility, which governs their actions, even after we no longer employ them.

We keep our employees informed about our policies and procedures for protecting Personal Information and reinforce the importance of complying with them. Our employees are also required, as a condition of employment to comply with these policies and procedures.

We endeavor to maintain adequate physical, procedural and electronic security with respect to our offices and information storage facilities to prevent unauthorized access, use, or disclosure, or destruction of your Personal Information.

Third Party Contracts
The safeguarding and security measures we employ to facilitate business resiliency include, but are not limited to, the use privacy impact assessments for new initiatives impacting Personal Information, secure locks on filing cabinets and doors, confidential destruction of in-active information, limited physical and electronic access to relevant information by only authorized employees, the use of passwords for system access.  All Personal Information stored in our computer database is protected with levels of security appropriate to the sensitivity of the Personal Information and the need for the employee to have access, to better serve you as our customer.

Visiting ATB Financial's Website
When you visit ATB Financial's website, and move from page to page, our web server may collect information about how you accessed our website, including pages visited, what content is downloaded, and sites immediately visited before coming to our website. This information is measured only in aggregate for general statistics and is not associated with you as an individual.

When you register for one of our Internet services, such as ATBOnline®, we compile a profile of you for that service, including, but not limited to; name, address, phone number, account number, login ID. Each time you use our Internet services, information about the transactions you complete and the information pages you visit are collected in order to confirm you as a user and ensure quality customer service.

Small files containing specific pieces of information that a website creates when you visit a site are known as Cookies.  Cookies can track how and when you visit a website, be used to recognize you on subsequent visits, and make your on-line experience more convenient.  ATB Financial’s Internet transaction services may not function if you do not accept the use of cookies.

Retention of your Personal Information
We will only keep your Personal Information for as long as we need it in order to meet the purposes for which it was collected. The length of time we retain your Personal Information varies, depending on the nature of your relationship with us, the type of program and or service, and regulatory or legal requirements we may be required to meet. We have policies in place that govern the destruction of the Personal Information we hold and no longer require.

Summary
We take our responsibility to respect and protect your Personal Information seriously.

If you have any questions about the Customer Privacy Code or our privacy practices, or if you would like to review your Personal Information, please contact our Customer Contact Center by calling 1-800-332-8383, or formally submit a privacy complaint by writing to the ATB Privacy Officer at 9888 Jasper Avenue, Edmonton, Alberta, T5J 1P1.

ATB Financial will review the Customer Privacy Code and Customer Privacy Brochure regularly to ensure that they continue to meet our obligations to you, the people we serve.  ATB Financial reserves the right to add, modify or remove all or part of this document at any time.

* ATBOnline^® and ATB Financial^® are registered trademarks of Alberta Treasury Branches

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