Quebec Privacy Notice

Effective date: September 2023

At PIMCO Canada Corp. (“Pimco Canada” or “we”), we consider privacy to be a fundamental aspect of our relationship with our current, former and prospective clients, and other individuals whose information we collect.  Some of this information may be considered “personal information” under applicable law.  For the purposes of this notice “personal information” means information that relates to an identifiable individual and/or allows an individual to be identified, directly, or indirectly, and, for greater certainty, includes without limitation, any information defined or deemed as such pursuant to applicable privacy laws.  To ensure the privacy, confidentiality, and security of this personal information, PIMCO Canada has developed an Information Oversight Program (the “Program”) and policies that are summarized in this Personal Information Privacy Notice (the “Notice”).  One or more of our privacy policies may apply to you depending on your relationship with us. 

Table of contents

1. Roles and Responsibilities
2. Overview of the Personal Information We Collect About You, How We Collect It, and Who We Share It With
3. Transfer of Personal Information Outside of Quebec and Canada
4. Retention of Personal Information
5. Security of Personal Information
6. Changes to our privacy notice
7. Contact Us
8. Your Rights and Complaint Handling
9. Complaints Handling Procedure

1. Roles and Responsibilities

In instances where we process your personal information, PIMCO Canada is responsible for ensuring that it uses your information in compliance with applicable privacy and security laws and regulations.  To ensure its compliance with such laws, PIMCO Canada and PIMCO’s entities that are based outside of Canada (“PIMCO” or “PIMCO Group”) have set out the following governance structure:

Responsibility for the Program rests with PIMCO Canada’s President, who has delegated oversight and maintenance of the Program to PIMCO Canada’s Privacy Officer and Vice President of Compliance.  The Program incorporates policies, procedures and controls designed to protect and safeguard personal information. PIMCO has a Global Data Privacy Manager who is responsible for the design, development, and implementation of PIMCO’s global data privacy program and is supported, where applicable, by Local Data Privacy Officers, including PIMCO Canada’s Privacy Officer, in the implementation and administration of the program. 

Depending on your relationship and interactions with PIMCO, the responsibility for the handling of your personal information may rest with one or more Information Owners who are the heads of internal business units that create or initiate the creation or storage of personal information. Each Information Owner shall, to the extent that it relates to the Information Owner’s sphere of responsibility, take steps reasonably designed to ensure compliance with PIMCO’s privacy requirements.

2. Overview of the Personal Information We Collect About You, How We Collect It, and Who We Share It With

We collect, use, and share your personal information in a variety of ways.  For a comprehensive description of what personal information we may collect, how we use it, and who we share it with, please refer to PIMCO’S Online Privacy Notice. Here’s a concise summary of our data processing practices for a quick understanding:

We may collect the following personal information from you:

• Information necessary to provide you with requested products and services,
• Employment information to process your application when you apply for a position at PIMCO (e.g., background checks),
• Information about your use of our online services or requests that you make when you visit our website pimco.ca or from other online interactions you may have with us,
• Information about your use of our services and products in order to prevent fraud and money laundering,
• Information necessary to respond to an inquiry you submit to us, for example, when you or a representative acting on your behalf submits an application or other form to us or one of our affiliates via mail, electronically, or by telephone.

Please review PIMCO’S Online Privacy Notice for a detailed list of the personal information we collect about you, how we collect it, and for what purpose.

We may share personal information we collect about you with the following parties:

• With our affiliates.
• With our service providers, business partners and vendors. If we provide your information to service providers, we require that the service providers keep your personal information secure, and only use it for the limited purposes for which it is provided.
• When you request any of our products or services. We will share your information to the extent necessary or appropriate to fulfill your request.
• When required to do so by law. For example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.

In addition, please note that if PIMCO Canada or any of its affiliates, subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger, consolidation, sale or divestiture of assets, the relevant customer database, including personal information we may possess about you, and information collected pursuant to our Online Privacy Notice, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.

Please review PIMCO’S Online Privacy Notice for details on who we may share your personal information with.

3. Transfer of Personal Information Outside of Quebec and Canada

With your consent or when permitted by applicable law, your personal information may be stored and/or processed outside of Quebec and outside of Canada.  In such instances, your personal information may be subject to foreign laws and may be accessible to foreign governments, courts, law enforcement and regulatory agencies. It may also be processed by staff operating outside of Quebec and outside of Canada who work for PIMCO or for one of our service providers.  In these instances, PIMCO has implemented procedures that are designed to restrict access to an individual’s personal information only to the personnel who need to know that information in order to provide products or services.  In order to guard such information, physical, electronic, and procedural safeguards are in place.

Where we transfer your personal information to another jurisdiction (e.g., outside of your province of residency), we will ensure that it is protected in a manner that is consistent with how we protect your personal information in Canada. This can be done in a number of ways, including implementing intercompany agreements if the transfer remains within the PIMCO Group; contractual terms in the case of services providers.

Please review PIMCO’S Online Privacy Notice for details on how we may transfer your personal information outside of Quebec and outside of Canada.

4. Retention of Personal Information

How long we hold personal information will vary.  The retention period for personal information will be determined by various criteria including:

• internal policies that dictate the period for which we hold personal information; and
• legal obligations – privacy and security laws or regulations may set a minimum period for which we have to store your personal data.

We will only hold your personal information for the purposes for which it was initially obtained.

5. Security of Personal Information

We protect and safeguard your personal information using physical, electronic and procedural measures appropriate to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, including safeguards to protect your information against loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Specifically, we implement a combination of security measures to protect your personal information, including:

• Physical, electronic and procedural safeguards that comply with relevant standards to protect personal information;
• If the information is collected or stored electronically, technical safeguards such as encryption, firewalls, passwords, anti-virus software and similar measures;
• Employee training in privacy and information security;
• Procedures for receiving, investigating, and responding to complaints or inquiries about PIMCO’s information handling practices;

We include contractual protections with service providers with whom we share personal information to ensure that they maintain adequate protections and security standards over personal information that they receive from us. For example, we generally require our service providers to limit their use and retention of personal information to that which is necessary to perform their services and to notify us in the event of an actual or suspected confidentiality incident. We also attempt to monitor and verify their compliance with these requirements in a variety of ways (e.g., on-site inspections (where possible), surveys and interviews, proof of certification).

6. Changes to Our Privacy Notice

We keep our privacy notice under regular review. Any changes we make to this notice in the future will be posted on this page.  Please check back frequently to see any updates or changes to our privacy notice.

7. Contact Us

Please contact us if you have any questions about our personal information handling procedures, this notice, or the personal information that we have about you.  It is important that this information remains current and accurate.  As a result, it is important that you notify us on a timely basis of any changes to your personal information:

• write to us at our addresses listed below; or
  PIMCO Canada Corp
  199 Bay Street, Suite 2050,
  Commerce Court Station,
  P.O. Box 363,
  Toronto, ON, M5L 1G2

• contact us by email at: CanadaPrivacy@pimco.com

For queries specific to PIMCO Canada’s Privacy Officer, please mark your query ‘for the attention of the Privacy Officer’.

8. Your Rights and Complaint Handling

PIMCO Canada is committed to maintaining the confidentiality, integrity, and security of your personal information.  We hope the need to complain will not arise, however, if you are dissatisfied with the handling of your personal information, PIMCO Canada takes such concerns seriously and endeavours to promptly respond to and resolve complaints.

Please find below for a summary of our Complaints Handling Procedure.

9.  Complaints Handling Procedure

1. What should you do if you wish to make a complaint?

If you have a complaint, you may contact PIMCO Canada in writing or verbally.  Contact details are as follows:
Address:
PIMCO Canada Corp
199 Bay Street, Suite 2050,
Commerce Court Station,
P.O. Box 363,
Toronto, ON, M5L 1G2
Telephone: 1-866-341-3350

Email: CanadaPrivacy@pimco.com or alternatively by completing the ‘contact us’ form on our website.

2. How will my complaint be handled?

Your complaint will be dealt with by PIMCO Canada in a prompt and fair manner.

3. How will I know that my complaint is being investigated?

PIMCO will promptly issue to you an initial written acknowledgement stating receipt of the complaint.  This will be sent via email or by mail. 

4. What can I expect in response to my complaint?

PIMCO Canada will promptly provide a written response stating the resolution to your complaint, including information on your rights.  Please note, more complex scenarios may require further time to investigate and respond but in all cases PIMCO Canada will endeavour to provide a prompt response and notifications in cases where follow up may be delayed due to complexity or other factors during review.

5. What if I feel that my complaint has not been resolved satisfactorily?

If you are of the view that your complaint has not been resolved satisfactorily, you may ask PIMCO Canada to reconsider the response.  Alternatively, you may contact the Office of the Privacy Commission of Canada or the Commission d’accès à l’information du Québec.

6. What is the Office of the Privacy Commission of Canada (OPC)?

The OPC oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), Canada’s federal private-sector privacy law.

You can find out more about the OPC on their website: https://www.priv.gc.ca/en/about-the-opc/

The OPC can be contacted by mail, telephone, or through an online form, which are all available through the following page: https://www.priv.gc.ca/en/contact-the-opc/contact-the-information-centre/

To file a formal privacy compliant related to the handling of your personal information by PIMCO Canada, the formal filing process can be followed through the following page: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/

7. What is the Commission d’accès à l’information (CAI) du Québec?

The CAI oversees compliance with Quebec’s provincial privacy and access legislation.

You can find out more about CAI on their website: https://www.cai.gouv.qc.ca/english/

The CAI can be contacted by mail, email, or telephone.  Contact details are available through the following page: https://www.cai.gouv.qc.ca/a-propos/nous-joindre/

8. What if I have general questions about the Complaints Handling Procedure?

If you have any questions related to this procedure, you may contact PIMCO Canada in writing or verbally.

Contact details are as follows:
Address:
PIMCO Canada Corp
199 Bay Street, Suite 2050,
Commerce Court Station,
P.O. Box 363,
Toronto, ON, M5L 1G2
Telephone: 1-866-341-3350

Email: CanadaPrivacy@pimco.com