The International Investment Funds Association Privacy Policy

INTRODUCTION

The International Investment Funds Association (referred to as “IIFA,” “we,” “us,” or “our” in this Privacy Policy is an association based in Canada with membership of approximately 40 national and regional investment fund associations from around the globe. Members of IIFA collectively represent managers holding more than US$50 trillion in assets at the end of the second quarter of 2019.
Please read this Privacy Policy carefully and contact us if you have any questions about our practices regarding the handling and protection of personal information or your personal information choices.

IMPORTANT INFORMATION ABOUT THIS PRIVACY POLICY

Purpose

This Privacy Policy sets out how IIFA collects and processes your personal information as you interact with us, including through your use of our website and any data you may provide through our website, in connection with membership, associates, our operations, activities and events (such as conferences) and IIFA publications, including IIFA’s news releases.

It is important that you read this Privacy Policy together with any other privacy notice or notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Changes to the Privacy Policy

This version is effective as of March 9, 2020.

If we make changes we consider important, we will place a notice on our website.

Third-Party Links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website by clicking on a link for a third party website, we encourage you to read the privacy notice of that website.

WHAT IS PERSONAL INFORMATION?

Personal information means any information relating to an identified or identifiable natural person. In general, under Canadian privacy legislation, personal information does not include business contact information (such as an employee’s name, title, business address, telephone number or email addresses) that is collected, used or disclosed in order to communicate with that person in relation to their employment or profession.

What Information do we collect about you?

We generally limit the information we collect and use to your business contact information and your preferences regarding our communication with you so that we can properly manage our relationship with you.

We may collect the following information about you:

• name (first name and last name)
• business address
• business telephone number
• business email address
• job title
• association name

When you visit our website, we also collect:

• information about your computer, including your IP address, the type of operating
• system and browser you use and your computer’s location;
• what pages you visit on our site and what links you click on; and
• what other sites you have visited recently.

ACCOUNTABILITY

IIFA is committed to the responsible handling and protection of personal information. This Privacy Policy provides information about how IIFA handles and protects personal information and how we look after personal information when you visit the iifa.ca website (regardless of your location) and otherwise interact with us.

IIFA’s Corporate Secretary is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights regarding the processing of your personal information, please contact IIFA’s Corporate Secretary using the details set out below.

Our full details are:

Full name of legal entity: The International Investment Funds Association
Name or title: Corporate Secretary
Postal address: 4th Floor, 11 King Street West, Toronto, Ontario M5H 4C7
E-Mail: privacy@IIFA.ca

HOW DO WE COLLECT INFORMATION ABOUT YOU?

We collect this information in a number of different ways, including from individuals who:

• use our website;
• are associated with a current IIFA member or associate, including through participation in one of our committees; and
• are associated with potential or current suppliers and vendors.

HOW WE USE INFORMATION ABOUT YOU

We collect information about you for the primary purpose of providing our services, including for the following purposes:

• to establish and manage our relationships with our members;
• where we need to perform the contract we are about to enter into or have entered into with you or your employer, including to issue invoices, administer accounts, collect and process payments and
• otherwise fulfil our contractual obligations;
• to contact and communicate with members and other individuals for the purpose of conducting market research;
• to distribute our publications and invitations to conferences and events to members and associates;
• to develop and manage our business and operations, including participation in one of our committees; and
• as permitted by, and to comply with, applicable legal or regulatory obligation.

If it is a necessary part of our relationship with you, we may disclose your information to another company. For example, we may pass on your name and address to a courier company to complete a delivery. We will only disclose that information which is necessary to provide our services to you.

IIFA Events and News

We use the contact information of individuals who subscribe for our services by invitation from IIFA representatives. Distribution of our publications and event marketing draws on a contact database of primarily business contacts that may also include individuals.

We may send email communications to individuals in our database to advise of industry developments, distribute our publications or to advise of upcoming IIFA events. Each email contains an opt-out feature and instructions on how to unsubscribe or change your email preferences.

Cookies

Cookies are data that is placed on your device when you visit a website in order to track use of the site and improve your user experience. IIFA may, from time to time, collect personal information about you and your use of our website with cookies as set out in section 3 above.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Service Providers

If we enter into arrangements with service providers or contractors to store, handle or process personal information on our behalf, such as for processing, storage, software support and office services, we will require such third parties by contract or otherwise to provide privacy protection that is substantially similar while the information is being processed or handled by them.

Consent

We obtain consent to the collection, use and disclosure of personal information where required by applicable privacy legislation. We assume consent to our collection and use of personal information for the purposes for which the information is given when you initiate contact with us or voluntarily provide personal information to us, including by providing your business card to IIFA representatives.

We obtain the oral or electronic consent of individuals who subscribe to our publications or who indicate an interest to IIFA representatives in receiving such materials. As set out under IIFA Events and News above, we provide an opt-out opportunity.

DISCLOSURES OF YOUR INFORMATION

IIFA shares or discloses information we collect about you when necessary for the purposes set out in Section 6 above. When we share personal information, we do so in accordance with applicable law. Below are the parties with whom we may share personal information and why we share it:

We may share your personal information with our other members or third parties in the context of the management of IIFA or its operations.

• From time to time we may collaborate with other organizations in order to carry out our business activities. Occasionally, these arrangements may involve our sharing your personal information with the organization in question.
• We engage third-party service providers for various services including IT, administration, consultancy, banking, legal, insurance, and accounting services.

We will share personal information when we believe it is required, such as:

• to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
• in the event of a disposal of our assets or our business (or any part thereof) (including in connection with any bankruptcy or similar proceedings); and
• to protect our rights, privacy, safety, or property, or those of other persons.
  

INTERNATIONAL TRANSFERS

We share your personal data within IIFA. Where your data originates inside the European Economic Area (EEA), the transfer of your personal data within IIFA may involve transferring your data outside the EEA, for example, to members or external third parties based outside the EEA.

Whenever we transfer personal data that originates inside the EEA out of the EEA, we implement one of the following mechanisms:

• We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• We may transfer your personal data out of the EEA where you have given your explicit consent to us to do so, after having been informed of the possible risks to you of such transfer because:
  • the jurisdiction to which it is proposed to transfer your personal data is not deemed to provide an adequate level of protection for personal data by the European Commission, and
  • there are no safeguards in place to protect your personal data.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the EEA.

INFORMATION SECURITY

We have put in place appropriate security measures to prevent information about you from being used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your information to those representatives, agents, contractors, and other third parties who have a business need to know.

Our security policies include:

• measures to protect against unauthorized access, use, destruction, or disclosure of personal information;
• appropriate measures and controls, including monitoring and physical measures, to store personal information securely;
• training and informing representatives: We train our representatives on their privacy and information security obligations so that they are informed about their responsibilities; and
• third-party risk management: We require any third-party service providers with whom we share personal information to protect such personal information in accordance with commercially acceptable security policies and procedures.

We have put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL IIFA USE INFORMATION ABOUT ME?

IIFA will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal requirements.

When we no longer need personal information, we seek to securely delete or destroy it.

ACCESS TO YOUR INFORMATION

We will give you access to your information upon request, subject to any relevant legal requirements and exemptions.

To maintain appropriate contact information and preferences, we may ask you to update your information from time to time. We encourage you to contact us to correct or amend your personal information if it is inaccurate or requires updating.

If you have any questions about how IIFA manages information about you, please contact us at the contact information set out in Section 4 above.