PRIVACY POLICY
INTRODUCTION
The Royal Canadian Mint's Canadian Gold Reserves and Canadian Silver Reserves Programs are precious metals investment vehicles, in the form of receipts, that track the price of gold and silver respectively and make investing directly in physical precious metals available to institutional and retail investors. The exchange traded receipts ("ETRs") are listed and traded on the Toronto Stock Exchange (the "TSX"), like any other exchange-listed securities.
Each Gold ETR and Silver ETR represent an undivided beneficial interest in bullion to be held in custody by the Mint on an unallocated basis. The bullion will be beneficially owned by the investors. Each Gold ETR is expressed as a fraction of one fine troy ounce of gold as of the issue date, reduced daily by the Service Fee at the rate of 0.35% per annum. Each Silver ETR is expressed as a fraction of one troy ounce of silver as of the issue date, reduced daily by the Service Fee at the rate of 0.45% per annum. Investors can also redeem, on a monthly basis, their ETRs for gold or silver bullion (as applicable) or cash, subject to fees, upon delivery of a Notice to Redeem.
This Privacy Policy details how the Mint collects, uses, shares and protects that personal information within the context of the Canadian Gold Reserves and Canadian Silver Reserves Programs. It complements the Mint's Privacy Policy, which can be read at http://www.mint.ca and is located at the bottom of each page.
THE ROLE OF THE MINT
The Mint's role is to manage, promote, sponsor and act as custodian for all the physical precious metals represented by the listed receipts. The Mint would, at no time, own the precious metal bullion represented by the receipts.
A third party acts as an escrow agent for investors' brokers to ensure that the mechanics of the Reserves Programs function smoothly and efficiently.
APPLICATION OF CANADIAN GOLD RESERVES AND CANADIAN SILVER RESERVES PROGRAMS PRIVACY POLICY
The Mint's Canadian Gold Reserves and Canadian Silver Reserves Privacy Policy only applies to the activities of the Mint as they relate to these programs.
LEGAL AUTHORITY AND REQUIREMENTS
Subsection 4(1) of the Royal Canadian Mint Act constitutes the general authority for the conduct of the Mint's operations, including the collection of personal information for the Canadian Gold Reserves and Canadian Silver Reserves Programs.
The Mint is subject to the Privacy Act, which is the federal Act that governs the collection, use, protection, disclosure/sharing, retention and disposition of personal information by federal government institutions. Generally, this means that we can only:
- collect the personal information about you that we absolutely need to serve you well and to meet our legal obligations;
- use that personal information only for the purposes that you have authorized and those by law;
- disclose your personal information under the following circumstances:
- with your fully informed and explicit consent; and
- to meet our legal obligations, as described later in this document.
COLLECTION OF PERSONAL INFORMATION
Circumstances that involve the collection of your personal information include:
- when you voluntarily provide your e-mail address on the Mint's website for the Canadian Gold Reserves and Canadian Silver Reserves Programs for the purposes of receiving updates from the Mint on these programs;
- when you contact the Mint and elect to redeem an ETR whereby you will be taking physical delivery of the precious metal directly from the Mint. To do so, you must send a completed redemption form to your broker, who will then proceed in forwarding the form to the Mint via e-mail, facsimile or by mail. In the form, you will be required to provide the Mint with the following personal information in order for the Mint to prepare your physical redemption shipment order, and which the Mint will use to validate your identity when you will contact the Mint directly to make final arrangements for the redemption:
- First and last names
- Address
- City
- Province
- Country
- Postal code
- Amount to be redeemed
- any other circumstances where you choose to share your personal information with one of our employees.
Depending upon the type of activity or interaction that we have with you, your personal information may be collected by telephone, regular mail, email or via our secure website.
We periodically analyze the emails that we receive to determine trends in information requested, which is specifically used to revise our website as necessary to help customers obtain information that they are looking for faster. Your email address is never used during this analysis and we will only contact you about the Reserves Programs with your explicit consent at the time of providing your e-mail address, where you have indicated that you agree to providing your e-mail address to the Mint, and that you consent to receiving updates from the Mint about these programs.
USE OF YOUR PERSONAL INFORMATION
We only use your personal information for the following purposes:
- to send you updates on the Reserves Programs via e-mail, where you have consented for the Mint to do so;
- to process your physical redemptions.
- in an anonymous fashion, to:
- manage, develop and improve our business and operations; and
- develop services and promotional offers that meet your needs.
In all other circumstances, we will always seek your express consent prior to using your personal information for a purpose other than those listed above.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not sell your personal information, and we only disclose whatever information is necessary to third parties under the following circumstances:
- to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC) in accordance with the requirements of Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act and supporting Guidelines;
- as required by other Acts of Canada's Parliament, including Canada's Income Tax Act ; and
- at your specific request or with your fully informed consent, depending on the circumstances that may require occasional disclosure.
In all other circumstances, we will always seek your express consent prior to disclosing your personal information to a party other than those listed above.
ACCURACY OF YOUR PERSONAL INFORMATION
The Mint exercises diligence in assuring that the personal information under its control remains accurate, up-to-date and complete; however, it is your responsibility to inform the Mint of any changes to your information and to any error that you may notice when reviewing your information or conducting a physical redemption.
PROTECTION OF YOUR PERSONAL INFORMATION
We recognize that the personal information that you share with us is very personal and sensitive, and for this reason, we apply the highest standards possible in regard to its protection. Access to your personal information is limited to those employees at the Mint who have a strict need to know, and we implement sound security measures to protect it from unauthorized access, use, modification and destruction.
That said, you are entirely responsible for the protection of your personal information that is physically or electronically in your possession or under your control, and the Mint takes no responsibility for any security or privacy breach that may occur while the personal information is outside its control.
Thus it is of the utmost importance that you exercise caution when providing personal information electronically. More specifically, you should take adequate precautions to protect your personal information from unauthorized access, use, modification and destruction. It is also your responsibility to inform the Mint immediately of any real or suspected breach of your privacy so that measures can be taken to restrict access to your information.
RETENTION AND DISPOSITION OF THE PERSONAL INFORMATION
The description of the Personal Information Bank for the Canadian Gold Reserves and Canadian Silver Reserves Programs, currently under development, specifies the retention period for the personal information that will be collected for the purpose of these programs, which will be six years after all administrative actions are completed.
Due to legal requirements, it is not possible for the Mint to destroy or otherwise dispose of your personal information before the end of the scheduled retention period.
MODIFICATIONS TO THIS PRIVACY POLICY
The Mint reserves the right to change this privacy policy at any time, without notice or liability to you or any other person, by posting a new privacy policy on the Mint's website. Our collection, use and disclosure of your personal information will be governed by the version of the privacy policy that is posted and in effect at that time.
RIGHT OF ACCESS AND RIGHT TO REQUEST CORRECTION
In accordance with the Privacy Act you have the right to request access to all the personal information that the Mint keeps about you as well as the right to request the correction of that personal information. You can do so by completing the Personal Information Request Form available on the Treasury Board Secretariat of Canada website (http://www.tbs-sct.gc.ca/tbsf-fsct/350-58-eng.asp) and send it to:
Access to Information and Privacy Coordinator
Royal Canadian Mint
320 Sussex Drive
Ottawa, Ontario K1A 0G8
Telephone: 613-993-2711
The Mint has thirty days to respond in writing to your request, and there are no fees for requesting access to your personal information.
Any questions, comments, concerns or complaints regarding the administration of the Privacy Act and the Mint's privacy policies may be directed to the Mint's Access to Information and Privacy Coordinator at the address noted above. If you are not satisfied with our response to your privacy concern, you may wish to contact the Office of the Privacy Commissioner at the following address:
The Privacy Commissioner of Canada
Tower "B", Third Floor, Place de Ville
112 Kent Street, Ottawa, Ontario K1A 1H3
Telephone: 1-800-282-1376
613-947-1698
Facsimile: 613-990-4665
Email: info@priv.gc.ca
Website: http://priv.gc.ca
DO YOU HAVE QUESTIONS?
We invite you to contact us for any questions related to the Canadian Gold Reserves and Canadian Silver Reserves Programs Privacy Policy or regarding the Mint’s privacy protection program in general by writing to the Mint’s Access to Information and Privacy Coordinator at the address indicated in the previous section.