At The Laurel Hill Advisory Group, LLC, a fundamental part of our commitment
to deliver exceptional service is protecting your privacy and maintaining the
confidentiality of your personal information. As our range of products and services expand, and
as the technology we use continues to evolve, Laurel Hill will maintain its commitment
to the steps outlined in this statement and to keeping you informed of any changes in
a timely manner.
What is Personal Information?
Personal information includes any factual or subjective information about an
identifiable individual. This may include information such as age, name, and ID numbers but
does not include the name, title, or business address or telephone number of an
employee of an organization. This Privacy Statement applies to the collection, use, and
disclosure of personal information by Laurel Hill.
Laurel Hill’s Collection, Use and Disclosure of Personal Information
Laurel Hill may receive personal information about you if you hold, or held,
securities in a company, or successor company, and that company requests one of our products
and services. This information may come from you or by a party authorized by you,
such as the issuer or their transfer agent, your broker, or your attorney. Laurel Hill
may be instructed by you to assist you in responding to, or participating in, a Proxy
Solicitation, an Asset Recovery Program, or Information Agent campaign where we typically
would receive personal information that could include name, address, social security
number, and securities ownership information.
In providing our services to you and our clients, Laurel Hill uses personal
information in a variety of ways. We may mail you program materials, assist you with Proxy
voting, or mail you a cheque. Participation in our programs may result in Laurel Hill
performing transactions and administering accounts at your direction; often resulting in
tax and other reporting required by law.
We will generally not disclose your personal information other than for the
identified purpose unless we have your consent or are required to by law. In the ordinary
course of conducting our business, your information may have to be shared with a related,
affiliate, or outside company. These companies may use your information, on our behalf, by performing certain securityholder database management or processing functions,
printing of tax forms, or the mailing of program materials and entitlement checks.
For the purposes of this Privacy Statement, “Laurel Hill”, “we”, “our”, and
“us” means The Laurel Hill Advisory Group, LLC. “You” and “yours” is defined as an individual whose personal information we may collect, use, and disclose as we
conduct our business.
Laurel Hill’s Privacy Responsibility
Our Privacy Statement reviews how we collect, use, retain and disclose personal information. Protecting personal and financial information as we practice our
business is a principle Laurel Hill pays special attention to. We follow 10 principles of
fair information practices included in the Personal Information Protection and
Electronic Documents Act (PIPEDA) 2001. These principles give an individual control over
how their personal information is handled while providing guidance to organizations
on how to responsibly protect information and ensure the fair handling of it all
Accountability: Laurel Hill
accepts responsibility for personal information in our possession and ensures that each of our employees is informed about the
importance of protecting personal information.
Identifying Purposes: Why do we collect personal information about you? We
can identify and describe the purpose for you in various ways and may do so by mail
or phone as our services are provided. If you are a shareholder in a corporate
issuer, you may receive a letter or phone call describing how we can assist you in proxy
voting or in claiming financial assets that you are entitled to.
Consent: We require your
consent to collect, use, and disclose your information, with certain exceptions. The choice to provide us with personal information is
yours. We commit to explaining your options to withhold consent; however, your ability to withdraw consent may be limited by legal or contractual restrictions.
Limiting Collection: We
fairly collect information for the purposes we identify in our shareholder programs and events. You may visit our website without
revealing any personal information about yourself.
Limiting Use, Disclosure, and Retention: We maintain procedures and policies governing the retention and destruction of recorded information. Statutory requirements of regulators and our clients mandate certain information to be
securely stored for extended lengths of time. When we are required to utilize the
expertise of an outside company, either in The U.S. we carefully ensure and require that similar privacy standards are met. At times, we may be compelled
to release information by legislation (including securities law, terrorist
financing, income and tax reporting).
Accuracy: Laurel Hill attempts to ensure that your personal
information is accurate and that we will make efforts to maintain its accuracy.
Safeguards: We provide
appropriate safeguards to protect your personal information from loss, theft, or unauthorized access, disclosure, copying, use, or
modification. Laurel Hill and each of its employees are aware of the importance in protecting
your information and use security measures such as locked facilities and access restrictions.
Openness: Our Privacy
Statement outlines our commitment to fair information practices and can be viewed electronically at www.laurelhill.com. Questions
or concerns regarding privacy can be addressed to our Privacy Officer (contact
below). Individual Access: Upon written request, and subject to certain conditions, we
will provide access to all private information we have of you, describe how that information is used and with whom that information was disclosed to.
Provide Recourse: Laurel Hill provides a straightforward process to voice your inquiries or concerns regarding privacy. For inquiries, please contact our
The Laurel Hill Advisory Group, LLC
2 Robbins Lane
Jericho, NY 11753
Tel: (516) 933-3100