Privacy Policy

This Privacy Policy governs the manner in which University of Toronto Asset Management Corporation (herein, referred to as “UTAM”, “we”, “us” or “our”) collects, uses, maintains and discloses information collected from users or visitors (each, a “User” or “you”) of the utam.utoronto.ca website (the “Website”). This Privacy Policy applies to the Website and all information, text, graphics, videos, or other material on the Website (“Content”).

1. Personal information

Privacy legislation in Canada defines “personal information” broadly as any information about an identifiable individual such as name, age, contact information, ID numbers and income.

2. Accountability

We are responsible under applicable privacy legislation for the personal information in our possession or control. This includes personal information we receive directly or indirectly from Users or others. We have established policies and procedures with the objective of protecting personal information and have appointed a Privacy Officer to oversee privacy matters for our firm. Our Privacy Officer can be reached at: privacy@utam.utoronto.ca.

3. How do we collect personal information and what personal information do we collect?

We may collect personal information from Users in a variety of ways, including, but not limited to, when Users visit the Website, register on the Website, subscribe to a newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we may make available on our Website from time to time.

Users may be asked for, as appropriate, name, email address, mailing address, telephone number, or other types of contact information. We may also collect any other information Users voluntarily share with us.

4. Non-personal information

We may collect non-personal information about Users whenever they interact with our Website. Non-personal information may include the browser name, the type of computer and technical information about Users’ means of connection to our Website, such as the operating system and the Internet service providers utilized and other similar information.

5. Our purposes for collecting and using personal information

We may collect and use Users’ personal information for the following purposes:

(a) To improve customer service
Information may be used to provide the Content more effectively.

(b) To improve our Website
We may use feedback you provide to improve our Website and Content.

(c) To run a survey or other Website feature
To send Users information they agreed to receive about topics we think will be of interest to them.

(d) To send periodic emails or otherwise contact Users
We may use Users’ contact information to send Users information and updates relating to the services we offer. It may also be used to respond to their inquiries, questions, and/or other requests. If a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or the User may contact us via our Website.

6. Consent

We will obtain a User’s consent to the collection, use and disclosure of personal information about the User, and the consent of other individuals where required by applicable privacy and anti-spam legislation. We assume that an individual has consented to our reasonable collection and use of personal information consistent with the purposes for which the information as given when the individual initiates contact with us or voluntarily provides personal information to us. We also assume that Users who use our services consent to the reasonable collection, use and disclosure of their personal information by us to facilitate the provision of such services.

We do not collect, use or disclose personal information without consent unless authorized or required by law to do so.

7. Limited collection, use, disclosure and retention

We collect personal information by fair and lawful means and, where appropriate, directly from the Users. Wherever possible, we limit the amount of personal information we collect, use or disclose to that necessary and appropriate for the operation of our business.

8. How we protect your information

We adopt appropriate physical, organizational, contractual and technological security safeguards to protect your personal information against unauthorized access, alteration, processing, disclosure or destruction. The security of your personal information is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While as noted above, we strive to use appropriate means to protect your personal information, we cannot guarantee its security. You assume the risk of sending us any personal information you choose to send through the Website.

We maintain policies and practices to protect your personal information. Depending on the volume and sensitivity of the information, the purposes for which it is used and the format in which it is stored, we may implement a combination of measures as considered necessary to protect your personal information, including:

  • Internal policies and procedures which define the roles and responsibilities of our employees and limit their access to such information on a “need-to-know” basis;
  • If information is collected or stored in electronic format, technical safeguards such as encryption, firewalls, antivirus software and similar measures;
  • A designated Privacy Officer to monitor our compliance with applicable data protection laws;
  • Employee privacy and data security training;
  • Contractual protections and other measures to ensure that service providers with whom we share personal information maintain adequate privacy protections and standards; and
  • Procedures for receiving, investigating and responding to complaints or inquiries regarding our information handling practices, including any security incidents involving personal information.

9. Sharing your personal information

We do not sell, trade, or rent Users’ personal information to others. We may share generic aggregated demographic information not linked to any personal information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third-party service providers to help us operate our business and the Website or administer activities on our behalf, and for sending out newsletters or surveys that you have requested, and as described in “Analytics and Cookies” below.

10. Retaining your personal information

Please note that we will only retain your personal information for as long as reasonably necessary for the above purposes or as required by law. Once no longer required, your personal information will be securely destroyed or anonymized in compliance with applicable laws.

11. Analytics and Cookies

We may monitor and analyze, and use third-party service providers to monitor and analyze, the use of the Website. Please read the following carefully: we may have access to, use, and/or disclose your personal information or browser type information if you do not instruct your web browser to refuse all cookies or to indicate when a cookie is sent, or if you do not opt out of Google Analytics or other services, as described more particularly below. We automatically track certain information including your IP address, what browser you are using and the URL you Just came from. We may use cookies to provide certain services on the Website to deliver content specific to you.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.Js, analytics.Js, and dc.Js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page at www.google.com/intl/en/policies/privacy.

12. Cross-border transfers of personal information

Your personal information may be transferred, stored, accessed, or used in a jurisdiction outside your jurisdiction of residence (for example, outside your province or outside Canada) in connection with our use of third-party service providers. We use our best efforts to ensure that our third-party service providers take reasonable security measures to protect your personal information (this includes technical, administrative, and physical safeguards to protect your personal information), and to our service providers only use your personal information for authorized purposes we have made known to you or which are otherwise permitted by applicable law.

Where personal information is located outside of your province of residence or outside Canada, it is subject to the laws of that jurisdiction which may differ from those in your jurisdiction and any personal information transferred to another jurisdiction will be subject to law enforcement, regulatory, and national security authorities in that jurisdiction. Subject to these laws, we will use contractual measures to maintain protections that are at least equivalent to those that apply in Canada.

13. Accessing and correcting your personal information

You may be entitled to access your personal information and request corrections to information that is inaccurate, incomplete or no longer up to date, subject to limited exceptions set out in applicable laws.

Depending on the law applicable in the jurisdiction where you reside and subject to legal or contractual restrictions, you may also be entitled to:

  • request that we stop or restrict processing your personal information or to have it erased;
  • request information on automated processing of your personal information. You can obtain information on the personal information used to render the decision (and request that this information be correct) and the reasons, principal factors and parameters that led to the decision;
  • obtain a copy of the personal information we collected from you; and
  • obtain additional information about data processing, including the personal information collected and how it is processed.

To submit a request, please contact us in writing using the relevant contact information listed in the “Contacting Us” section below.

14. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. When such updates are material, we will post a notification on the main page of our Website, and revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

15. Your acceptance of these terms

By using this Website, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Website. Your continued use of the Website following the posting of any changes to this Privacy Policy will be deemed your acceptance of those changes.

16. Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact our Privacy Officer at: privacy@utam.utoronto.ca.

Last Updated: April 25, 2024