Privacy and Cookies Policies
Privacy Policy
Russell Investments Canada Limited
Russell Investments Canada Limited ("Russell Investments") has always been committed to maintaining the confidentiality, integrity and security of all personal information that we collect, use and maintain in the course of carrying on business. We are proud of our privacy practices and want you to know how we protect this information and use it to service your account.
PERSONAL INFORMATION
In this policy, personal information means any information that identifies an individual directly or indirectly, including information such as home address and telephone number, date of birth, age, marital status, employment history, social insurance number and credit history. It does not include business contact information of individuals that communicate with us in relation to their business, employment or profession.
COLLECTION OF PERSONAL INFORMATION
Personal information is collected directly from you or through your advisor when you open an account with Russell Investments. This information is obtained by us when you or your advisor sends us a completed application form or when your advisor transmits information to us electronically. From time to time, we may be required to collect information from a third party who is not your advisor, such as an executor of an estate of a third party who may provide information about you or your account to us. We may also collect other personal information if it is provided to us by your financial advisor or dealer.
Where applicable, consent to the collection of your personal information may be express or implied, depending on the circumstances and the sensitivity of the information collected.
The personal information in your account with us may include your name, birth date, mailing address, social insurance number, phone number(s), account holdings, transactions and statements, tax slips, and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request, and the types of communications that you have with us (for example, to group together individuals in your household to qualify for higher rebates.) At times, we may request independent sources to verify and supplement information that you provide to us.
You are not required to provide us with some or all of the personal information we request. However, this may result in us not being able to provide you with the product, service or information you requested.
In providing information to us and continuing to conduct business with us, you are consenting to the use of your personal information. When you provide us with personal information about another individual (for example, you are an advisor providing information about a client), you represent to us that you are authorized to disclose such information to us on the terms specified in this privacy policy.
USE OF PERSONAL INFORMATION
Russell Investments may use your personal information for these stated purposes:
- Communicating with you and your advisor and dealer regarding service offering or products which may be of interest to you
- Establishing and administering your account
- Ensuring the information in our records is accurate
- Executing your transactions
- Meeting legal and regulatory requirements
- Collecting a debt owed to us
- Providing you and your advisor and dealer with account statements and other account related information
- Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account
- Setting-up and managing products and services you have requested
- Verifying your identity and protecting against fraud
- Verifying previously given information when necessary
From time to time, we may use personal information to create aggregated or otherwise anonymized data whose purpose is to help us better provide services or assist with research or educational tasks. We only do this if the anonymized data cannot be used to directly or indirectly identify the personal information of any individuals.
DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
Russell Investments discloses your personal information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy. Third parties who may be provided with your personal information include:
- Entities to whom we are legally obliged or permitted to provide information
- Governments, government agencies and regulators
- Other mutual fund companies, financial institutions and securities dealers when necessary to carry out your instructions such as transferring funds
- Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, server hosts, imaging and document storage
- Your advisor and dealer
Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose your information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities, and if such disclosure is not prohibited by law.
We may disclose user information when we believe in good faith that such disclosure is required or permitted by and in accordance with the law.
When we transfer personal information to third parties, we ensure by contractual means that the transferred personal information is protected to the same degree as if it were in our possession.
We may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets. In this case, we would ensure that the information disclosed continues to be used only for the purposes permitted by this Privacy Policy and by the entity acquiring the information.
We do not sell your personal information to any third party.
COMMUNICATION OF PERSONAL INFORMATION OUTSIDE CANADA AND QUEBEC
Personal information that we collect from you is stored on our servers in the United States. As a result, the personal information of Quebec residents may be communicated outside Quebec.
At times we may use third parties and/or our affiliates in the United States, the United Kingdom and India to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information, and may be accessible by regulatory authorities in other jurisdictions.
However, our practices regarding your personal information will at all times be governed by this Privacy Policy.
YOUR RIGHTS AND HOW TO EXERCISE THEM
In accordance with applicable laws and where applicable, you have the following rights:
- To access: you may access information relating to the collection, use or disclosure of your personal information and obtain a copy of your personal information, the categories of persons who have access to your personal information, and the duration of the period of time your personal information will be kept.
- To rectify: if you believe your personal data we have on file is inaccurate, incomplete or unclear, or that our collection, communication or keeping of your personal information is not legal, you may ask us to correct your personal information. Except under limited circumstances, you may ask us to amend or update your personal information at any time.
- To withdraw your consent: where you provided consent to our use or disclosure of your personal information, you have the right to withdraw such consent at any time. However, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent.
In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information. When you provide us with personal information about another individual, you represent to us that you are authorized to disclose such information to us on the terms specified in this privacy policy.
Russell Investments will provide you with access to your personal information on your written request. Our verification procedures help to minimize risk that such information is released to anyone not authorized to receive it. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law. You may ask us to amend or update your personal information at any time. Access to your personal information is free. However, we may charge reasonable costs we incur (for example, photocopies, postage, etc.) We will always provide you with an estimate prior to charging you any amounts. Russell Investments reserves the right to charge you for our costs incurred in providing the information requested.
Russell Investments may not be able to provide you with full access to your information if:
- It contains references to other persons
- It has been destroyed
- It is too costly to retrieve
- It cannot be disclosed for legal or regulatory reasons
- We would have to disclose proprietary information confidential to Russell Investments or its affiliates
If we are unable to provide you with access to your personal information or rectify it, we will provide you with a written explanation in our response to your request.
Please inform us promptly of any change in the personal information that you have provided, or if you become aware of any errors in the personal information that we have in respect of you.
If you wish to exercise any of these rights, please contact our Privacy Officer as listed in the “Contact Us” section below.
PROTECTION OF PERSONAL INFORMATION
We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and data encryption for on-line activities. We have policies and procedures, training programs and monitoring in place to ensure that these measures are followed.
Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your account.
Despite these measures, no method of information transmission or information storage is 100% secure or error free, and we cannot guarantee security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any information that you provided to us has been compromised), please contact us immediately.
RETENTION OF PERSONAL INFORMATION
We only keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). Once it is no longer needed, it is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date.
CHANGE OF RUSSELL INVESTMENTS' PRIVACY POLICY
If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower left-hand corner of this web page.
CONTACT US
If you have any concerns, queries or complaints in respect of this privacy policy, or our management of your personal information, you can contact our Client Services team by email at privacy@russellinvestments.com, by telephone at 416-362-8411 or toll-free at 888-509-1792, or by mail to the following address:
Russell Investments Canada Limited
100 King Street West
Suite 5715
Toronto, ON M5X 1E4
Attn: Client Services
You may also contact our Chief Privacy Officer, Kathie Johnson, at kjohnson@russellinvestments.com, by telephone at 416-640-2511 or by mail at the address noted above.SECURITY
This site has security measures in place to protect the loss, misuse and alteration of the information under our control.
Choice/opt-out
Our site provides users the opportunity to opt-out of receiving communications from us at the point where we request information about the visitor.
This site gives users the following options for removing their information from our database to stop future communications or to no longer receive our service.
You can send e-mail to canada@russellinvestments.com.
Correct/update
This site gives users the following options for changing and modifying information previously provided.
You can send e-mail to canada@russellinvestments.com.
COOKIES AND ANALYTICS
We may also employ "cookies" or similar technology that provides additional functionality to the Website and helps us analyze Website usage more accurately. Cookies allow for a personalized experience when you visit or revisit the Website. We use various cookies to store some details you enter and choices you make so that we do not have to ask you for them every time you visit a page that needs them. With your consent, we may use cookies to present you with relevant products or advertisements on our Website and on other websites that are based on your interests. Some cookies, like preference cookies, do not need your permission. If you do not want any cookies, you can set your browsers to refuse cookies before using the Website, but some website features might not work well without cookies. However, you should be aware that if cookies are rejected you will not be able to use some of the online services provided by Russell Investments. For more information on the cookies we use and how to configure your browser preferences, please consult our cookies policy.
For example, we also use Google Analytics, a web analytics service provided by Google, in order to find out how visitors interact with Russell Investments so we can improve it. Information is collected anonymously and website trends are reported without identifying individual visitors.
We also may use DoubleClick cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (”interest based targeting”). The ads served will be targeted based on your previous browsing history. DoubleClick uses “non personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-in of this ad serving on all sites using this advertising by visiting https://adssettings.google.com/authenticated.
Cookies Policy
This Cookie Policy (the “Cookie Policy”) is intended to inform you of Russell Investments Canada Limited’s (“Russell Investments”) use of cookies and related technologies (such as pixel, tags or beacons) (together “cookies” or “cookie”), on https://russellinvestments.com/ca (the “Website”).
Please take a minute to read and understand this Cookies Policy. This Cookies Policy should also be read in conjunction with our Privacy Policy.
1. What are cookies?
A cookie is a very small text file stored on your computer/other device (and maintained by your website browser), and often includes a randomized unique identifier so that a website can ‘recognize’ this cookie again. Cookies support website functions and improve browsing, and also provide certain information to the owners of these websites, in particular for audience measurement.
For example, cookies make it easier to pre-fill certain fields in webforms and adapt the content of the website and its services to your preferences or circumstances, improving the user experience and tailoring aspects of the website and its services to you.
2. How do we use cookies?
Information collected through cookies helps us analyze the use of the Website and offer users a better experience when visiting the Website. We will only keep cookies for as long as necessary to achieve the relevant purposes set out in this Cookie Policy, notably for marketing and statistical purposes.
Generally speaking, we use first and third-party cookies which can be session or persistent cookies. Cookies set by us are called “first-party cookies”. Cookies set by our third-party partners and service providers are called “third-party cookies.”
“Session” cookies are temporary cookies that remain on your device until you close your web browser. Many session cookies are essential to make our Website function correctly, as they typically enable you to move around our Website and use our features.
“Persistent” cookies remain on your device after you close your browser. How long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings – or if you choose to delete the cookie. Persistent cookies help us recognize you as an existing user of our Website, so that you do not need to sign-in again or adjust Website preferences when you return to our Website or interact with our services in the future. In addition, persistent cookies help us recognize you when you view a resource belonging to our Website from another website or app (such as an advertisement) and help us record information about your web browsing habits during the lifetime of the persistent cookie.
3. What cookies do we use?
Necessary cookies are necessary for our Website to function properly and ensure our Website services are accessible to you (e.g., log-in functionality, load balancing, navigation, filling in forms). The Website cannot function properly without these cookies.
Preference cookies allow us to remember information that changes the way the website behaves or looks, like your preferred language or to tailor information to the region that you are in.
Statistical cookies allow us to understand how visitors interact with our Website by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across our Website. They help display ads that are relevant and engaging for the visitor.
Social media cookies are used when we incorporate functionalities from certain social networks. These features may sometimes be accompanied by scripts or other features that read and sometimes place cookies from these social networks on your device. These cookies can be used to personalize advertising messages. We have no access to these cookies or to the data they collect, nor any control over the social networks (which are responsible for their own processing activities), however it is important to be transparent about the fact that we use them. For additional information, please refer to the list of potential social network cookies we may use below:
- LinkedIn: the following LinkedIn features can be integrated into our Website and may read or place LinkedIn cookies:
- Sign-in to LinkedIn (which allows the user to sign in to their LinkedIn account and interact with our Website through that account);
- Share on LinkedIn (which allows the user to share with others an item on LinkedIn)
Click here to read LinkedIn’s Privacy policy
Click here to get information on LinkedIn’s cookies - YouTube: certain YouTube features may be integrated into our Website and may read or place YouTube cookies.
Click here to consult YouTube’s Privacy Resources
| Cookie Type | Provider | Cookie | Duration | Description |
|---|---|---|---|---|
| Necessary | linkedin.com | UserMatchHistory | 30 days | Ensures visitor browsing security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor. |
| Necessary | russellinvestments.com | .AspNet.Cookies | Session | Authentication cookie set and used by Sitecore |
| Necessary | russellinvestments.com | .ASPNET_Auth | 1 hour | Used for user authentication |
| Necessary | russellinvestments.com | .ASPNET_R | 14 days | Used to refresh the authentication cookie |
| Necessary | russellinvestments.com | _cls_s | Session | Session identifying cookie. It also indicates if the visitor is new or existing |
| Necessary | russellinvestments.com | _cls_v | 184 days | Used to identify visitor |
| Necessary | russellinvestments.com | ASP.NET_SessionId | Session | Preserves the visitor's session state across page requests. |
| Necessary | russellinvestments.com | BIGipServer# | Session | Used to distribute traffic to the website on several servers in order to optimise response times. |
| Necessary | russellinvestments.com | cookies.js | Session | Determines whether the visitor has accepted the cookie consent box. This ensures that the cookie consent box will not be presented again upon re-entry. |
| Necessary | russellinvestments.com | i18nextLng | Persistent | Determines the preferred language of the visitor. Allows the website to set the preferred language upon the visitor's re-entry. |
| Necessary | russellinvestments.com | ri.blog | Session | Used to store blog region |
| Necessary | russellinvestments.com | ri.com | 180 days | Used to store user information |
| Necessary | russellinvestments.com | SESS# | 1 day | Preserves users states across page requests. |
| Necessary | russellinvestments.com | session | 30 minutes | Used to store session information |
| Necessary | russellinvestments.com | shell#lang | Session | This cookie is used to determine the preferred language of the visitor and sets the language accordingly on the website, if possible. |
| Necessary | russellinvestments.com | tms_wsip | 1 day | Used for gathering technical information regarding the user's browser, operating system, IP address and screen resolution as well as the user's navigation on the website. |
| Necessary | russellinvestments.com | TS# | Session | Used to ensure website security and fraud detection. |
| Necessary | youtube.com | remote_sid | Session | Necessary for the implementation and functionality of YouTube video content on the website. |
| Necessary | youtube.com | VISITOR_INFO1_LIVE | 180 days | Tries to estimate the users' bandwidth on pages with integrated YouTube videos. |
| Necessary | youtube.com | VISITOR_PRIVACY_METADATA | 180 days | Stores the user's cookie consent state for the current domain. |
| Preference | engage.russellinvestments.com | ELOQUA | 13 months | Registers a unique ID that identifies the user's device upon return visits. Used for auto-populating forms and to validate if a certain contact is registered to an email group. |
| Preference | russellinvestments.com | nmstat | 1000 days | This cookie contains an ID string on the current session. This contains non-personal information on what subpages the visitor enters – this information is used to optimize the visitor's experience. |
| Preference | russellinvestments.com | website#lang | Session | Saves the user's preferred language on the website. |
| Preference | youtube.com | LogsDatabaseV2:V#||LogsRequestsStore | Persistent | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | YSC | Session | Registers a unique ID to keep statistics of what videos from YouTube the user has seen. |
| Preference | youtube.com | yt-remote-cast-available | Session | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-cast-installed | Session | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-connected-devices | Persistent | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-device-id | Persistent | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-fast-check-period | Session | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-session-app | Session | Stores the user's video player preferences using embedded YouTube video. |
| Preference | youtube.com | yt-remote-session-name | Session | Stores the user's video player preferences using embedded YouTube video. |
| Statistical | fonts.net | __cf_bm | 1 day | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. |
| Statistical | global.siteimproveanalytics.io | AWSALB | 7 days | Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience. |
| Statistical | global.siteimproveanalytics.io | AWSALBCORS | 7 days | Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience. |
| Statistical | global.siteimproveanalytics.io | image.aspx | Session | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. |
| Statistical | google-analytics.com | collect | Session | Used to send data to Google Analytics about the visitor's device and behavior. Tracks the visitor across devices and marketing channels. |
| Statistical | googletagmanager.com | td | Session | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. |
| Statistical | linkedin.com | AnalyticsSyncHistory | 30 days | Used in connection with data-synchronization with third-party analysis service. |
| Statistical | report.russell.glassboxdigital.io | _cls_cfgver | Session | Cookie set and used by Glassbox |
| Statistical | russellinvestments.com | _ga | 2 years | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
| Statistical | russellinvestments.com | _ga_# | 2 years | Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. |
| Statistical | russellinvestments.com | _gat | 1 day | Used by Google Analytics to throttle request rate. |
| Statistical | russellinvestments.com | _gid | 1 day | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
| Statistical | russellinvestments.com | BE_CLA3 | 1 year | Enables data aggregation, analysis, and report creation to assess marketing effectiveness and for website performance. (BrightEdge cookie) |
| Statistical | russellinvestments.com | ln_or | 1 day | Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator. |
| Statistical | russellinvestments.com | SC_ANALYTICS_GLOBAL_COOKIE | 400 days | Used by Sitecore Engagement Analytics to identify the visitor on repeat visits to the website. |
| Marketing | doubleclick.net | ar_debug | 30 days | Advertising cookie used to store and track conversions |
| Marketing | doubleclick.net | DSID | 2 weeks | Advertising cookie used to identify a logged in user on non-Google sites and to store user preferences regarding ad personalization |
| Marketing | doubleclick.net | IDE | 13 months EEA UK / 24 months elsewhere | Advertising cookie used to provide ad delivery or retargeting |
| Marketing | doubleclick.net | test_cookie | 1 day | Used to check if the user's browser supports cookies. |
| Marketing | google.com | ads/ga-audiences | Session | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. |
| Marketing | google.com | AEC | 6 months | Ensure that requests within a browsing session are made by the user, and not by other sites. These cookies prevent malicious sites from acting on behalf of a user without that user’s knowledge |
| Marketing | google.com | NID | 6 months | Advertising cookie used to show Google ads in Google services for signed-out users |
| Marketing | google.com | SEARCH_SAMESITE | 2 months | Used to prevent the browser from sending the cookie along with cross-site requests. |
| Marketing | linkedin.com | li_sugr | 3 months | Collects data on user behaviour and interaction in order to optimize the website and make advertisement on the website more relevant. |
| Marketing | russellinvestments.com | _gcl_au | 3 months | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. |
| Marketing | russellinvestments.com | _mkto_trk | 2 years | Contains data on visitor behaviour and website interaction. This is used in context with the email marketing service Marketo.com, which allows the website to target visitors via email. |
| Marketing | russellinvestments.com | tms_VisitorID | 560 days | This cookie may collect the following information and store it against a user ID: Product codes from merchant sites the visitor has browsed and other information relevant to shopping behaviour on main stream shopping sites. This information is used to serve targeted adverts to the visitor. |
| Marketing | youtube.com | __Secure-1PSIDTS | 1 year | Collects information about user's interactions with Google services and ads |
| Marketing | youtube.com | CONSENT | 2 years | Used to detect if the visitor has accepted the marketing category in the cookie banner. |
| Marketing | youtube.com | LAST_RESULT_ENTRY_KEY | Session | Used to track user’s interaction with embedded content. |
| Marketing | youtube.com | nextId | Session | Used to track user’s interaction with embedded content. |
| Marketing | youtube.com | PREF | 8 months | Advertising cookie used to store user preferences |
| Marketing | youtube.com | requests | Session | Used to track user’s interaction with embedded content. |
| Marketing | youtube.com | TESTCOOKIESENABLED | 1 day | Used to track user’s interaction with embedded content. |
| Marketing | youtube.com | YtIdbMeta#databases | Persistent | Used to track user’s interaction with embedded content. |
| Social Media | linkedin.com | bcookie | 1 year | Used to store browser details. |
| Social Media | linkedin.com | bscookie | 1 year | This cookie is used to identify the visitor through an application. This allows the visitor to login to a website through their LinkedIn application for example. |
| Social Media | linkedin.com | li_gc | 180 days | Stores the user's cookie consent state for the current domain. |
| Social Media | linkedin.com | lidc | 1 day | Used to provide load balancing functionality. |
4. Can I manage my cookies preferences?
Some cookies are used with your consent, such as cookies to present you with relevant products or advertisements. Conversely, some cookies, like preference cookies, do not need your permission. If you have any concerns about our use of cookies, you can take action to prevent them from being set, such as by changing your browser settings to block certain types of cookies. You may also delete cookies held on your device at any time by going to the appropriate settings within your web browser.
You have the option to configure your devices to accept all cookies, to notify you when a cookie is issued or to never accept cookies. However, the latter option may result in some personalized services not being provided and, as a result, you may not be able to take full advantage of all the features offered by the Website. If you do not wish to receive cookies in general or only to refuse certain cookies, you can change your browser settings accordingly.
For any other browser not mentioned above, consult the cookie management help information available on the browser provider’s website. You can also visit http://www.allaboutcookies.org for an overview of how to manage cookies on most common browsers.
5. Contact us
For any further queries or information related to this Cookies Policy, please write to our Chief Privacy Officer, Kathie Johnson at kjohnson@russellinvestments, or privacy@russellinvestments.com with the subject line “Cookies Policy”.