• Our Commitment to You

    BMO Financial Group appreciates the opportunity to help you meet your financial needs. From the day Bank of Montreal was founded in 1817, earning and keeping your trust has been at the very core of our business. We are committed to respecting and protecting the Personal Data that you entrust to us. It is important for you to understand what Personal Data we will collect, how we will use it, and who may see it.

    Scope

    This Privacy Code applies to the BMO Financial Group operations that take place in Europe. Data protection contact details of these companies can be found below. Defined terms are listed in Annex A.

    This Privacy Code outlines our commitment to you and incorporates the following 10 key privacy principles:

    1. Accountability

    We have strict policies and procedures governing how we deal with your Personal Data. Every employee is responsible for respecting and protecting the Personal Data to which they have access.

    Our Data Protection Officer oversees how we deal with your Personal Data. Please see Contact Us for information on how to reach our Data Protection Officer.

    2. Identifying Purpose

    When we collect your Personal Data, we may use or disclose it for the following purposes.

    • To provide and manage products and services you have requested ► to deliver our products and services that you have requested, or to notify you about changes to our services and products.
    • To verify your identity, protect against fraud and manage risk ► we and other organisations may access and use certain Personal Data to prevent fraud, money laundering and terrorism, or other criminal offences, as required by applicable law and regulation and best practice at any given time. This could include checking against sanctions, politically exposed persons and other fraud or crime screening databases. If false or inaccurate information is provided and fraud is identified or suspected, we may pass your details to fraud prevention agencies and they may be recorded by us or by them.
    • To comply with legal or regulatory requirements, or as otherwise permitted by law ► we may process your Personal Data to comply with our regulatory requirements, when communicating with our regulators or to defend or prosecute claims as applicable. This could include passing your Personal Data to third parties, the courts and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by them anywhere in the world.
    • To communicate with you regarding products and services that may interest you ► to send you updates and offers if you have chosen to receive these. We may also use your Personal Data for marketing our products and services to you by post, email, phone, SMS, online or through social media. Where required by law, we will ask for your consent at the time we collect your Personal Data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt out of further communication on any electronic marketing communications. You may opt out at any time by contacting the BMO Financial Group company that you do business with.
    • To understand our customers and develop and tailor our products and services ► we may analyse the Personal Data we hold in order to better understand our clients’ services and marketing requirements, to better understand our business and to develop our products and services. In order to ensure that content from our websites is presented in the most effective manner for you and for your device, we may pass your data to business partners, suppliers and/or service providers.
    • To re-organise or make changes to our business ► If we negotiate and/or sell part or all of our business to a third party, or undergo a significant corporate reorganisation, we may need to transfer some or all of your Personal Data to the relevant third party (or its advisors) as part of any due diligence process and use it for the same purposes as set out in this policy or for the purpose of analysing any proposed sale or reorganisation.
    • To respond to any questions you may have ► we may be required to process your Personal Data in order to conduct and keep a record of our correspondence with you.

    We may monitor calls and transactions to ensure service quality, to comply with law and regulation and our internal procedures and to combat fraud and other criminal activity.

    If a new purpose for using your Personal Data develops, we will update this policy to identify that purpose.

    3. Consent and Your Choices

    Some of our processing is permitted by legal bases other than consent (see section 2 above). Where we are required to do so, we will obtain your consent before using your Personal Data for Direct Marketing. If you do not want to receive our Direct Marketing communications and/or do not want to have your Personal Data shared among relevant members of BMO Financial Group for the purpose of marketing, you can have your name deleted from our Direct Marketing and/or shared information lists. If you want to change your privacy preferences, please contact the BMO Financial Group company that you do business with.

    To the extent another legal basis cannot be applied, we will rely on your consent to process criminal convictions data and politically exposed persons’ Personal Data. Such consent is necessary for us to provide our services; if you withdraw this consent we may have to stop providing certain services.

    4. Limited Collection

    We only collect the Personal Data that we determine we need for one or more of the purposes set out in Principle 2.

    For example, we may collect:

    • Contact information ► information including your address, telephone number and email address.
    • Information you provide about others we may require information about third parties such as your immediate family members. You must have their permission to give us their Personal Data and you need to let them know how we use their Personal Data before providing it to us.
    • Anti-crime and fraud information ►Personal Data you or third parties provide us that establishes your identity (such as driving licences, passports and utility bills) and other related information, such as addresses, phone numbers, email addresses, signatures and work histories, that enables us to verify that you are neither suspected nor a victim of fraud, other criminal offences or suspicious transactions and that your details do not appear on politically exposed person and sanctions lists.
    • Financial Information ► Personal Data to ensure that any products and services we provide you with are appropriate and suitable for you.
    • Your transactions and holdings ► details of transactions or investments with us that you have made or initiated with us.
    • Our correspondence ► details of any correspondence between us and you (verbal or in writing).
    • Device information ► information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk.
    • Website use information ► details of activity on our websites, including browsing behaviour on BMO sites and links, the location you click, form data and downloads as well as other data gathered from the use of web tools (for example, cookies, web beacons, tagging) to better understand your interests and needs so that we can serve you better. For more information, see our Cookie Policy below.
    • Marketing preference information ► details of your marketing preferences (e.g. communication preferences) and information to help us choose appropriate products and services to offer you.
    • Email tracking information ► our emails may contain a single, campaign-unique “web beacon pixel” to tell us whether our emails are opened and combined with other technology verify any clicks through to links within the email. We may use this information to determine which of our emails are more interesting to you and to query whether people who do not open our emails wish to continue receiving them. This information may include Personal Data. The pixel will be deleted when you delete the email. If you do not wish the pixel to be downloaded to your device, please select to receive emails from us in plain text rather than HTML or choose not to click links that we send you or unsubscribe from receiving our emails.
    • Call recordings and CCTV ► we may monitor or record our telephone calls with you, for service quality or training purposes and to establish a record of our communications for regulatory recordkeeping purposes, including for the prevention and detection of fraud. If you do not wish to have your call recorded, you have other options to conduct business with us such as online or by contacting us in writing. We may record CCTV footage in and around our premises and other locations for the safety of our clients and employees, and to protect against theft, property damage and fraud.

    5. Limited Use and Disclosure

    We will only use or disclose your Personal Data for the purpose(s) it was collected for and as otherwise identified in this Privacy Code.

    Sharing outside the BMO Financial Group: Personal Data may be provided to third parties, including anti-fraud organisations or legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organisations, or to comply with a court order. Unless prohibited by law, we can give you details of any such third party disclosures upon request.

    Sharing within the BMO Financial Group: We may share your Personal Data within the BMO Financial Group, including locations outside of the European Economic Area (EEA) for marketing purposes, for legal and regulatory purposes, to manage business risks, to perform analytics, to ensure we have correct or up-to-date information about you (such as your current address or date of birth) and to better manage your relationship with us.

    Business sale or re-organisation: over time, we may buy new businesses or sell some of our businesses. Accordingly, Personal Data associated with any accounts, products or services of the business being sold will be reviewed as part of the due diligence process and subsequently transferred as a business asset to the new business owner. We may also transfer Personal Data as part of a corporate reorganisation or other change in corporate control.

    Sub-contractors and agents: we may use affiliates or other companies to provide services on our behalf such as data processing, account administration, fraud prevention and detection, analytics and marketing. Such companies will be given only the Personal Data needed to perform those services and we do not authorise them to use or disclose your Personal Data for their own marketing or other purposes. We have contracts that hold these companies to the same standards of confidentiality by which we are governed.

    • Transfers outside the EEA: your Personal Data may be accessed by staff or suppliers in, transferred to, and/or stored in, a country outside the EEA in which data protection laws may be of a lower standard than within the EEA. Regardless of location, we will impose the same data protection safeguards that we use inside the EEA.
    • Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws (see the full list here and therefore no additional safeguards are required to export Personal Data to these jurisdictions. In countries which have not been approved, we will establish legal grounds to justify transferring Personal Data, such as contractual terms approved by the European Commission that impose equivalent data protection obligations directly on the recipient.
    • Please Contact Us if you would like to see a copy of the specific safeguards applied to the export of your Personal Data.

    6. Retention

    • Our retention periods for personal data are based on business needs and legal requirements. We retain Personal Data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (we may further retain and use the anonymised information) or securely destroy the data.

    7. Accuracy

    We are committed to keeping your Personal Data accurate, complete and up-to-date. If you discover inaccuracies in our records, or your Personal Data changes, please notify the BMO Financial Group company that you do business with immediately so that we can make the necessary changes. Failure to notify us of changes to your Personal Data may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your Personal Data that we may have released to them. If we do not agree to make your requested amendments, you may challenge our decision as described in Contact Us.

    8. Safeguards

    We use an extensive range of safeguards to protect your Personal Data.

    We have agreements and controls in place with third party service providers requiring them to safeguard any Personal Data we provide to them and use the Personal Data only for the purpose of providing the service we have requested them to perform.

    We may link to other sites that will have their own privacy policies and customer information practices. If you click through to a third party site, please ensure you read their privacy policy as we cannot be held responsible for the content or practices of other sites.

    9. Openness

    From time to time, we may make changes to this Privacy Code. Where we have your email address, we may email you if the changes are material. Otherwise, we will not. We therefore recommend that you check the Code from time to time.

    This Privacy Code at http://www.bmogam.com is always the most recent version.

    Please see Contact Us to answer any questions you may have about our Privacy Code.

    10. Individual Access

    • The BMO Financial Group company that you correspond with will usually determine the purpose of processing your Personal Data and the way in which it is processed. Sometimes the company will do it jointly with others, depending on the products and services you use. Data protection contact details of these companies can be found in the Contact Us section.
    • Personal Data must be processed in line with your rights as a Data Subject. In the EU Data Subjects generally have certain rights, like the right of access to Personal Data or the right to prevent processing for purposes of direct marketing; however, these are subject to certain exceptions and variations in different EU member states.
    • If you are not satisfied with our use of your Personal Data or our response to any exercise of these rights, you can contact us as set out below.

    Escalate to BMO Financial Group Data Protection Officer

    If your complaint remains unresolved after raising it with the BMO Financial Group entity you do business with, you may contact our Data Protection Officer at:

    BMO Financial Group
    Office of the Data Protection Officer
    95 Queen Victoria Street
    London, EC4V 4HG.
    United Kingdom

    Privacy.UK-EU@bmo.com

    If after contacting us you do not feel that we have adequately addressed your concerns, please contact the Data Protection Regulator in the country where the BMO Financial Group entity that you deal with is established, as set out in the chart above.

    Cookie Policy

    We use cookies on this Website to provide customised information for users and to improve their online experience.

    What are cookies?

    Cookies are small text files that are stored on your device when you visit certain web pages. They provide us with valuable information and feedback, in general terms, such as how and when pages on the Website are visited, and what your technology preferences are.

    The cookies that we use on this Website can be categorised into the following groups:

    1. Strictly necessary cookies: these are essential to enable you to move around a website and use its features, such as accessing secure areas of the website. Without these cookies, certain services you may have asked for cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
    2. Performance cookies: these collect information about how you use a website, for instance which pages you go to most often, and if you get error messages from web pages. These cookies don't collect information that identifies you. All information these cookies collect is anonymous and is only used to improve how a website works.
    3. Functionality cookies: these allow a website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as watching a video. The information these cookies collect may not always be anonymous, but these cookies are not able to track your browsing activity on other websites.

    By using our Website, you agree that we can place these types of cookies from us and third parties such as Google Analytics, Hotjar and Flashtalking on your device.

    Amending cookie preferences

    If you wish to remove or block cookies set by this Website from your browser, you can delete them. The instructions for removing cookies from your computer or mobile device will depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use may impact your access to this Website. Click here for further information about cookies in general and instructions for managing cookies on many commonly used browsers. Alternatively you can consult your browser provider for such instructions.

  • Contact Us

    If you have any questions or concerns about our privacy practices, the privacy of your Personal Data or you want to change your privacy preferences, please let us know.

    Talk to the BMO Financial Group company that you do business with

    The company that you correspond with or do business with will usually be the data controller in respect of your Personal Data and can answer any questions you may have about our Privacy Code or our use of your Personal Data. If your concerns are not resolved, please contact:

    BMO Financial Group business

    Country

    Business Unit Contact

    Data Protection Regulator Contact

    BMO Global Asset Management

    F&C Management Ltd

    F&C Managers Ltd

    F&C Asset Managers Ltd

    UK

    Client Services
    +44(0)20 7011 4444

    Information Commissioner’s Office
    0303 123 1113

    Austria

    Rogier Van Harten
    +31 20 582 3795

    Austrian Data Protection Authority
    E-Mail: dsb@dsb.gv.at

    Belgium

    Rogier Van Harten
    +31 20 582 3795

    Commission for the Protection of Privacy
    +32 (0)2 274 48 00

    Finland

    Robert Elfström
    +46 (0) 856646501

    Data Protection Ombudsman
    +358 29 56 66700

    France

    Jean Michel Bongiorno
    +44 207 011 5233

    Commission Nationale de l'Informatique et des Libertés
    +33 (0)1.53.73.22.22

    Germany

    Elmar Rathmayr
    +49 69 22228 3613

    The Bavarian State Commissioner for Data Protection (BayLfD)
    0981 / 53-1300

    Ireland

    State Street Fund Services (Ireland) Limited
    +353 1 242 5529

    Office of the Data Protection Commissioner
    +353 (0761) 104 800

    Italy

    Giampaolo Giannelli
    +39 020068 1619

    Italian data protection authority
    +39-06-6967 71

    Luxembourg

    State Street Bank Luxembourg S.A
    +352 46 40 10 7460

    National Commission for Data Protection
    (+352) 26 10 60 - 1

    Norway

    Robert Elfström
    +46 (0) 856646501

    Data Protection Authority

    Spain

    Luis Martin-Hoyos
    +34 91 419 89 01

    Spanish Data Protection Agency (AEPD)
    Spanish Agency for Data Protection
    C / Jorge Juan, 6
    28001-Madrid

    Sweden

    Robert Elfström
    +46 (0) 856646501

    Data Inspection Board (DIB)
    +46 8 657 61 00

    Switzerland

    Rochus Appert
    +41 44 488 1951

    Federal Data Protection and Information Commissioner (FDPIC)
    +41 (0) 58 462 43 95

    F&C Portugal S.A.

    Portugal

    Joao Santos
    +351 21 003 3220

    Comissão Nacional de Protecção de Dados (CNPD)
    (+ 351) 21 392 84 00

    F&C Netherlands B.V.

    Netherlands

    Marco Mante de Vreede
    +31 20 582 3074

    The Dutch Data Protection Authority
    0900 200 12 01

    Thames River Capital LLP

    UK

    Client Services
    +44(0)20 7011 4444

    Information Commissioner’s Office
    0303 123 1113

    Thames River Multi-Capital

    UK

    Client Services
    +44(0)20 7011 4444

    LGM Investments

    UK

    Client Services
    +44(0)20 7011 4444

    BMO Real Estate Partners

    UK

    Nick Criticos
    +44 207 016 3567

    Information Commissioner’s Office
    0303 123 1113

    Germany

    Iris Schoeberl
    +49 89 614 65151

    The Bavarian State Commissioner for Data Protection (BayLfD)
    0981 / 53-1300

    France

    Ian Kelley
    +33 01 70395992

    Commission Nationale de l'Informatique et des Libertés
    +33 (0)1.53.73.22.22

    Ireland

    BMO Real Estate Partners
    enquiries@bmorep.com

    Office of the Data Protection Commissioner
    +353 (0761) 104 800

    Gibraltar

    BMO Real Estate Partners
    enquiries@bmorep.com

    Gibraltar Regulatory Authority
    (+350) 20074636

    BMO Capital Markets

    Capital Markets Ltd

    France

     

    BMI Compliance
    BMICompliance@bmo.com

    Commission Nationale de l'Informatique et des Libertés
    +33 (0)1.53.73.22.22

    Switzerland

    Federal Data Protection and Information Commissioner (FDPIC)
    +41 (0) 58 462 43 95

    Luxembourg

    National Commission for Data Protection
    (+352) 26 10 60 - 1

    London Branch

    UK

    Information Commissioner’s Office
    0303 123 1113

    BMI

    Ireland

    Office of the Data Protection Commissioner
    +353 (0761) 104 800

    Pyrford

    UK

    Business Unit Compliance Officer information@pyrford.co.uk
    +44 (0) 20 7495 4641

    Information Commissioner’s Office
    0303 123 1113

  • ANNEX A: Definitions

    BMO Financial Group means Bank of Montreal and all of its subsidiaries

    Data Subject the person to whom the Personal Data relates. A BMO Financial Group entity established in the EEA determines the purposes and means for which this person’s Personal Data is processed.

    Direct Marketing is our communication with you such as mail, telemarketing or email, using your contact information, to inform you about products and services that we think may be of interest and value to you. This does not include communications regarding products or services that you currently have, including improved ways to use the products, or additional features of the products as well as transactional information.

    EEA means the European Economic Union

    Personal Data is any information relating to an identified or identifiable Data Subject, i.e. one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. For the purposes of this Privacy Code, Personal Data is that which a BMO Financial Group entity established in the EEA processes.