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Privacy Policy (Clients)

PRIVACY POLICY (CLIENTS)

Protecting your personal information is important to Altium.

This policy addresses the collection, use and disclosure of personal information by Altium Wealth Architecture Inc., its representatives and agents (“Altium”, “we” or “us”). This policy is intended to meet the standards of the Personal Information Protection and Electronic Documents Act and its regulations, as well as substantially similar provincial privacy laws and regulations, including the Act respecting the protection of personal information in the private sector (Quebec) and the Personal Information Protection Act (British Columbia).

The term “personal information” means any information that directly or indirectly identifies an individual.

1. Collection of Your Personal Information

Altium collects personal information about you, including:

  • your personal circumstances and contact information (e.g., name, address, telephone number, email, date of birth, marital status, social insurance number, government identification numbers, etc.), including to establish your identity;
  • your financial and professional situation (e.g., employment status, income, assets, debts, investment accounts, financial transactions, risk profile, investment knowledge, etc.); and
  • other individuals related to the products and services we offer to you (e.g., personal information about your spouse, common-law partner, dependent(s), beneficiary(ies), guardian, attorney(s), trusted contact person(s), etc.).

Altium limits the collection of personal information to that which is permitted by law and necessary to serve you well. This personal information is generally collected directly from you, including in person, over the phone, in writing or online. It may also be obtained from persons authorized to represent you in your interactions with us or from publicly available sources. With your consent or if permitted by law, information about you may also be obtained from other third parties (e.g., another organization, credit reporting agency, etc.).

2. Use of Your Personal Information

Altium only uses your information with your consent or as permitted by law. Your personal information may be used for the following purposes, among others:

  • help us better serve you and manage our business;
  • communicate with you using the contact information you have provided to us;
  • verify your identity, update your information, and ensure its accuracy;
  • better understand and assess your personal and financial situation;
  • establish your investor profile, financial needs and goals, and investment strategies;
  • determine your eligibility for the products and services we offer and ensure that they are suitable for you;
  • offer you or provide you with our products and services as well as those of partners (e.g., a custodian), including to open and manage your accounts, process your instructions and provide you with investment and financial planning advice;
  • manage risk and comply with applicable laws and regulations;
  • preventing, detecting and controlling fraud and other illegal activities (e.g., money laundering, cyber threats);
  • to allow the due diligence of our business in the context of a business transaction; and
  • to help us, with the help of questionnaires, statistics and analyses, to better understand of our clients' current and future needs or satisfaction.

3. Sharing Your Information

Sharing your personal information with others is sometimes necessary. This may include disclosure that is required by law, necessary to protect your interests or to offer you products or services. At all times, we are committed to limiting the disclosure of personal information to what is necessary and, when required, to obtaining your consent.

We may share your information, in accordance with applicable legal requirements, to:

  • a person who holds an account jointly with you;
  • a person acting for you, at your request or at our request, including a custodian, investment professional, dealer, securities transfer agent and any other professional (accountant, tax specialist, lawyer, notary, etc.) you designate;
  • a credit reporting agency, partner or agent acting for us;
  • third parties, if we need to disclose your information in connection with legal proceedings;
  • a regulatory or governmental authority, including provincial securities regulators or self-regulatory organizations;
  • a person authorized by law to obtain it;
  • third parties involved in a business transaction; and
  • suppliers of products and services that we use to perform certain tasks. These providers include providers of technology (e.g., applications, data storage and hosting), professional services, insurance, communications, marketing, etc.

4. Your Rights to Accept or Refuse to Provide Personal Information or to Withdraw Your Consent

You have the right to refuse to consent to the collection, use or disclosure of your personal information. You may also withdraw your consent to our use and disclosure of personal information. However, some personal information is essential for us (and/or partners such as the custodian) to provide you with certain products and services. If you refuse to provide essential personal information or withdraw your consent, it may not be possible to establish or maintain a business relationship with you or to offer you certain products or services. For example, in certain circumstances, we are required by applicable laws and tax authorities to obtain, use and disclose your social insurance number (SIN) for tax purposes.

5. Your Right to Access and Correct Your Personal Information

In order to serve you well, it is essential that your personal information be accurate and complete. By contacting us using the contact information set out in Section 7, you may request access to the personal information we hold about you (except where there are legal limitations) to review its content and accuracy and to amend it if necessary.

6. Protection of Personal Information

We are committed to the protection of your personal information and ensure that our suppliers and partners are serious companies that share this concern. Altium ensures that it takes reasonable measures to protect your personal information, including through technological means (use of passwords, firewalls, etc.) and physical means (secured offices, locked filing cabinets, etc.). Altium also ensures that its employees are aware of the importance of protecting personal information.

We primarily retain your personal information and correspondence in Canada for as long as necessary to fulfill the purposes for which it was collected or as permitted or required by law (including tax and anti-money laundering laws).

Altium, its suppliers or partners to whom your personal information is disclosed under this policy may operate outside of Quebec and Canada. As a result, your personal information may be used and stored in other provinces and countries. In some cases, your information may be subject to the laws and rights of access by authorities in foreign countries, including the United States.

7. Contact Us

If you have any questions or would like to access or change your personal information, make a complaint or withdraw your consent, we invite you to contact our Chief Privacy Officer by email (compliance@altium.ca), telephone (1-800-932-3032) or mail (1130 Sherbrooke Street West, Suite 400, Montreal, Quebec, H3A 2M8). We may ask you for information and/or documents to confirm your identity.

8. Amendments to this Policy

This policy may be amended by Altium from time to time. If applicable, we will notify you by means of an update on our website or by any other appropriate mean to reach you.

Last revised: April 2024