ALTIUM WEALTH ARCHITECTURE INC.
1. Our Privacy Philosophy
2. Our Policy
“You” refers to anyone who visits our website, our clients and investors in our funds, and anyone who engages with our services. It’s our duty to inform you about what we’re doing with your personal information and why, and ensure you are properly informed so you can give us meaningful consent.
You have the right to withdraw your consent from us collecting and using your personal information, but this may limit our ability to provide you with our services or products, if applicable. See below for details around same.
4. Types of Information Collected
The type of information that may be collected includes but is not limited to:
- Contact information: this information allows us to identify you as well as send you materials. It lets us communicate with you for instructions and requests. It includes your name, mailing address, email address, and telephone number;
- Banking information: including your bank account information, billing address, or other banking and financial information required to complete your order;
- Date of birth: this information allows us to fulfill our legal obligation to establish your identity and also helps protect against error, identity theft, and fraud;
- Employment History: we collect this information to better understand your unique financial situation and investment needs, and to help us fulfill our suitability obligations;
- Social Insurance Number: we obtain your Social Insurance Number (SIN) for tax reporting purposes. We may also use your SIN for credit reporting or monitoring purposes, and to distinguish you from other persons or clients;
- Information required to comply with applicable laws and regulations: including your date of birth, home address, marital status, employment history, criminal record history, bankruptcy history, disciplinary history, passport, driver’s license, SIN, Tax Identification Number (TIN), investment history, account numbers, if there is a spousal account or not, performance of investments, size of investments, etc.;
- Profile information: includes your username and password, requests made by you, your interests, preferences, feedback, and survey responses;
- Transaction information: includes details about payments to and from you and other details of subscriptions and redemptions you have requested from us, including product information and dollar values;
- Marketing and communications information: includes communication preferences and your preferences in receiving marketing or other communications from us and third parties;
- Computer information: this includes information like device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use; and
- Other information you voluntarily provide to us, our employees, our service providers or our contractors.
Information will be collected by fair and lawful means. We won’t take more information than we need, and you decide how and what you want to share.
5. Why We Collect Your Information
At Altium, we collect and use personal information for reasons like:
- Fulfillment of subscription/redemption requests and other services: to fulfill subscription/redemption requests and access services with us;
- Business and website operations: to administer and protect our business and this Website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
- Marketing and advertising: to be presented on our Website. We may also administer surveys, contests, draws, raffles, offer tailored content, and other promotional materials to you based on your interests;
- Regulatory requirements: complying generally with all laws and applicable regulatory requirements, including securities legislation and regulations, know your client obligations, AML regulations, FATCA and CRS reporting, client reporting, CRA obligations, and confirmation of resident status; and
- Business development and market research: we use data to understand demographics, interests, usage patterns, and other characteristics of customers and to track and analyze trends and patterns.
6. How We Collect Your Information
Personal information may be collected in a number of ways, including: through our Website, in person, by mail, by email, from our applications or other software, and from third parties such as investment advisors and dealers whom you have authorized to disclose personal information to us.
If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.
Cookies can be used to: (i) recognize you when you visit the Website, remember your preferences, and give you a personalized experience that’s in line with your settings, (ii) make your interactions with the website faster and more secure, and (iii) bring you advertising and customized experiences through personalization. Further, cookies are used for authentication, security, and research.
b) Social media
If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website or other applications, your communications may be viewable by the public.
7. Who We Share Your Information With
Altium may share your information with third parties. Altium will do so to support with providing our services, administering our business, and for such other purposes as set forth below, including:
- Fund managers of investment funds in which you invest: sending your personal information to fund managers if you invest in one or more of their funds as part of the subscription and redemption process;
- Contractors, service providers and affiliates: sending duplicate T3s to wealth advisors who request a copy of their clients’ T3s, and sharing your information with companies we use for storage, processing, and delivery of services;
- Administrative and technical support: including cloud storage providers, IT support, and data analytics providers;
- Public media and marketing: including media networks and companies we use for public broadcasting, advertising, marketing, public relations, and press releases;
- Financial institutions and payment processors: we do not store your banking or other financial information in connection with the fulfillment of subscription/redemption requests. This is shared directly with our third party financial institutions and payment processors as applicable, all of which are separate legal entities, to provide you with a range of products and services; and
- Securities and tax regulators: including applicable governmental and regulatory entities required as part of securities and tax law compliance such as submitting exempt trade reports to securities regulators.
We may also disclose personal information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk. We may be ordered by a court to disclose personal information to a third party or to the court, or to preserve personal information pending the outcome of a legal hearing. We may also be legally required to disclose information in connection with the collection or repayment of a debt, to assist in the prevention of fraud or other criminal activity, when we obtain legal advice from a lawyer, or in an emergency that affects the health or safety of an individual.
In the instances described above we may be required to share your personal information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.
If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
We make every reasonable effort to keep your personal information as accurate, complete and up-to-date as necessary. We encourage you to verify the accuracy and completeness of your personal information in our records.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
9. Protecting Your Personal Information
Our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information.
To ensure that your personal information is protected, we utilize security safeguards that are on par with industry standards. We keep electronic files in a secured environment with restricted access and use.
Despite all of the foregoing security measures, online storage and online communications are not entirely secure. We encourage all individuals to provide only the information they are comfortable with providing a third party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible. As a community, we can all help keep it safe.
You may withdraw your consent for our use and collection of your personal information at any time, however this may limit our ability to provide services or products to you, if applicable.
13. Governing Law
14. Personal Information Outside of Canada
Personal information provided to our service providers may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
15. Addressing Your Inquiries and Concerns
Attention: Chief Compliance Officer
Altium Wealth Architecture Inc.
1130 Sherbrooke Street West, Suite #400
Montréal (QC) H3A 2M8
Last revised: November 2021