Quintessence Wealth (QW, us, we) is committed to protecting your privacy and the confidentiality of your Personal Information (as defined below). QW is guided and governed by applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA) substantially similar privacy legislation, which regulates our collection, use and disclosure of your Personal Information.
This privacy policy describes how QW’s collects, uses, and discloses your Personal Information. It applies to all Personal Information that you provide to QW, including Personal Information that you provide to our advisor, that you send us by email, or that you input into our website. Please read this policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Information.
QW also maintains a
Cookie Policy, which describes how QW uses cookies to run our website.This privacy notice is subject to change in response to changes in laws and/or periodic reviews of QW’s operations. At minimum this privacy notice will be reviewed and approved annually by QW’s Chief Compliance Officer.
Personal Information
The term “Personal Information” refers to information that identifies you as an individual and is provided to or collected by us. It includes, for example:
• Personal identifiers, such as your name, email address, mailing address, phone number, identification numbers such as your social insurance number (SIN), Internet Protocol (IP) addresses, and signatures. It also includes other identifiers necessary to conduct “know your client” activities (for example, information about named beneficiaries and/or spouses and partners).
• Demographic data, such as your age, date of birth, and gender.
• Your financial information, including your assets, debt, investment objectives, risk tolerance, investment knowledge, financial situation and circumstances. • Information collected for money laundering, sanctions, financial crimes and fraud prevention checks, such as actual or alleged criminal convictions and offences.
• Internet or other electronic network activity information, such as browser type, Internet service provider (ISP), referring/exit pages, pages viewed on our site.
• Professional or employment-related information, such as your professional title and occupation.
Collection and use of Personal Information
QW collects and uses Personal Information to:
• Provide you with services, including delivering investment advice and finding suitable investments for you.
• Communicate with you, including responding to your inquiries.
• To improve our services, including by conducting research.
• Comply with our regulatory obligations, including our obligations under securities legislation and anti-money laundering legislation to verify the identity and reputation of clients.
• For other legal purposes, including to comply with any applicable law, regulation, or valid court order, to prevent and detect fraud, and to defend and enforce our legal rights.
Consent
When you open an account with us, you consent to us collecting and using your Personal Information. In some cases, your consent may be “implied” (i.e., your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information).
We will generally obtain consent when we want to use Personal Information for a new purpose or for purposes other than those stated at the time of collection. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
Protecting Personal InformationYour Personal Information is protected by reasonable administrative, physical, and technical security safeguards that are commensurate with the sensitivity and volume of the information. These include:
• Restricting access to Your Personal Information to a limited number of people;
• Encryption;
• Multi-factor authentication;
• Logging and monitoring software.
All employees of QW are responsible for protecting client privacy, confidentiality and security. This obligation remains in effect even after an employee leaves QW.
Sharing Personal InformationQW does not disclose Personal Information for purposes other than those for which it was collected, except with your consent or as required by law.
In providing services to clients, QW may be required to share Personal Information with its employees, and other financial institutions. All QW staff are required to keep client Personal Information private and confidential. Further, each staff member is required to sign our Compliance Manual Code of Conduct, which contractually obligates them to respect and protect clients’ Personal Information.
QW may transfer Personal Information to our service providers, agents, vendors or other organizations that provide services to QW, for the purposes set out in this policy. These include preparing income tax slips, cloud services, processing transactions or other data processing.
Our service providers are given only the information necessary to perform the required service and are subject to regulatory requirements imposing data security obligations on the ways in which they process Personal Information. Specifically, we require our service providers and data processors to have appropriate security procedures and controls in place to protect Personal Information in a manner that is consistent with our Privacy Policy and the security practices and regulations applicable in their country of jurisdiction.
When we store your Personal Information or engage a service provider that operates outside of Canada, your Personal Information may be stored, processed, accessed, or used in another country. In that case, your Personal Information may be subject to the law of the jurisdiction in which it is used or stored, including any law permitting or requiring the disclosure of the information to a government, government agency, court, or law enforcement agency of that jurisdiction. QW stores data on servers in Canada and the United States. The countries in which our service providers operate are Canada and the United States.
For Quebec residents: Please note that your information may be stored outside of Quebec.
Retention of Personal Information
Personal information will be retained only as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your Personal Information will be securely destroyed or anonymized (so the information no longer identifies you).
Your Privacy RightsAccess and rectification: With some limited exceptions, you have the right to access and update Personal Information held by QW. You may also request that QW correct, cancel, and stop processing personal information that QW holds about you. If QW agrees the Personal Information is incorrect, or the processing should be stopped, QW will correct the Personal Information or stop its processing. If QW does not agree the Personal Information is incorrect, QW will inform you it does not agree. We will record that you consider Personal Information to be incorrect in your file.
For Quebec residents: You may request an explanation of a decision rendered exclusively via the automated processing of your Personal Information (where applicable). You may also request that your Personal Information be provided to you in a structured, commonly used technological format.
Exercising your rights: Please contact your Portfolio Manager to update or correct your Personal Information.
For further assistance, please send us an email to the contact listed below. For security purposes, we may require that you provide your full name, address and telephone number and a copy of an identity document (such as an ID card or passport) through a secured portal before we provide you with access to your Personal Information. QW will contact you if it needs additional information.
UpdatesWe may make changes to this policy from time to time. Any changes we make will become effective when we post a modified version of the policy on this webpage. If we make any significant changes to the policy, we will post a notice on our website. By continuing to use our services and our website after the modified version of the policy has been posted, you are accepting the changes to the policy, subject to any additional requirements which may apply. If you do not agree to the changes in our policy, it is your responsibility to stop using our services and our website. It is your obligation to ensure that you read, understand and agree to the latest version of this policy. The “Effective Date” at the top of the policy indicates when it was last updated.
Contact UsIf there are any questions regarding this policy or our collection, use or disclosure of your Personal Information, you may contact us using the information below:
