Last updated: September, 2023

Aviso follows 10 fair information privacy principles which outline the rules for the collection, use, and disclosure of personal information, as well as for providing access and correction to personal information.

At the heart of our commitment to clients are the following principles concerning the collection, use and disclosure of personal information:

Accountability

We are responsible for protecting personal information that is in our control or is transferred to third parties for processing on our behalf. Our Chief Privacy Officer is accountable for ensuring our compliance with the principles described in this Privacy Policy.

Identifying Purposes

The purposes for which personal information is being collected will be identified and explained before or at the time of collection.

Consent

We will obtain informed consent prior to collecting, using and disclosing personal information, except as otherwise permitted or required by law.

Limited Collection

Personal information will be collected by fair and lawful means, and we will only collect the information that is needed for the specific purposes identified to our clients.

Limiting Use, Disclosure and Retention

We will use and disclose personal information only for the purposes we have identified to our clients, except as otherwise permitted or required by law. We retain personal information only for as long as reasonably required to serve those purposes.

Accuracy

We keep personal information as accurate, complete and up to date as possible to properly satisfy the purposes for which it is to be used.

Safeguards

We safeguard personal information with appropriate protective and security measures relative to the sensitivity of the information.

Openness

Within a reasonable time after receipt of a request, we will provide easily understandable, specific information on our personal information management policies and procedures.

Access

Our clients have the right to review the personal information we have about them, except where we are required or permitted by law to deny access. We encourage our clients to verify the accuracy and completeness of the information and inform us of any necessary corrections.

Challenging Our Compliance

If an individual has any concerns about our collection, use or disclosure of their personal information, they may request that our Chief Privacy Officer investigate the matter and respond within a reasonable time.

With your consent, we collect and use personal information to establish and manage our relationship with you, provide you with products and services, and comply with legal and regulatory requirements. We will only collect your personal information in a fair and lawful manner. We obtain personal information primarily by requesting it from you directly. We may also collect your personal information from other sources such as your Referring Organization, other financial institutions, credit reporting agencies and other third parties. In each case collection only takes place following your consent or permitted by law.

The decision to provide us with your personal information rests with you. However, we may be limited in our ability to provide certain products and services to you if you decline to provide us with required information.

We collect personal information for the following purposes, each purpose requires specific types of information that is outlined below:

Required Identification and Verification: We are required to collect certain information for identification purposes. Examples include name, address, email address, telephone numbers, date of birth, and government issued identification documents.

Optional Identification and Verification: With your express consent, we collect certain optional identification information to improve the client experience and fraud prevention. Examples include biometric information such as a fingerprint, voice print, or facial scan.

Tax Reporting: We are required to collect certain information for tax reporting purposes: Examples include Social Insurance Number, residency information, citizenship status, marital status, etc.

Using your SIN for Non-Tax Purposes: With your consent, we may also use your Social Insurance Number (SIN) as a unique identifier in situations where it is necessary to keep your personal information separate from that of other customers or individuals with similar names, for internal matching of your personal records against records received from authorized third parties, and to help maintain the accuracy of your personal information.

Credit Reporting and Monitoring: With your consent, we collect credit information about you from credit reporting agencies. 

Communications: We collect your contact information and use it to communicate to you in the form of phone, fax, mail, email, SMS, text message or other electronic means.

Financial Assessment: We require certain information to better understand your unique financial situation and investment needs. Examples include employment, education, income, assets, liability, credit, and payment history. We may use this information to provide appropriate investment advice or to determine your interest in other products and services that we offer.

Marketing Communications: We may collect information such as phone number, fax number, address, email address so that we can contact you to provide marketing updates about new products and services, offers, events and promotions. If you do not wish to receive these communications, you can withdraw your consent at any time by clicking the unsubscribe link in the communication. We may also use services provided by third-party platforms (such as social networking and other websites) to serve relevant advertisements on such platforms to you and others. We may provide a de-identified version of your email address to the platform provider for such purposes.

To participate in contests, surveys, or promotions: We may collect your name, phone number, email address, and other information if you participate in a contest, survey, or promotion. We will use this information to manage your participation in the contest as described when you enter. If a contest or promotion is administered by a third party (such as a loyalty program partner), we may share information with the third party as described to you at the time of entry into the contest or promotion.

To provide you with insurance products: We may collect personal health information from you. This information is required for certain types of insurance products that we offer.

Account Operation: We use your personal information to establish and operate your accounts with us, to determine your eligibility for, inform you about and provide you with products and services, and to fully understand and meet your needs. We may also use your personal information as necessary or appropriate for the following purposes:

Conducting or responding to audits: We collect and use personal information in relation to our or your Referring Organization’s audit purposes, intended to assist in protecting you from illegal or fraudulent activity.

Investigating issues and settling claims: We collect and use personal information in connection with the investigation and resolution of issues, including disclosing your information to insurance providers, regulators, law enforcement, lawyers or other third parties involved.

Complying with legal and regulatory obligations: We collect and use personal information to comply with any applicable laws, including but not limited to the rules of securities regulators, anti-money laundering and “know your client” regulations, tax legislation and trustee requirements, and to cooperate with appropriate authorities.

Understanding client needs and business requirements: We collect and use personal information to help us better understand client habits and preferences, monitor customer needs and demands, review and improve products and services, and forecast future business requirements. If we determine it is necessary to use personal information for study or research purposes or for the production of statistics and analytics, we will do so with your consent or use de-identified information.

Monitor traffic: We may collect the IP address of the device you use to visit our website(s). Our website(s) have cookies that inform us, at an aggregated level, how our website is being used, how many people have visited our website and what pages were viewed.

Other information: We may collect other information about you as required in connection with the products and services requested, such as citizenship or residency information, marital status and spousal information, which we use to comply with our legal and regulatory obligations.

We use your personal information exclusively for the purposes described in this Privacy Policy, and for no other reason unless specifically agreed to by you or required by law. We do not rent or sell your personal information to any third parties.

In the course of business, we may share your personal information with certain other parties for purposes described below.

Across Aviso and our Employees

Aviso has centralized operations for some administrative, operational, marketing and other functions. Accordingly, we may share information between the companies that are part of the Aviso organization (“Aviso affiliates”) from time to time. In the course of performing their duties, our authorized employees or representatives of all Aviso affiliates may have access to personal information. They may only access the information strictly necessary to perform their duties. Employees of all Aviso affiliates are required to adhere to our Code of Business Conduct & Ethics, under which they commit to protect the confidentiality of client information and to act in compliance with applicable laws and Aviso’s policies and procedures. For clients located in the province of Quebec, this means that our Aviso affiliates may store and process your information outside of the province of Quebec.

Your Referring Organization and other Financial Organizations

Aviso works in close partnership with your Referring Organization and other financial organizations, which are separate legal entities, to provide you with a range of products and services. Allowing us to share your personal information with these entities helps us fulfill our commitment to provide you with the best possible service and ensures you benefit from our full range of available products and services. With your consent, these entities may contact you for marketing purposes, use your personal information to refer you to other products and services that they offer, to refer you to the products and services offered by Aviso, and to better understand and manage their overall relationship with you.

Service Providers

We disclose information to third party service providers retained by us to process or handle personal information. Our service providers perform specialized services, such as preparing and mailing statements, confirmations, and notices, providing secured data storage, transacting trades on behalf of clients, marketing (by telephone or electronic means), advertising, research, analytics, and providing other services in connection with your account on our behalf. In these cases, we only disclose the specific information required to perform the services. Our service providers must undertake to use and retain client information solely for the purposes of carrying out the services they have been contracted to provide and must agree to implement and maintain appropriate safeguards and security measures.

We partner with service providers throughout Canada and abroad. For clients located in the province of Quebec, this means that our Canadian service providers may store and process your information outside of the province of Quebec. In addition, some of our service providers may be located in jurisdictions other than Canada and may store, process, or access your information outside of Canada. Please note that the privacy laws in such jurisdictions may differ from Quebec and Canada privacy laws. Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to applicable foreign legal requirements, including lawful requirements to disclose personal information to government authorities and law enforcement in certain circumstances.

Joint Account Holders, Representatives, Executors and Beneficiaries

We share personal information with joint account holders or legal representatives (for example legal guardian, lawyer, or power of attorney). Joint account holders will have access to your transaction details and account history for the account. We may also share personal information with your (or joint account holder’s) estate representatives or beneficiaries where reasonably necessary to administer the estate.

Securities Regulators, Government Agencies and Law Enforcement

We are required to share your information with authorities that oversee our business (such as the Canadian Investment Regulatory Organization and other regulators). These organizations require access to personal information of clients, employees, agents, directors, officers, partners and other individuals for regulatory purposes, including surveillance of trading-related activity, sales, financial compliance, trade-desk review and audit, investigation of potential regulatory and statutory violations, regulatory databases, enforcement or disciplinary proceedings, reporting and information-sharing with applicable authorities, regulated marketplaces, and law enforcement agencies in any jurisdiction.

We may also be compelled to disclose information in response to a legally valid demand, inquiry, proceeding or other order. In these cases, we take steps to ensure the request is valid and we only disclose the specific information necessary to satisfy the inquiry or order. 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. In such circumstances, we will verify the legitimacy of the court order and will take reasonable steps to limit the amount of personal information that is disclosed to that which is necessary to satisfy the court order. 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.

Other Third Parties

If you request a product or service that requires us to extend credit to you, we may obtain information about you through a credit check or from references that you have provided to us. We will only do so with your consent. If you do not consent, we may not be able to extend credit to you.

As we continue to grow, we may expand, sell, or reorganize our businesses. We may disclose your personal information in such a business transaction if permitted by law. The receiving party must collect, use, and disclose the information only for the purposes for which you initially granted your consent to us. Such party will also be subject to take the necessary measures to ensure the protection of the confidentiality of the information, to destroy the information if the commercial transaction is not completed or if its use is no longer necessary, and the party is subject to applicable privacy legislation.

We have an information protection program in place to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification, and misuse. We use a variety of security measures to protect your personal information including:

• physical measures, such as locked fireproof cabinets, restricted access to offices and document shredding;
• organizational measures, such as restricted access to files and data centers;
• technological measures, such as network security, strong authentication and data encryption, password protection; and
• ongoing employee privacy and data security training.

We have agreements and controls in place with our third party service providers requiring that they must safeguard any personal information we provide them or any personal information they collect on our behalf and require that they use the personal information only for the purpose of providing the service we have requested them to perform.

We make our employees and other representatives aware of the importance of maintaining confidentiality of personal information. Each of our employees and representatives is responsible for respecting and protecting the personal information to which the employee or representative has access. The only employees who are granted access to your personal information are those with a business ‘need to know’ where their duties reasonably require such information.

You are responsible for helping to protect the security of your personal information. For instance, safeguard and never give out your information or passwords associated with the services.

You can request access to the personal information we hold about you. Your request must be written and should provide us with sufficient detail to enable us to identify you and your personal information.

Requests can be provided via several channels:

• In person, at an office location
• Via email to privacyofficer@aviso.ca
• Via letter to

Attn: Chief Privacy Officer
700 - 1111 West Georgia Street
Vancouver, BC V6E 4T6

We will respond to your request within thirty (30) days. If we need more time to fulfill your request or require further information from you, we will inform you. In some instances, it may be inappropriate to provide you with information that constitutes proprietary data, is protected by solicitor-client privilege, would compromise the confidentiality of another individual’s personal information or is restricted or permitted to be withheld by law. We will provide an explanation if we are unable to meet your request or if an extension is required to process the request. If you are not satisfied, you may contact the applicable federal or provincial Privacy Commissioner.

We are committed to maintaining the accuracy of your personal information and ensuring that it is as complete and up to date as needed for the identified purposes. We do not routinely update your personal information unless an update process is necessary. We rely on you to inform us in a timely manner of any changes or corrections to your personal information. Failure to notify us of changes to your personal information may negatively impact the way we communicate with you, provide services to you, and/or fulfill our legal and regulatory obligations. If a change or correction is required, please provide an update through our online client portal or by contacting your advisor or a Client Relations Officer at 1-877-787-2330. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend it as required. Where appropriate, we will transmit any material amendments to your personal information to affiliates or third party service providers having access to your personal information. If we do not agree to make the amendments that you request, you may challenge our decision by contacting us as described in the Section below “Procedure for Handling Privacy Concerns”.

We retain your personal information for as long as reasonably necessary to provide you with the products or services you have requested and to meet legal and regulatory requirements. The length of time your personal information is retained may vary according to the product or service and the sensitivity and nature of the information. This period may extend beyond the termination of our relationship for as long as it is reasonably necessary for legal, business or other purposes. We may destroy, delete, erase or convert your personal information to an anonymous form if it is no longer required for the identified purposes.

Subject to legal and regulatory requirements, where you have withdrawn your consent or we no longer have a business relationship with you, you have the right to request that we cease disseminating your personal information or request that we de-index (de-link or anonymize) your personal information. 

We do not, without your knowledge, collect any personally identifiable information about you while you are visiting our websites. However, we do collect non-identifying information such as IP addresses, browser types, pages viewed, the time and date of your visit, which site you came from, plus any ads you may have clicked on to reach our websites. This information helps us to understand how our websites are used and how visitors find us. This information also assists us in planning improvements to better meet visitor needs. This information cannot in any way be used to personally identify a visitor.

You may be asked to provide information that allows us to enhance our websites or to answer inquiries or surveys about our products and services. Your participation is optional. We will collect information from you when you take part in an online survey, subscribe to a newsletter or mailing list, participate in an online promotion or contest, or email us an inquiry. If you participate in such an activity and provide your email address, it may reveal personal information such as your name and organization. Any information you provide will be kept confidential and will only be used to respond to your comments or questions. Note that email inquiries may not be encrypted, and others could view the contents of your message. Do not include confidential or personal information in email messages.

We use cookies on our websites, which help us track usage and determine which areas are popular. A cookie is a piece of information that is stored on your web browser by a particular website. The website can later retrieve this information from your computer when you visit the site again. Cookies do not contain any personally identifiable information. Please see our Aviso Online Digital & Cookie Notice at www.qtrade.ca/en/investor/privacy-policy.html. for more information on how to manage your cookies.

Our websites contain several links to websites of third parties that we do not own or operate. We provide these links to third party websites as a convenience to you. These links are not intended as an endorsement or, or referral to the linked websites. The linked websites should have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have control over these websites and are not responsible for the content of these websites or how these parties treat or protect personal information. Therefore, we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, secure, and otherwise treat your personal information. Please review their privacy notices for more information on how they process your personal information. Be careful when you send information over the Internet. Any unprotected communication over the Internet is not confidential and is subject to possible interception, loss or alteration.

If you feel that the confidentiality of your personal information has been compromised, or if you have any questions about your personal information or your dealings with us in this regard, we encourage you to contact us. In most cases, your concern can be resolved by discussing it with your advisor or a Service Centre representative at the toll-free phone numbers listed below.

Aviso 1-855-714-3800
Qtrade 1-877-787-2330
Qtrade Guided Portfolios 1-844-622-4500
NEI 1-888-809-3333

If they are unable to address your concern to your satisfaction, you may contact our Chief Privacy Officer at:

Aviso Wealth Inc.
Attn: Privacy Officer
700 - 1111 West Georgia Street
Vancouver, BC V6E 4T6
Telephone: 1-877-787-2330
Email: privacyofficer@aviso.ca

Our Chief Privacy Officer will investigate your question or concern and endeavor to provide a response within thirty (30) days. If after contacting our Chief Privacy Officer your concern remains unresolved, you may file a complaint with the Office of the Privacy Commissioner of Canada:

30 Victoria St.
Gatineau QC
K1A 1H3

Toll-free: 1 800 282-1376
Phone: 819 994-5444
TTY: 819 994-6591
www.priv.gc.ca

We may update or modify our Privacy Policy from time to time as we deem appropriate or necessary to reflect any changes in our business, applicable regulations or industry practices. The current version of our Privacy Policy can be found on our website at www.qtrade.ca/en/investor/privacy-policy.html. 

We may also notify you of any changes to the Policy in any of the following ways:

• Digitally, by mobile app or email;
• A notice on the Aviso subsidiary website;
• A notice by mail