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Privacy policy
Last Modified date: October 2019
At Aviso, we know that our clients are concerned about their personal information and we are committed to protecting the confidentiality and security of the information entrusted to us. Our Privacy Policy is part of a comprehensive program that ensures that our policies, procedures and security measures are adequately complied with by our employees and representatives. The policies and practices we have implemented meet the standards set out in the Personal Information Protection and Electronic Documents Act (Canada) and other applicable laws. Aviso has a designated Chief Privacy Officer who is responsible for maintaining and implementing our Privacy Policy.
Interpretation and Application
In this Privacy Policy:
- “Aviso”, “we” or “us” refers to Aviso Wealth Inc. and each of our subsidiaries, including Credential Qtrade Securities Inc., Credential Asset Management Inc., Qtrade Asset Management Inc., Northwest & Ethical Investments L.P., Credential Insurance Services Inc., Qtrade Insurance Solutions Inc., Credential Financial Strategies Inc. and any other entities that may become part of Aviso from time to time;
- “personal information” includes any factual or subjective information about an identifiable individual; and
- “Referring Organization” means the credit union, caisse populaire, portfolio manager or other financial organization that you have a relationship with and/or that referred you to us, and that we may work in partnership with to provide products and services.
This Privacy Policy applies to all clients of Aviso and is designed to explain the manner in which we handle your personal information. Our Chief Privacy Officer is accountable for compliance with the principles described in this Privacy Policy and for the design and oversight of our privacy program generally. We have established procedures to protect personal information, to respond to complaints and inquiries, to provide ongoing employee training, and to ensure that clients and other individuals who contact us or visit our website can access our policies.
Privacy Principles
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.
Collecting Your Personal Information
As regulated entities, Aviso’s companies are required to obtain certain information about you in the course of providing products and services to you. We will only collect your personal information in a fair and lawful manner. We obtain most of the information directly from you through your interactions with us (whether in writing, verbally, electronically or otherwise), and we may also collect information from other sources, including from your Referring Organization, other financial institutions, credit reporting agencies and other third parties, in each case as approved by you 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 any information essential to do so.
What We Collect and How We Use It
The information we collect will depend on the products and services that you ask us to provide. The types of information that we generally collect and a description of how we use such information are as follows:
Name and Contact Information
This information allows us to identify you and send you statements and other important or required notices. It also allows us to communicate with you to obtain instructions and respond to your requests and inquires.
Date of Birth
This information allows us to fulfill our legal obligation to ascertain your identity and also helps protect against error, identity theft and fraud. We may also use this information to determine your interest in other products and services that we offer.
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.
Employment and Financial Information
We collect this information to better understand your unique financial situation and investment needs, and to help us provide appropriate investment advice. We may also use this information to determine your interest in other products and services that we offer.
Health Information
This information is required for certain types of insurance products.
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 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
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
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
To comply with any applicable laws, including but not limited to the rules of securities regulators, anti-money laundering regulations, tax legislation and trustee requirements, and to cooperate with appropriate authorities.
Understanding client needs and business requirements
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.
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.
Sharing Your Personal Information
In connection with providing you products and services and operating your account, we may share your personal information with certain other parties.
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 from time to time. In the course of performing their duties, our authorized employees or representatives may have access to personal information. They may only access the information strictly necessary to perform their duties. Employees 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.
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 use your personal information to refer you to other products and services that it offers, to refer you to the products and services offered by Aviso, and to better understand and manage its overall relationship with you.
Service Providers
We disclose information to third party service providers retained by us to perform specialized services, such as preparing and mailing statements, confirmations and notices, providing secured data storage, transacting trades on behalf of clients, and providing other services in connection with your account. In these cases, we only disclose the specific information required to perform the services. Our service providers must undertake to use client information solely for the purposes of carrying out the services they have been retained to provide, and must agree to implement and maintain appropriate safeguards and security measures. Some of our service providers may be located outside of Canada and may store and process your information outside of Canada or access your information from a location outside of Canada.
Securities Regulators, Government Agencies and Law Enforcement
We are required to share your information with securities authorities that oversee our business (such as the Investment Industry Regulatory Organization of Canada, the Mutual Fund Dealers Association of Canada 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 applicable privacy legislation.
Safeguarding Your Personal Information
We have an information protection program in place to protect your personal information against unauthorized access 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.
Our Chief Privacy Officer is accountable for ensuring that our Privacy Policy is properly administered and that our security measures are up to date and effective.
Accessing and Updating Your Personal Information
You can request access to the personal information we hold about you. Your request must be written and provide us with sufficient detail to enable us to identify you and your personal information. Within thirty (30) days of your request, we will provide you details of what personal information we have, how we collected it, how we use it, and to whom it has been disclosed. 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. If you are not satisfied you may contact the applicable federal or provincial Privacy Commissioner.
We rely on you to inform us in a timely manner of any changes or corrections to your information. 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.
Retaining Your Personal Information
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.
Withdrawing Your Consent
Subject to legal, regulatory and contractual requirements, you may contact us at any time to withdraw your consent. We will explain your options and any consequences of withdrawing your consent. If you do not consent to certain uses or sharing of your personal information, we may be unable, or limited in our ability, to provide you with certain products or services.
Online Privacy
We do not, without your knowledge, collect any personal 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 personal information.
Our websites contain a number of links to websites of third parties. We are not responsible for the content of these websites or how these parties treat or protect 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.
Procedure for Handling Privacy Concerns
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 Client Relations Officer at 1 877 787-2330. 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 endeavour to provide a response within thirty (30) days. If after contacting our Chief Privacy Officer your concern remains unresolved, you may contact the applicable federal or provincial Privacy Commissioner.
Updating This Policy
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.aviso.ca/en/privacy.