Privacy Policy

1. Information We Collect

1.1 Personal Information

We collect personal information that you provide directly to us when you use our services, including:

• Full name, date of birth, and government-issued identification numbers
• Contact information including address, email address, and telephone number
• Social Insurance Number (SIN) when required for regulatory compliance
• Employment information and income details
• Financial information including account numbers and transaction history
• Digital signatures and authentication credentials

1.2 Automatically Collected Information

When you access our digital platforms, we automatically collect certain information:

• Device information including IP address, browser type, and operating system
• Usage data such as pages visited, time spent on pages, and navigation patterns
• Location data based on IP address or GPS (with your permission)
• Cookies and similar tracking technologies
• Session information and authentication logs

1.3 Information from Third Parties

We may receive information about you from third-party sources including credit bureaus, identity verification services, fraud prevention agencies, and other financial institutions as permitted by law and necessary for providing our services.

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Provision

• Processing and managing your accounts and transactions
• Verifying your identity and preventing unauthorized access
• Providing customer support and responding to inquiries
• Facilitating electronic transfers and payment processing
• Maintaining and improving our digital platforms

2.2 Regulatory Compliance

• Complying with anti-money laundering (AML) regulations
• Meeting Know Your Client (KYC) requirements
• Fulfilling reporting obligations to regulatory authorities
• Preventing and detecting fraud and financial crimes
• Responding to legal requests and court orders

2.3 Business Operations

• Analyzing usage patterns to improve our services
• Conducting risk assessments and management
• Developing new products and features
• Sending service-related communications and updates
• Conducting internal audits and quality assurance

2.4 Marketing Communications

With your consent, we may use your information to send you promotional materials about products and services that may interest you. You can opt out of marketing communications at any time by following the unsubscribe instructions in our emails or contacting us directly.

3. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers

We share information with trusted third-party service providers who assist us in operating our business, including payment processors, technology providers, data analytics firms, and customer service platforms. These providers are contractually obligated to protect your information and use it only for the purposes we specify.

3.2 Financial Institutions

We may share information with other financial institutions, payment networks, and clearing houses as necessary to process transactions, verify account information, and facilitate financial services on your behalf.

3.3 Regulatory and Legal Requirements

We disclose information when required by law or in response to:

• Subpoenas, court orders, or legal processes
• Requests from government agencies and regulatory bodies
• Law enforcement investigations
• Requirements under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act
• Other legal obligations under Canadian federal and provincial laws

3.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and the choices you may have regarding your information.

3.5 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so, such as when you authorize us to share information with a financial advisor or accountant.

4. Data Security Measures

We implement comprehensive security measures to protect your information from unauthorized access, disclosure, alteration, and destruction:

4.1 Technical Safeguards

• 256-bit SSL/TLS encryption for data transmission
• Advanced encryption standards (AES) for data at rest
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Intrusion detection and prevention systems
• Secure data centers with physical access controls
• Regular software updates and security patches

4.2 Administrative Safeguards

• Strict access controls limiting employee access to personal information
• Comprehensive employee training on privacy and security
• Background checks for employees with access to sensitive data
• Confidentiality agreements with all staff and contractors
• Incident response and breach notification procedures
• Regular privacy impact assessments

4.3 Physical Safeguards

• Secure facilities with controlled access
• Video surveillance and alarm systems
• Secure disposal of physical documents containing personal information
• Locked storage for sensitive materials

5. Your Privacy Rights

Under Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), you have the following rights:

5.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your information in a commonly used format within 30 days of your request, subject to certain legal exceptions.

5.2 Right to Correction

If you believe any information we hold about you is inaccurate or incomplete, you have the right to request corrections. We will update your information promptly and notify any third parties to whom we have disclosed the information, where appropriate.

5.3 Right to Withdraw Consent

You may withdraw your consent for certain uses of your information at any time, subject to legal or contractual restrictions. Please note that withdrawing consent may affect our ability to provide certain services to you.

5.4 Right to Deletion

You may request deletion of your personal information, subject to our legal and regulatory obligations to retain certain records. We will delete or anonymize your information where legally permissible.

5.5 Right to Object

You have the right to object to certain processing of your information, including direct marketing. We will honor your objection unless we have compelling legitimate grounds to continue processing.

5.6 Right to File a Complaint

If you believe we have not handled your personal information appropriately, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or your provincial privacy commissioner.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with legal and regulatory requirements:

• Account information: Duration of the relationship plus 7 years after account closure
• Transaction records: Minimum 7 years as required by financial regulations
• Identity verification documents: 7 years after relationship ends
• Marketing consent records: Until consent is withdrawn plus 3 years
• Customer service records: 3 years from last interaction
• Website usage data: 24 months unless longer retention is required

After the retention period expires, we securely delete or anonymize your information in accordance with our data retention and disposal policies.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our website and mobile applications:

7.1 Types of Cookies We Use

• Essential Cookies:Required for website functionality, security, and authentication
• Performance Cookies:Help us understand how visitors use our website
• Functional Cookies:Remember your preferences and settings
• Analytics Cookies:Collect information about website usage and performance

7.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our services. Most browsers allow you to refuse cookies, delete existing cookies, or receive notifications when cookies are set.

8. International Data Transfers

Your information is primarily stored and processed in Canada. In some cases, we may transfer your information to service providers located outside Canada, including in the United States. When we do so, we ensure appropriate safeguards are in place through contractual agreements that require these providers to protect your information in accordance with Canadian privacy standards. Your information may be subject to the laws of the jurisdiction where it is processed.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors without parental consent. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately so we can delete such information.

10. Compliance with Financial Regulations

As a financial services provider in Canada, we comply with various federal and provincial regulations:

• Personal Information Protection and Electronic Documents Act (PIPEDA)
• Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA)
• Provincial privacy legislation where applicable
• Financial consumer protection regulations
• Anti-spam legislation (CASL)
• Guidelines from the Office of the Superintendent of Financial Institutions (OSFI)

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. For significant changes, we may provide additional notice such as email notification or a prominent notice on our website. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. Contact Information for Privacy Concerns

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer:

13. Additional Resources

For more information about privacy rights in Canada, you may contact:

• Office of the Privacy Commissioner of Canada
  Website: www.priv.gc.ca
  Toll-free: 1-800-282-1376
• Financial Consumer Agency of Canada
  Website: www.fcac-acfc.gc.ca
  Toll-free: 1-866-461-3222