Assante Connect (“Assante Connect”) is a division of WealthBar Financial Services. We are concerned with safeguarding and protecting the privacy of your personal information. In accordance with Canada's Personal Information Protection & Electronic Documents Act (“PIPEDA”) we have established policies on how we collect, use and protect any information that you give us when you use our website or services.
Why do we collect personal information?
We collect personal information for various reasons. Usually, it relates to meeting our regulatory, legal or contractual requirements to provide portfolio management services to you. We also collect personal information so our business can deliver products and services that are best suited to our client’s needs.
For example, we collect information about your use of our website for the purposes of improving the web services we make available. Due to the nature of web servers, we may also collect your IP address if you visit our website.
What personal information do we collect?
Required Regulatory Information
We collect limited personal information that is required to provide services, which is collected on our secure web based applications and forms including, but not limited to name, date of birth, Social Insurance Number (“SIN”), personal financial information and contact information. We also collect information about your interactions with us when engaging our services through our website and client services department. As part of account operations, we also generate information which may include your personal information such as account numbers, market values account statements, and tax receipts.
Passive Data Collection
We may receive passively-collected information through a variety of methods, such as “cookies”, to collect information.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie.
When sending e-mails, we may use tracking pixels and urls to help us measure open rates for e-mails and link clicks. This tracking information is used internally only to help us provide relevant content and is never shared with any third parties.
Opting Out of Cookies
If you choose, you may set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it.
Analytics and Marketing
We use analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our online Sites and/or Services.
We also use online advertising to reach new potential clients and remarketing tools that allow us to target ads to specific groups of people who have previously interacted with our marketing campaigns.
Google allows individuals to opt out of its advertising cookies from its ad settings page and has additional information on the Restrictions page.
How do we collect personal information and obtain your consent?
We collect personal information about you from various sources that include but are not limited to:
- application forms and other information provided by you in writing, by telephone, in person, electronically or by other means;
- your activity on the web site and transactional activity in your accounts, including account balances, investments, withdrawals and fees/commissions;
- other interactions with us, such as discussions with our staff;
- the advisor who invited you onto Assante Connect.
Wherever possible, we seek a person’s consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative, such as your financial advisor or their dealership.
Your personal information will be collected via our website and application form(s), in which case you will formally indicate your consent for us to collect and use the personal information by registering, entering the information on our form. The information may also be provided to us by your financial advisor, in which case, by virtue of account opening, your consent is implicitly provided to us to collect and use the information. In this case, at the time of initial collection of your personal information by your financial advisor, you will have provided consent to your advisor to disclose your personal information for the purposes of effecting investment transactions, including the opening of accounts with us.
How do we protect and store personal information?
How is your information stored?
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In the event that we share your personal information with third-party service providers, affiliates and agents in the normal course of operating and managing your account, these parties will be required to adhere to strict confidentiality obligations and practices.
Where is your personal information kept?
Your personal information may be kept in electronic or paper format in our offices, in secure off-site storage facilities, or in the offices of our service providers.
We may use third parties to store and process data. We will ensure that such third party service providers have significant expertise with data and digital privacy and that personal data is stored and transmitted in encrypted format using technology.
We may store your personal information via third party entities that reside in foreign jurisdictions. As a result personal information may be subject to that jurisdictions privacy law which may differ from Canadian privacy law. Information may be transferred to, accessed and/or retained by third parties pursuant to data storage agreements that are necessary to provide you services. We and/or a third party may be compelled, by law or otherwise, to provide information to a third party, subject to applicable privacy law. We must abide by applicable privacy legislation in the jurisdiction(s) in which we operate.
How do we use your personal information?
The information we collect is used so we can communicate with you, provide wealth management services,
improve our products and services, and meet our regulatory obligations.
We share only the information which is reasonably required in the normal course of business with third parties such as our custodians, securities regulators, auditors, legal counsel, or law enforcement agencies, to enable them to fulfill their obligations to us and our clients. We may also disclose your personal information to third-party service providers, affiliates and agents in order to assist us in providing the services you requested and to fulfill the purposes for which your personal information has been collected. Outside of this we shall not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.
To whom do we disclose your personal information?
Access to personal information within Assante Connect will be restricted to those staff members who need the information in order to carry out their job duties. Those employees are required to maintain the information in the strictest of confidence and will not provide access to the information to anyone who is not authorized.
Your personal information may also be shared with Assante Connect’s affiliates, including but not limited to: CI Investments Inc., First Asset Management Inc. and Assante Wealth Management Ltd., for the purpose of understanding our business, clients and the product and service that are best suited to their needs. We may also share your information with our affiliates for the purpose of fraud or crime prevention, suppression or detection purposes. Sharing your personal information allows us to help you meet your financial goals and provide you the best possible products and services. You may opt-out of the sharing of your personal information with the Inviting Advisor and their dealership for these purposes by forwarding a written request to our Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.
Other third parties that may also be provided with your personal information include:
- Your financial planner and/or financial planning company;
- Our legal representatives;
- Other financial institutions, securities dealers and mutual fund companies;
- Canadian, provincial and municipal governments, government agencies and regulators (for example Canada Revenue Agency or the Ontario Securities Commission) as required by law or legal process; and
- Authorities investigating (or who could potentially investigate) alleged fraudulent or suspicious transactions in relation to your account or any other account on which you are authorized to act.
We do not sell your personal information to third parties.
How can you access or correct your personal information held by Assante Connect?
Individuals do not always need to use their right under PIPEDA to access to or correct their personal information (e.g. informal request) with Assante Connect. Clients are encouraged to utilize our online platform to access the personal information that we have on file or to contact our client services department to correct their information. However, subject to certain restrictions, you have the right to formally request access or corrections of your personal information. To make a formal request for access send a written request addressed to our Privacy Officer (contact details below). Please include your full name, address, telephone number and account number(s) on any correspondence to us and provide enough detail to allow us to identify the information you want.
Upon request, we will provide you with access to your personal information we have on record at the time of the request. Please note that we may not be able to provide you with this information in certain circumstances, for example, where such information: contains references to other persons; contains proprietary information confidential to us or your financial advisor; has been destroyed or is too costly to retrieve; is subject to legal or some other form of privilege; or cannot be disclosed for legal reasons or relates to an investigation.
Withdrawing your consent
Subject to certain restrictions and reasonable notice, you may withdraw your consent for the collection and use of your personal information at any time by forwarding a written request to our Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.
In some circumstances, legal requirements may prevent you from withholding consent. In addition, your decision to withhold consent may also limit the products and services that we may provide to you and may require you to close your accounts with us.
How long do we keep your information?
We only keep your personal information as long as it is necessary to do so. The length of time we keep your information will depend upon the product or service and the nature of the information and will be only as long as it is legally necessary for us to retain sufficient information to respond to any inquiries that may arise later.
Questions, concerns or complaints?
490 - 1122 Mainland St.
Attn: Privacy Officer
If you believe that any information we have on file for you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.