Personal Data Protection and Management Policy

In carrying out our responsibilities, we must collect personal and confidential information relating to our clients that is necessary for the performance of our tasks. We are committed to protecting personal information collected from our clients. This policy explains the practices for collecting, using and disclosing personal information about clients, as well as measures adopted to ensure that it is treated appropriately.
Our policy is in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), a federal privacy law, and the Respecting the protection of personal information in the private sector Act (chapter P-39.1).

Definition of “Personal information”

Personal information means any information that concerns a natural person and allows him to be identified, in particular: name, age, social insurance number, annual income, net worth, social status, banking information, accounts, financial objectives, risk tolerance, investment strategies, files relating to loans, investment orders as well as legal decisions in matrimonial and estate matters, a copy of which is kept in the client’s file. This concept does not concern information relating to companies and other legal persons.

Policy Implementation

The implementation of this policy has been entrusted to Mélanie Pelletier, Personal Information Protection Officer. Not only this person has the high task of ensuring compliance with the various laws applicable to the protection of personal information, but she is required to ensure the circulation of information as well as the training of the members of the organization on the procedures and practices od this policy. The application of this policy is part of an ethical framework that favors prudence in the collection, use and disclosure of personal information as well as the confidentiality of client’s orders and transactions. Ultimately, this person will be responsible for receiving inquiries an complains regarding this policy.

Consent

We are committed to collecting the personal information of a client necessary for the constitution of his file only if he has given clear, free, and informed consent. This consent will be required when the information is first collected.

Use and Disclosure for Specific Purposes

We are committed to using and disclosing personal information only for the purposes for which it was collected. Our employees or agents will be able to read it, provided that this information is necessary for the exercise of their functions or the execution of their mandates.
In addition, we may transmit to third parties the personal information collected for the purposes set out below, particularly to mutual funds, to government departments and agencies for which we are required by law to do so, to insurance, to our IT provider, to courier companies and with the written consent of the person concerned, to any other person who requests it.

Access to Personal Information

Under section 27 of the Respecting the protection of personal information in the private sector Act, any person who so requests and who proves his identity may have the existence of his file confirmed and may obtain communication of personal information concerning him. In addition, under article 30 of the law, any person who so requests and who proved his identity may have access to his file or may have his file rectified. This request must be made in writing by the person concerned to Mélanie Pelletier, who will respond to this request within 30 days of its reception.
Access to personal information will be free subject to reasonable fees that may be charged for transcription, reproduction, or transmission. If charges are payable, the client will be informed in advance.
Access to personal information may be refused in any of the following situations: the personal information contains details of other individuals; the disclosure of the personal information could affect an investigation by our internal department; the disclosure could have an effect on legal proceedings in which Pelletier Wealth Management has an interest; the impossibility of reproducing personal information because of the medium on which it is held. Furthermore, any refusal will be motivated and notified in writhing to the person concerned.

Communication of Personal Information to Third Parties

In the cases provided for in articles 18 and following of the law, a company may, without consent of the person concerned, communication information that it holds about him. Mélanie Pelletier will be the only competent person to determine whether this article applies in the event of such request. This request must be made in writing to be considered.
For requests not covered by articles 18 and following of the law, article 13 of the same law stipulated the following: “No one may communicate to a third party the personal information contained in a file that holds on another person or use it for purposes irrelevant to the subject of the file, unless the person concerned consents thereto or this present law provides for it”.
Any request for information or documents made by a third party to us concerning a client must be sent in writing to Mélanie Pelletier, accompanied by the “consent to the communication of personal information to an authorized third party” form. “Third party” means any person, organization or company that is not the person concerned by the request. Unless otherwise provided by law, Mélanie Pelletier will be required to obtain the consent form for the communication of personal information to an authorized third party and will have to meet with the client concerned to obtain his signature and authorization.
Once the client’s written consent has been received, our Personal Information Protection Officer will undertake to transmit, within 30 days of receipt of the third party’s request, the information and/or documents requested and will at the same time transmit to the client, by mail, a true copy of the letter sent to the third party, copies of the documents that will be attached to it, a copy of the letter of request from the third party as well as a copy of the consent signed by the client. We will need to identify the information or documents that may be transmitted. Failing to obtain the written consent of the person concerned, we will not be able to transmit anything whatsoever to anyone except by order of the Commission d’accès à l’information or a competent court. The Compliance Department will notify the requesting third party in writing of the omission or refusal of the person concerned by the request to consent to the transmission of the requested information or documents.
Only Mélanie Pelletier is authorized to transmit, under the conditions listed above, information or documents to third parties.
Any other person who gives or transmits any information or documents to a third party will be solely responsible for any damages that this fact may cause to the person concerned or to Pelletier Wealth Management.

Security Measures and Record Retention

We are committed to ensuring the protection of personal information held by appropriate measures, against loss or theft as well as against unauthorized consultation, communication, copying, use or modification. The protective measures used by Pelletier Wealth Management will apply regardless of the form of medium used: paper, computer or other.
The protective measures used include, among others, material means such as the use of an alarm system, magnetic keys giving access to the building, restricted traffic areas allowing access to our offices controlled by codes digital files as well as the locking of certain filing cabinets. In addition, access to our computer system is secured at two levels. First access to computer network requires the possession of a username and a password. Second, access to certain databases also require possession of a username and password. Only authorized personnel may have access to the computer network. Only authorized personnel have access to the personal information necessary to carry out their activities.
Duration of the data conservation
We will retain personal information for as long as necessary to fulfill the identified purposes. The minimum retention period for books, registers and client files will be that prescribed by regulation, i.e., 7 years from the date the file is closed.

Destruction of Personal information

Any destruction of files, books, registers, or documents containing personal information must be carried out while respecting the confidential nature of this information.
Inquiries and Complaints Procedures
In the event of a refusal to provide a client with personal information concerning him or non-compliance with one of the principles set out above, the client will have the opportunity to formulate his comments, concerns, or complaints to the attention of:

Pelletier Wealth Management

Care of Mélanie Pelletier
Personal Information Protection Officer
7900 boul. Pierre Bertrand, Suite 300
Québec (QC) G2J 0C5

Breach of confidentiality

As soon as an employee or agent is informed of a real or potential breach of confidentiality, he must immediately contact Mélanie Pelletier. Immediately after being informed, this person must make all necessary and reasonable efforts to minimize the impact of such a breach of confidentiality and must ensure that the situation is restored as soon as possible. Among other things, the person in charge must immediately notify the client concerned of the breach of confidentiality concerning him so that he can take the appropriate and required measures to protect himself adequately.