Confidentiality policy

Allard, Allard & Associés Inc. (“AA&A”, “we”, “us” or “our”) undertakes to protect your privacy and personal information. The objective of this Confidentiality Policy is to inform you about our confidentiality practices, including how we collect, use and disclose your personal information.

This Confidentiality Policy concerns our website https://allard-allard.ca/, hereinafter referred to as the “Website”, and all our activities, unless a separate Confidentiality Policy has been provided for a particular product, service or activity.

Please read this Confidentiality Policy carefully. By submitting your personal information, registering for or using any of the services we offer, using our Website or interacting voluntarily with us, you give your consent that we may collect, use and disclose your personal information in accordance with this Confidentiality Policy, as revised from time to time.

CONTENTS OF THIS CONFIDENTIALITY POLICY:

1. Consent to the collection, use and disclosure of personal information

2. Collection of personal information

3. Use of personal information

4. Disclosure of personal information

5. Procedure to unsubscribe from our communications

6. Retention of personal information

7. Protection of personal information

8. Rights with respect to your personal information

9. International information transfer and storage

10. Third-party websites and services

11. Privacy Officer

12. Updates

13. Contact us
    

1-     Consent to the collection, use and disclosure of personal information

We collect, use and disclose personal information with your consent or to the extent permitted or required by law. The manner in which we obtain your consent (i.e., the consent form that we use) depends on the circumstances, as well as on the sensitivity of the information collected. Subject to applicable law, your consent may be explicit or implicit, depending on the circumstances and the sensitivity of the personal information in question.

You may withdraw your consent to the collection, use or disclosure of your personal information at any time by contacting us at the address indicated in the “Contact us” section below. However, before finalizing the withdrawal of your consent, we may require proof of your identity. In certain cases, withdrawing your consent may mean that we are no longer able to provide you with certain products or services.

If you provide us with personal information about someone else, you are responsible for obtaining his or her consent for us to collect, use and disclose his or her information, as described in this Confidentiality Policy.

2-    Collection of personal information

“Personal information” is defined as any information concerning a “natural person” (i.e. private individual) and making it possible to identify him or her. The personal information we collect typically falls within one or more of the following categories:

• Forms or documents relating to our business activities, such as:

  • AA&A account application forms

  • Account application forms required by our depositaries

  • Client profile forms

  • Management agreement

  • Investment policy

• Meetings, telephone conversations or email exchanges

• Website:

  • “Subscribe” section: when you subscribe to our newsletter, we collect your email address.

  • “Contact us” section: when you contact us using our online form, we collect your first and last names, your email address and any other information you provide.

  • “Employment – Apply for a job”: when you apply for a job, we collect your name, email address, résumé and any other information you provide.

  • Technical information – Cookies: with your consent, we may collect certain types of technical and device-related information on your use of our Website. This information may include your IP address, information on your device, browser and/or operating system, as well as the date and time of your visit. Our Website uses cookies or other technologies. For further information, please refer to our Cookie Policy.

3- Use of personal information

We may use your personal information and other information to:

• Meet our “know-your-client” obligations.

• Open a securities account with our broker.

• Verify your identity.

• Communicate with you in accordance with the laws governing our services.

• Respond to information requests and other queries.

• Meet our legal obligations.

• Make full use of, maintain, improve and provide access to all of the features of the Website, in addition to providing question-answering services and assistance to users of the Website.

• Send you our newsletter.

• Monitor and improve our Website and, as applicable, develop new services and send you surveys or satisfaction questionnaires.

• Combat fraud and money laundering.

• Investigate legal claims.

We may use your personal information and other information for the purposes for which your consent was obtained, as well as for any other purposes that may be authorized or required by applicable law.

We do not use the information we collect to advertise third-party products/services or for the targeted advertising of AA&A’s products/services on third-party websites or service offers.

4- Disclosure of personal information

We may provide your information to our service providers, as well as to our partners, in particular to provide you with our services. In that case, we take steps to ensure that the rules set out in this Confidentiality Policy are complied with. We also require service providers to safeguard the confidentiality and security of your personal information. For further information on our service providers, please contact us at the address listed in the “Contact us” section below.

A non-exhaustive list of our third-party service providers that may handle your personal information (with links to their respective confidentiality policies) is provided below:

• National Bank Independent Network (“NBIN”) – https://www.nbc.ca/privacy-policy.html

• Royal Bank of Canada (“RBC”) – https://www.rbc.com/privacysecurity/ca/index.html

• Microsoft – https://www.microsoft.com/en-ca/trust-center/privacy

• Mailchimp – https://www.intuit.com/privacy/statement/

In addition, we may use and disclose your information if we believe such use or disclosure is authorized, necessary or appropriate: (a) under applicable laws, including laws outside your country of residence; (b) to comply with legal proceedings; (c) to respond to requests made by public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the provisions of the agreement governing our products and services; (e) to safeguard our activities or those of our affiliates or subsidiaries; (f) to protect our rights, privacy, security or property, and/or those of our affiliates and/or of yourself or other persons; and (g) to enable us to pursue all available legal remedies or to limit the damages we may sustain. We may also transfer your personal information and other information to a third party in the event of a restructuring, merger, sale, joint venture, assignment, transfer or other provision involving all or part of our activities, trademarks, affiliates, subsidiaries or other assets.

If we plan to disclose your personal information to a third party, we will identify the third party. We will also state the reason for the disclosure and will obtain your consent.

5- Procedure to unsubscribe from our communications

You may choose to no longer receive marketing emails by clicking on the “Unsubscribe” link at the bottom of each email you receive from us. You may also unsubscribe by contacting us directly at the address listed in the “Contact us” section below.

We will strive to respond swiftly to your unsubscribe request, although we ask you to allow us a reasonable period of time to process your request.

6-     Retention of personal information

We will only use, disclose or retain your personal information for as long as necessary to achieve the objectives for which this personal information was collected and to the extent permitted or required by law. For further information on the length of time during which your personal information will be retained, please contact us at the address listed in the “Contact us” section below.

7-     Protection of personal information

We have put in place physical, organizational, contractual and technological security measures to protect your personal information and other information against loss, theft, unauthorized access, disclosure, copying, use or modification.

Despite the above-mentioned measures, no method of transmitting or storing information is 100% secure or error-free. Therefore, unfortunately we cannot guarantee absolute security. If you have reason to believe that your interaction with us is not secure (e.g., if you believe that the security of the information you provided has been compromised), please contact us immediately at the address listed in the “Contact us” section below.

8-     Rights with respect to your personal information

We take all necessary measures to ensure that your personal information is as accurate, complete and up to date as is reasonably necessary. We will not systematically update your personal information unless necessary. You are expected to provide us with periodic updates on your personal information if necessary.

You may submit a written request to consult the personal information we collect, use or disclose concerning you; you will be provided with this personal information as required by law. You may also challenge the accuracy or completeness of the personal information we have on file concerning you. If you demonstrate that your personal information on file is inaccurate or incomplete, we will modify it as required.

You may also withdraw your consent regarding the disclosure or use of the personal information we collected.

In addition, under certain circumstances, you have the following rights:

• You may request that your personal information on file no longer be disclosed.

• You may request information on the use of automated decision-making systems and on the impact they may have on you.

To avail yourself of those rights, please contact us at the address indicated in the “Contact us” section.

In response to requests to access or correct your personal information, we may require you to provide sufficient proof of identity. Your ID-related information will only be used for the stated purposes.

9-     International information transfer and storage

Your personal information is currently stored in Canada and/or in a country in which we have service providers, in particular the United States.

Your personal information is therefore transferred to countries other than your country of residence, which may have different confidentiality rules than those in effect in your country. In that case, your personal information is subject to the laws of the country in which they are stored and may be disclosed to governments, courts or other official bodies tasked with enforcing the laws or regulations of that country and in accordance with the laws of that country.

However, our personal information practices remain governed by this Confidentiality Policy at all times. As applicable, we will comply with the requirements of Canadian law by offering adequate protection for personal information transfers, in particular by putting in place appropriate safeguards such as template contractual provisions.

10-     Third-party websites and services

This Confidentiality Policy only applies to our products and services. It does not extend to third-party websites or to third-party products or services. We assume no responsibility for third-party confidentiality practices. You are encouraged to consult the confidentiality policies of third parties prior to using their websites, products or services.

11-     Privacy Officer

AA&A has designated its Chief Compliance Officer as its Privacy Officer.

12-     Updates

We will update this Confidentiality Policy from time to time to reflect changes in our practices, technology, legal obligations and other factors. Please consult the “Last updated” section at the bottom of this page for information on the most recent update to this Confidentiality Policy. Unless otherwise indicated, any modifications to this Confidentiality Policy will take effect as soon as they are posted on this page. By using the Website following a modification, you agree to the practices set out in the updated Confidentiality Policy.

13-     Contact us

If you have any questions or comments about this Confidentiality Policy or your personal information, or if you would like to access or rectify your information, submit a complaint or obtain information on our policies, you may contact us:

• By email: privacy@allard-allard.ca

• By regular mail: 9001 Boulevard de l’Acadie, Suite 401, Montreal, Quebec H4N 3H5

Last updated: May 1, 2023