Privacy Policy

Protecting your Privacy is important to us!

At Aviso, we understand the importance of your Personal Information and are committed to protecting the confidentiality and security of the information entrusted to us. Our Privacy Policy is part of a comprehensive program which includes Aviso providing employees and representatives with ongoing privacy training and awareness and promoting a culture of privacy compliance at Aviso. The policies and practices we have implemented meet the standards set out in applicable laws. Aviso has a designated Chief Privacy Officer who is responsible for maintaining and implementing our privacy program, including this Privacy Policy. 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, among other things, established procedures to protect Personal Information, respond to complaints and inquiries, provide ongoing training, and to ensure that clients and other individuals who contact us or visit our websites can access our policies.

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Interpretation and Application

In this Privacy Policy:

  • “Aviso”, “we” or “us” refers to Aviso Wealth Inc. and each of our subsidiaries, including Aviso Financial Inc. (including divisions Aviso Wealth, Qtrade Direct Investing, Qtrade Guided Portfolios and Aviso Correspondent Partners), Northwest & Ethical Investments L.P., Credential Insurance Services Inc., Aviso Insurance Inc. and any other entities that may become part of Aviso from time to time.
  • “Personal Information” means information that identifies you or can be used to identify you. Examples of Personal Information include but are not limited to name, address, telephone number, email address, health information, date of birth, social insurance number (“SIN”), government issued identification, credit history, employment or education information, transaction history, and assets, income and liabilities information.
  • “Referring Organization” means the credit union, caisse populaire, portfolio manager, affiliate partner or other financial or non-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 is designed to explain the manner in which we handle your Personal Information.

Note: This Privacy Policy applies to Personal Information.  It includes information that you have provided to us or that we collect from other sources.  Personal Information may be factual or subjective, as well as recorded or not.

Services and Channels: This Privacy Policy applies to all clients of Aviso across all products and services offered by Aviso and to all channels through which we provide those products and services, including in-person interactions, over the phone, and online.

Jurisdiction and Regulation: This Privacy Policy applies to our operations in Canada.  The practices described in this Privacy Policy are subject to applicable Canadian federal and provincial / territorial privacy laws for the private sector in the jurisdictions in which we operate.

No Persons Under the Age of Majority: We do not knowingly solicit from, and our services are not intended for, persons under the age of majority in their jurisdiction (“Minors”).  Minors should not provide us with their Personal Information, except under the permission and supervision of their parents or guardians.  If a parent or guardian becomes aware that their Minor child has provided us with information, the parent or guardian should contact us as detailed in the “Procedure for Handling Privacy Concerns” section below.

Collecting your Personal Information

With your consent, we collect and use Personal Information to establish and manage our relationship with you, provide you with products and services, and comply with legal and regulatory requirements. We will only collect your Personal Information in a fair and lawful manner. We obtain Personal Information primarily by requesting it from you directly. We may also collect your Personal Information from other sources such as your Referring Organization, financial institutions, credit reporting agencies and other third parties. In each case collection only takes place with your consent or as permitted by law.

The decision to provide us with your Personal Information rests with you. However, our ability to provide certain products and services to you may be limited if you decline to provide us with the required information.

What is Collected and How it is Used

We collect specific types of Personal Information for the following purposes:

  • Required Identification and Verification: We are required to collect certain information for identification purposes. Examples include name, address, email address, telephone number, date of birth, and government issued identification.
  • Optional Identification and Verification: With your consent, we collect certain optional identification information to improve client experience and for fraud prevention. Examples include biometric information such as a fingerprint, voice print, and facial scan.
  • Tax Reporting: We are required by law to collect, use, and disclose certain information for tax reporting purposes and to fulfill other regulatory requirements. Examples include SIN, residency information, citizenship status, and marital status.
  • Using your SIN for Non-Tax Purposes: With your consent, we may also use your SIN as a unique identifier in situations where it is necessary to keep your Personal Information separate from that of other customers or individuals with similar names, for internal matching of your personal records against records received from authorized third parties, and to help maintain the accuracy and security of your Personal Information.
  • Credit Reporting and Monitoring: With your consent, we collect credit information about you from credit reporting agencies and other third parties.
  • Communications: We collect your contact information and use it to communicate with you in the form of phone, fax, mail, email, SMS, text message or other electronic means.
  • Financial Assessment: We require certain information to understand your unique financial situation and investment needs. Examples include employment, education, income, assets, liabilities, credit, and payment history. We may use this information to provide investment advice and/or to offer products and services.
  • Marketing Communications: We may collect information such as phone number, fax number, address, and email address in order to contact you to provide information about products and services, offers, events and promotions. If you do not wish to receive these communications, you can withdraw your consent at any time. We may also use services provided by third-party platforms (such as social networking and other websites) to serve relevant advertisements on such platforms to you and others.
  • To participate in contests, surveys, or promotions: We may collect your name, phone number, email address, and other information if you participate in a contest, survey, or promotion. We will use this information to manage your participation in the contest as described when you enter. If a contest or promotion is administered by a third-party (such as a loyalty program partner), we may share information with the third-party as described to you at the time of entry into the contest or promotion.
  • Account Operation: 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 for the following purposes:
    • Conducting or responding to audits: We collect and use Personal Information in relation to our or your Referring Organization’s audit purposes, intended to assist in protecting you from suspicious, illegal or fraudulent activity.
    • Fraud Management: Your Personal Information may be utilized to help protect both you and us against fraud risks and errors. This includes preventing, detecting, and suppressing any financial abuse, fraud, or criminal activity, and enhancing security measures. To safeguard our assets and interests, as well as yours, we may collect, use, and disclose your Personal Information to assist with both external and internal fraud investigations. These investigations may pertain to suspected or actual illegal or suspicious activities, or to manage, defend, or settle any potential or actual losses related to such activities. This Personal Information may be sourced from you, your Referring Organization, or another financial institution or entity. Additionally, we may disclose your Personal Information to any person or organization, fraud prevention agency, regulatory or government body, operator of any database or registry used to verify information, or other financial/lending institutions for the purpose of fraud management.
    • Investigating issues and settling claims: We collect and use Personal Information in connection with the investigation and resolution of issues, including disclosing your information to insurance providers, regulators, law enforcement, legal counsel or other third parties involved.
    • Complying with legal and regulatory obligations: We collect and use Personal Information to comply with any applicable laws, including but not limited to the rules of securities regulators, anti-money laundering and “know your client” regulations, tax legislation and trustee requirements, and to cooperate with appropriate authorities.
    • Understanding client needs and business requirements: We collect and use Personal Information 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. If we determine it is necessary to use Personal Information for study or research purposes, or for the production of statistics and analytics, we will use aggregated and/or de-identified information.
    • Monitor traffic: We may collect the IP address of the device you use to visit our websites. Our websites have cookies that inform us, at an aggregated level, how our websites are being used, how many people have visited our websites and what pages were viewed.
    • Automated decision making: We may use artificial intelligence, machine learning and automated decision-making technologies in connection with or to enhance our business operations, including the products and services we offer. These technologies help us analyze data, improve user experience, and support decision-making processes. Where such technologies are used, appropriate safeguards are in place to protect the confidentiality and security of the information entrusted to us and to ensure compliance with applicable laws.
  • Employment information: If you inquire about or apply for a job with Aviso or any of our affiliates, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter or similar employment related materials). Aviso uses this information for the purpose of processing and responding to your application for current and future career opportunities.
  • Other information: We may collect other information about you as required in connection with the products and services requested and/or provided to you, such as citizenship or residency information, marital status and spousal information, which we use to comply with our legal and regulatory obligations. You should not give us information about another person unless you have the right to give us their information, and you have their consent for Aviso to collect, use and disclose their information in accordance with this Privacy Policy.

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 third-parties.

Sharing your Personal Information

We may share your Personal Information for the purposes described below.

Across Aviso

Aviso has centralized operations for administrative, operational, compliance, marketing and other functions. Accordingly, we may share information amongst our group of companies (Aviso subsidiaries and their divisions) from time to time. In the course of performing their duties, our authorized employees and representatives may have access to Personal Information. They may only access the information strictly necessary to perform their duties. All Aviso employees are required to adhere to Aviso’s 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.  For clients located in Québec, this means that Aviso may store and process your information outside of Québec.

Your Referring Organization and other Financial Organizations

Aviso works in close partnership with your Referring Organization and other third-party financial organizations to help you achieve your financial goals and provide you with a wide range of products and services. Allowing us to share your Personal Information with these third-parties helps us provide you with financial products and services that may be of interest and benefit to you. With your consent, these third-parties may contact you for marketing initiatives, use your Personal Information to refer you to other financial products and services offered and/or requested, refer you to the financial products and services offered by Aviso, to better understand the interests of our current and prospective clients, and to manage the overall relationship with you.

Service Providers

We disclose information to third-party service providers retained by us to process or handle Personal Information in connection with the products and services we offer. Our service providers perform specialized services, such as preparing and mailing statements, confirmations, and notices, providing secure data storage, transacting trades on behalf of clients, marketing, advertising, research, analytics, and providing other services in connection with your account on our behalf. In these cases, we only disclose the specific information required to perform those services. Our service providers must undertake to use and retain the personal information solely for the purposes of carrying out the services they have been contracted to provide and must agree to implement and maintain appropriate safeguards and security measures.

We also share aggregated information in the form of insights, trends or analytics that do not identify you to our service providers for purposes including product and services improvement, and supporting business development, for example by creating sales performance insights and supporting development of customer demographic and behavioral insights. We also share aggregated information with trusted third-parties for benchmarking, understanding, and forecasting spending patterns and macroeconomic trend analysis. Aviso does not rent or sell your Personal Information.

We partner with service providers throughout Canada and abroad. For clients located in Québec, this means that our Canadian service providers may store and process your information outside of Québec. In addition, some of our service providers may be located in jurisdictions other than Canada and may store, process, or access your information outside of Canada. Please note that the privacy laws in such jurisdictions may differ from the privacy laws of Québec and Canada. Reasonable contractual or other measures we may take to protect your Personal Information while processed or handled by these service providers are subject to applicable foreign legal requirements, including legal requirements to disclose Personal Information to government authorities and law enforcement in certain circumstances.

Joint Account Holders, Representatives, Executors and Beneficiaries

We share Personal Information between joint account holders and with each of the respective account holder’s legal representatives (for example legal guardian, lawyer, or power of attorney). Joint account holders will have access to each other’s transaction details and account history for the joint account. We may also share your Personal Information with your (or joint account holder’s) estate representatives or beneficiaries where reasonably necessary to administer the estate. 

Securities Regulators, Government Agencies and Law Enforcement

We are required to share your information with authorities that oversee our business (such as the Canadian Investment Regulatory Organization 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. 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 inquiry or order and will take reasonable steps to limit the amount of Personal Information that is disclosed to that which is necessary to satisfy the inquiry or 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 legal counsel, 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 as permitted by law. The receiving party would collect, use, and disclose the information only for the purposes for which you initially granted your consent to us. Such a party would also be subject to applicable privacy legislation and would be required to take the necessary measures to ensure the confidentiality of the information, and to destroy the information if the commercial transaction is not completed or if its use is no longer necessary.

Consent and your Choices

We believe that you should have choices with respect to your Personal Information. We provide you with information and the ability to express your preferences, including what and how much you share with us, and when and how you hear from us.

To change how we communicate with you, you can use the unsubscribe link at the bottom of our communications. If you no longer want to receive marketing-related emails, contests, or surveys, you may opt out by using the unsubscribe link in any such email you receive from us.

For information on your choices related to cookies and other data, including opting out of online digital advertising, please see our Online Digital & Cookie Notice at www.aviso.ca/en/privacy.

To opt out of direct mail and telephone marketing communications, contact us at the toll-free numbers listed in “Withdrawing Your Consent”.

Note that even if you choose to opt out of marketing-related emails or communications, we are required to continue to send you operational, transactional, and regulatory messages, such as account statements, trade confirmations and account security updates.

Withdrawing your Consent

You are always in control of your Personal Information and providing us with your information is your choice.  If you object to the processing of your Personal Information, you can choose to withdraw any consent you previously provided to us, and we will respect that choice in accordance with our legal and contractual obligations and requirements.  You may withdraw your consent to the further collection, use and disclosure of Personal Information at any time by giving us notice, subject to limited exceptions. You are not entitled to withdraw your consent to our collection, use and disclosure of Personal Information required to be disclosed to government authorities, law enforcement, regulators, including self-regulatory organizations or otherwise required by law.

If you wish to withdraw consent, you or your advisor (from your Referring Organization) may do so at any time by contacting the toll-free phone numbers listed below. To the extent permitted by law, we will need to verify your identity (or the identity of your advisor) and ensure the authenticity of your request.

Aviso:    1-855-714-3800
Qtrade Direct Investing:    1-877-787-2330
Qtrade Guided Portfolios:    1-844-622-4500
NEI:    1-888-809-3333

We will explain your options and any consequences of withdrawing your consent. If you do not consent to certain collection, uses or sharing of your Personal Information, we may be unable, or limited in our ability, to provide you with certain products and services or information that may be of value to you, due to legal, regulatory, or contractual obligations. For example, if you do not provide your SIN, we are unable to provide you with any product where the collection of a SIN is required by law, such as an RRSP or other registered product.

Safeguarding your Personal Information

We have an information protection program in place to protect your Personal Information against loss, theft, misuse and unauthorized access, disclosure, copying, use or modification. 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 privacy and data security training.

We have agreements and controls in place with our third-party service providers requiring that they safeguard any Personal Information we provide them or any Personal Information they collect on our behalf, and require that they use the Personal Information only for the purpose of providing the service we have engaged them to perform.

We make our employees and other representatives aware of the importance of maintaining the confidentiality and security of Personal Information.  Each of our employees and representatives is responsible for respecting and protecting the Personal Information to which they have access. Access is granted to Personal Information on a ‘need to know’ basis where their duties reasonably require such information. Unauthorized access, use and disclosure of Personal Information is strictly prohibited. All employees or representatives are required to maintain the confidentiality and security of client Personal Information and failing to do so will result in appropriate disciplinary measures.

You are responsible for helping to protect the confidentiality and security of your Personal Information. Always protect your credentials and never disclose passwords or sensitive information related to these services.

Accessing and Updating your Personal Information

You have the right to access the Personal Information we hold about you. Most of your information is already available to you:

  • on your paper or electronic account statements;
  • by viewing your account online;
  • by contacting a customer service representative; and
  • by contacting your advisor at your Referring Organization.

If you want access to any additional Personal Information we hold about you, you can make a request in writing. To avoid delays in obtaining your information, please provide us with sufficient detail to enable us to identify you and retrieve your Personal Information.

Requests can be submitted via several channels:

Attn: Chief Privacy Officer
700 – 1111 West Georgia Street
Vancouver, BC V6E 4T6

We will verify your identity and validate the authenticity of the request before responding. We will respond to your request within thirty (30) days. 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 or if an extension is required to process the request. If you are not satisfied, you may contact the applicable federal, provincial or territorial Privacy Commissioner.

Maintaining the Accuracy of your Personal Information

We encourage you to help us keep your information current. It is critical that the Personal Information we have about you is accurate and complete as we make decisions based on this information. We rely on you to inform us in a timely manner of any changes or corrections to your Personal Information. Failure to do so may negatively impact the way we communicate with you, provide services to you, and/or fulfill our legal and regulatory obligations. If a change or correction is required, please provide an update through our online client portal, by contacting your advisor, or by contacting us at 1-855-714-3800. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend it as required.  Where appropriate, we will transmit any material amendments to your Personal Information to affiliates or third-party service providers having access to your Personal Information. If we do not agree to make the amendments that you request, you may challenge our decision by contacting us as described in the Section below titled “Procedure for Handling Privacy Concerns”.

Retaining your Personal Information

We retain your Personal Information for as long as required to provide you with the products or services you have requested and to comply with all business, legal and regulatory record-keeping requirements and aligned with our internal policies and retention schedules. 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.

Subject to legal and regulatory requirements, where you have withdrawn your consent or we no longer have a business relationship with you, you have the right to request that we cease using or sharing your Personal Information or request that we de-index (de-link or anonymize) your Personal Information.  

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 personally identifiable information. Please see our Aviso Online Digital & Cookie Notice at  www.aviso.ca/en/privacy for more information on how to manage your cookies.

Our websites contain several links to websites of third-parties that we do not own or operate. We provide these links to third-party websites as a convenience to you. These links are not intended as an endorsement or, or referral to the linked websites. The linked websites should have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have control over these websites and are not responsible for the content of these websites or how these parties treat or protect Personal Information. Therefore, we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose, secure, and otherwise treat your Personal Information. Please review their privacy notices for more information on how they process your Personal Information. Be careful when you send information over the Internet. Any unprotected communication sent over the Internet is not confidential and is subject to possible interception, loss or alteration.

Procedure for Handling Privacy Concerns

If you believe 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 Service Centre representative at the toll-free phone numbers listed below.

Aviso:    1-855-714-3800
Qtrade Direct Investing:    1-877-787-2330
Qtrade Guided Portfolios:    1-844-622-4500
NEI:    1-888-809-3333

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: 1.855.714.3800
Email: privacyofficer@aviso.ca

Our Chief Privacy Officer will investigate your question or concern and endeavor to provide a response within thirty (30) days. If after contacting our Chief Privacy Officer your concern remains unresolved, you may file a complaint with the Office of the Privacy Commissioner of Canada:

30 Victoria St.
Gatineau QC
K1A 1H3
Toll-free: 1-800-282-1376
Phone: 819-994-5444
TTY: 819-994-6591
www.priv.gc.ca

Updating this Policy

We may update or modify our Privacy Policy from time to time to reflect changes in our Personal Information practices or as industry practices and regulations are revised. We will post the revised policy on our website at www.aviso.ca/en/privacy. Please regularly review our Privacy Policy to ensure you are up to date with any changes.

We may also notify you of changes to the policy in any of the following ways:

  • digitally, by mobile app or email;
  • a notice posted on an Aviso website; and/or
  • a notice delivered by mail.

Contact

  • 1.888.545.5959
    151 Yonge Street, Suite 1200
    Toronto, ON M5C 2W7

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