Confidentiality Policy

La Clinique Financière is committed to protect privacy and confidentiality of persona; information that it holds and control. The following Confidentiality Policy explains the measures we take to fulfill this commitment and describes how La Clinique Financière collects, use, communicate and process these information with its website, at cliniquefinanciere.com , including secondary and following pages (hereafter called the Website), and by other means with our clients and prospective clients.

This Confidentiality Policy can be updated periodically to reflect changes in our practice with personal information. We invite you to look into regularly this policy to find out the latest updates in the way we deal with personal information.

We only ask our clients necessary personal information.

La Clinique Financière must collect personal information from its clients and prospective clients to supply services and fulfill legal obligations. When understanding needs and wishes from our clients, as well as their financial and family situation, we make sure to present investment recommendations that are always appropriate. It is a requirement of regulations as much as sound commercial practices. La Clinique Financière is committed to protect the privacy of its clients and the confidentiality of personal information in its possesion. This Policy explains the actions we take to fulfill this commitment.

The Personal Information form that we ask you to fill only require the necessary data we need to fulfill contractual, legal or tax purposes, as well as full name, address, phone and fax numbers, e-mail address, date of birth, Social Insurance Number (SIN - for tax documents), assets you have and their value, your investment knowledge and objectives. We also collect data on chequing account as well as information about your beneficiaries (for example, the name and occupation of your spouse, the names and age of your children and dependants).

Our RRSP (Registered Retirement Savings Plan) form require data needed to register these programs with the government including Social Insurance Number, and the name and date of birth of your spouse or designated beneficiary. We do not communicate non public personal data to any third party, except in the cases governed by law or otherwise mentioned in the present policy. We also collect information in a risk tolerance questionnaire and other questions that law require us to collect. 

We limit the use of your personal information.

 Personal data collected when you open an account are used for the following purposes:

  • help us determine the portfolio that suit your needs and objectives;
  • verify your identity (and the other information you gave us);
  • open and manage your account;
  • send and receive payment of invoices with your chequing account;
  • find and prevent fraud and other illegal or unauthorized activities;
  • fulfill any and all legal or other obligation;
  • carry out what is otherwise required or authorized by applicable laws.

Personal information collected and used in other ways

Recommendation Program: Should you participate in our recommendation program or other "Invite a friend" application (available on our websites), we collect the e-mail addresses of each person you wish to recommend to La Clinique Financière. We will use these information to send a single e-mail giving information about the recommendation program. We do not use the e-mail addresses given for that purpose for other means without the consent of the recipient. Make sure you only submit the e-mail addresses of people of your family or who would like to receive such an e-mail from you.


 Other types of communication: From time to time, we could ask your consent before sending e-mails, text messages (SMS) or other communications about products and des services offered by La Clinique Financière or events that might interest you. You can unsubscribe from commercial or promotional e-mails by following the unsubscribe instructions appearing in all of our e-mail communications. Note however that you will continue receiving e-mails about your accounts or transactions with us. You can also unsubscribe from all commercial communications by sending an e-mail to support@lacliniquefinanciere.com.


 Customer Service: If you communicate with a Customer Service Agent to make a statement, lodge a complaint or ask a question via e-mail, text message, telephone or video conferencing, we could ask you information that will enable to identify you (like your name, address and a phone number). We could also ask more details to enable us to quickly answer your question, comment or complaint. We could keep these information to help you in the future and better our customer service as well as product or service offer.

Employment: If you inquire about employment with us or apply for a job, you will supply some personal information (such as those appearing on a resume, a presentation letter or other documents supplied for that purpose). We will use that information to process your job application for an existing or future position.

How we collect personalinformation

Unless otherwise indicated in the present confidentiality policy, we collect personal data directly from you. If you open an account with La Clinique Financière, you must open an account with a broker via its portal that offer services to execute operations and compensation in your name. We collect your personal data thru our agents, including operations statements, title and liquid asset statements in your account, so as to verify the return on your investements and deliver statements according to current Securities rules and regulations.

We limit access to clients’ personal data.

We register clients’ personal data électronically on servers to which only authorized personnel have access. These must use a secure password. We authorize our employees and service providers access to clients’ personal data only under circumstances where this information are necessary to fill their job and duties.

We put in place ways to protect personal data.

La Clinique Financière has put in place administrative, technical and physical measures to protect personal data entrusted against any unauthorized access or use, modification and communication. Our employees are trained to keep clients’ personal information strictly private and confidential. All our personnel sign a Confidentiality Clause to protect Privacy that obligates them to respect and protect clients’ personal data. We make sure our personnel that leave La Clinique Financière understand thar they remain by contract obligated to respect the confidentiality of this information.

Your online access to some of your personal information is protected by a password of your choice. We strongly recommend that you do not share it with anyone. We will never ask you for this password in an unsolicited communication (such as a letter, phone call, or email).

Our process for retaining the personal information of our clients and potential clients is designed so that such information is never retained longer than necessary for the purposes set out in this Privacy Policy or to comply with legal obligations.

We restrict communication of personal information.

We will not disclose, negotiate, rent, sell or otherwise transfer your personal information without your consent, except as otherwise provided in this privacy policy.

Service Providers: We may transfer your personal information to members of our group and other third party service providers who provide various services on our behalf, such as identity verification, administration, printing services, marketing and advertising, hosting, data analysis or accounting or technological or legal services.

Broker: When you open a brokerage account with our custodian, we provide your account information to the relevant brokerage to simplify the application process. We also notify them of updates and changes to your account information.

Business transactions: We may transfer any information we hold about you as an asset in connection with any sale or merger made or proposed (including transfers made in the context of bankruptcy or insolvency proceedings) which relates in whole or in part to La Clinique Financière or in the context of a corporate reorganization, without being limited thereto, or a sale of shares or another change in control of the company, including for the purpose of determining whether or not to proceed with a transaction or a business relationship or to continue it.

Securities Regulation: We and / or our custodian may share your name, contact details and interests with the issuers of the securities you hold in your account and with other natural or legal persons as required by law. on securities. Such issuers may request your personal information for the purpose of providing you with financial reports, tax documents and other relevant documents, or to comply with applicable regulatory obligations. We [and / or our custodian] may also communicate certain personal information, such as the number of units subscribed for and their purchase price, to the relevant Canadian Securities Authority, when required by law.

Legal Matters: We and our affiliates in Canada, the United States and elsewhere as well as third party service providers may provide your personal information pursuant to a search warrant or other investigation. or legitimate prescription. It could also be provided to another organization for the purpose of investigating a breach of an agreement or a law or in order to detect, counter or prevent a case of fraud. Finally, it could be provided as required or otherwise permitted by Canadian, US or other laws and regulations (which could include legitimate access requests by courts, law enforcement agencies). law or government authorities in Canada, the United States or elsewhere).

We expect our providers to have similarprotection measures.

Our service providers receive the information they need to perform the functions expected of them, and we do not authorize them to use or disclose personal information for marketing or other purposes of their own. Your personal information may be stored and processed by our group members and other third party service providers in the United States or other territories. If personal information is transferred to the United States or another foreign jurisdiction, it will be subject to the laws of that jurisdiction and may be disclosed to courts, law enforcement agencies, and government authorities, or may be accessed by these, in accordance with the laws of those territories.

We take seriously privacy protection.

La Clinique Financière's Director of Compliance, Lawrence Shaw, is responsible for ensuring that La Clinique Financière complies with its privacy policy. He is responsible for educating our employees about our privacy policies and for ensuring that we respect our privacy commitments. We invite any client or potential client to contact them at the addresses or numbers indicated below for any further clarification. If you wish to consult your personal information in our possession, you must make a written request to the Compliance Director of La Clinique Financière.

We will give you access to your personal information.

You have the right to access your personal information, which La Clinique Financière has custody and control, to update it and to correct any inaccuracies, except in certain circumstances provided for by law. You may update certain information that you have provided to us on your profile by logging into your account and clicking on "Settings". Otherwise, if you wish to access your other personal information for which La Clinique Financière has custody and control, update it and correct any inaccuracies, you must make a written request to the Director of Compliance, at the contact details indicated below. below. We may ask for certain personal information to verify the identity of the author of the request for access to the personal information file.

La Clinique Financière

2486 Viau Street, Montreal H1V 3H9

Or

to lodge a complaint
 plaintes@lacliniquefinanciere.com

We collect and use information about your visit to our website.

In general, you can visit our website without indicating who you are or submitting any personal information. However, we collect and / or store the IP addresses of all website visitors and other related data, such as pages viewed, browser type, operating system and the average length of your visit to the website. website. We use this information to understand website activity and to monitor and improve the website.

Cookies and Similar Technologies: The website uses a technology called “cookies”. A cookie is a small piece of information that the website can send to your browser, which can then be stored on your hard drive and which allows you to be recognized each time you return to the site. We use cookies on the pages of the website that you are called to log on to or that are customizable. If you have registered with the website, cookies can tell us who you are and identify your browser as a browser that has visited the website before; in addition, they may be required to access your account information (stored on our computers) in order to deliver personalized products and services to you. We also use cookies to provide, to us and our service providers, information about your use of the website, which we may use to personalize the website or other content in accordance with your interests and preferences (for example, language) and improve your user experience. You can set your browser to warn you when you receive a cookie or to decline certain cookies. However, if you decide not to accept cookies from the website, you may not be able to take advantage of all of the features. language) and improve your user experience. You can set your browser to warn you when you receive a cookie or to decline certain cookies. However, if you decide not to accept cookies from the website, you may not be able to take advantage of all of the features. language) and improve your user experience. You can set your browser to warn you when you receive a cookie or to decline certain cookies. However, if you decide not to accept cookies from the website, you may not be able to take advantage of all of the features.

Web beacons: The website may also use a technology called "web beacons". This technology allows us to understand which pages of the website you visit. Web beacons help us optimize the website and tailor it to you and other future visitors.

Website analysis services: We may use the services of third parties to help us collect and analyze data on the pages visited on the website in order to better understand, evaluate and improve the user experience and the usability of the website.

Social Media: We may provide you with the opportunity to view our content on or through third party social networking websites, such sites, plugins and applications. By viewing it in this way, you may allow us to access certain information associated with your social media account (for example, your name, username, email address, profile picture, gender ) to provide content to you or to operate the website, plug-in or application. If you provide information to us through your social media account, we may use that information to personalize your experience when you visit the website and third party social networking websites or use the plugins and applications,

We use online advertisement.

We may use the services of third parties, such as ad data and ad exchange companies, to administer our ads on our website or other websites. These companies may use cookies or web beacons to obtain certain information about your visits to our website and other websites (such as the web pages you visit and your responses to advertisements) in order to measure the effectiveness of our marketing campaigns and to send you advertisements that are more relevant and relevant to your situation, whether on our website or outside our website.

To learn more about these behavioral advertising practices or to opt out of such advertising, you can visit the Digital Advertising Alliance website at www.aboutads.info/choices/ or the Advertising Association website. Digital Canada, at www.youradchoices.ca/choices.

We can supply links to third party websites.

Our website may contain links to other websites which are not owned or operated by us. In addition, third party websites on which we display advertising may include links to our website. Except as otherwise provided herein, we will not share your personal information with such third parties without your consent. We provide links to third party websites to assist users. These links should not be taken as an endorsement or recommendation of the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use, which we recommend that you read carefully. We have no control over these websites and, therefore.