Privacy Policy

Wealthbar Financial Services Inc., doing business as "CI Direct Investing", "WealthBar", "Assante Connect" or "PPI Valet"

Privacy Notice

Your Privacy

We are dedicated to respecting and protecting the privacy andconfidentiality of the information you have entrusted to us. This Privacy Notice outlines our privacy principles and practices.

Scope

What is personal information?
Personal information refers to information that identifies you. The word "information" means personal, financial and other details about you thatyou, or someone you authorize, provide to us or we obtain from otherswithin or outside the Company.

What does it apply to?
This Privacy Notice applies to the operations of Wealthbar Financial Services Inc., doing business as CI Direct Investing, WealthBar, Assante Connect or PPI Valet in Canada. It applies regardless of how you choose to do business with us – over the phone, in person, through the internet, through your mobile device or through email.

Who does it apply to?
The Notice applies to all individuals whose personal information we collect, including clients who are individuals, individuals carrying on business alone or in partnership with other individuals, signing officers of our business clients, and beneficiaries of clients to the extent that we collect, use or disclose their personal information.

Changes to the notice
We may amend this Notice from time to time and will post the revised Privacy Notice on our website.

Your consent
Each time you use our online, mobile, and electronic services, you are indicating your acknowledgment and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services.

Our Privacy Principles

The Privacy Notice outlines our privacy principles and informs you of the practices we have in place to manage personal information. We aim to respect and protect your privacy by following the key privacy principles below.

Other important information

Contact us

1. Taking accountability

We have designated a privacy officer who is accountable for personal information under our control and responsible for compliance with this Privacy Notice. Please see here for information on how to reach the privacy officer.

We have strict policies and procedures governing how we deal with your personal information. Every employee is responsible for respecting and protecting the personal information to which the employee has access.

2. Identifying purpose for collection, use, or disclosure

Purposes

We collect, use and disclose personal information responsibly and only for the purposes for which it was collected. When we collect personal information, we may use it to:

Your personal information may also be used for purposes named in your respective application forms and account agreements.

If a new purpose for using your personal information develops, we will inform you of that purpose.

3. Obtaining consent and providing choices

Obtaining Consent

Depending on the type and sensitivity of the personal information and the way you choose to interact with us (in person, internet, phone, email, etc.), we may obtain your consent in different ways.

Before we make information available to third parties, other than an agent or service provider who needs it, we will tell you at the time of consent or before we make the information available, who those third parties are, the kind of information we want to share with them, and why.

We are committed to being transparent and providing you with choices about how your information is used.

Revoking Consent

You may withdraw your consent for the collection, use and disclosure of your personal information at any time by forwarding a written request to the Privacy Officer. Please include your full name, address, telephone number and account number(s) on any correspondence to us.

However there are certain times when you may not withhold or revoke your consent including certain legal, regulatory, or contractual requirements.

We must receive reasonable notice of your request in order to honour your consent withdrawal.
Your decision to withhold or revoke your consent may limit the products and services that we may provide to you and may require you to close your accounts with us.

4. Limiting collection

We only collect the personal information we determine we need for our identified purposes.

For instance, we may collect:

5. Limiting use and disclosure

Use

We only use or disclose your information for the purpose(s) it was collected and as otherwise identified in this Notice.

Disclosure

Access to personal information is restricted to those staff members who need the information to carry out their job duties. Those employees maintain the information in the strictest of confidence and do not provide access to the information to anyone who is not authorized.

We may provide your information to third parties, including:

6. Retaining information

Where your information is kept

Your personal information is kept:

We may store your personal information via third party entities that reside in foreign jurisdictions. Information may be transferred to, accessed and/or retained by these third parties. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. 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 law in the jurisdiction(s) in which we operate.

Retention

We have policies in place that govern the retention of your personal information so we keep it only for as long as reasonably necessary to fulfill its intended purpose or to satisfy legal requirements. The length of time we keep your information will depend upon the product or service and the nature of the information.

Deletion

When we no longer retain your personal information, we have procedures to destroy, delete, erase or convert it to an anonymous form, in a manner that keeps it safe in the process.

7. Keeping information accurate

We are committed to maintaining the accuracy of your personal information and take reasonable efforts to keep your information complete and up-to-date. We maintain your personal information in as accurate, complete, and up-to-date form as is needed for its use.

If you discover inaccuracies in our records, or your personal information changes, please notify your financial advisor or contact our Client Services Department directly at [email protected] so that we can make the necessary changes. Failure to notify us of changes to your personal information may negatively impact the way we communicate or provide services to you. Where appropriate, we will advise others of any material amendments to your personal information that we may have released to them.

8. Protecting information

We maintain appropriate physical, electronic, technological, procedural, and organizational safeguards to protect against unauthorized access, disclosure, copying, use or modification, theft, misuse, or loss of your personal information in our custody or control. These safeguards are appropriate to the sensitivity of the information.

We have agreements in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the provider to perform. More details are available on the Security page.

9. Maintaining openness

We make readily available to our clients, employees and agents information about our policies and procedures relating to our management of personal information.

From time to time, we may make changes to this Privacy Notice and our Online and Mobile Privacy Policy. Our Online and Mobile Privacy below is always the most recent version.

Please see Contact Us to answer any question you may have about our Privacy Notice.

10. Accessing or correction information

Individuals do not always need to use their right under the law to access or correct their personal information with us. Clients are encouraged to contact our Client Services department at [email protected] to correct or access their information. However, you do have the right, subject to certain limitations, to formally request to review or verify your personal information, or to find out to whom we have disclosed it. To make a formal request for access, send a written request addressed to the Privacy Officer in Contact Us below. Please include your full name, address, telephone number, and account number(s) on all 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 without limitation, where such information:

If we are unable to provide some of the personal information, we hold about you, we will tell you why where permitted by law.

We will advise you in advance if a minimal charge will be required for conducting the search and we will respond to your request within 30 days.

Online and Mobile Privacy Policy

Scope

This Online and Mobile Privacy Policy supplements the Privacy Notice and specifically addresses the way in which we collect, use, disclose, and manage personal information in connection with our online, mobile and other digital channels and services. It should be read in conjunction with the Legal Notice and Terms of Use.

Your consent

Each time you use our online, mobile, and electronic services, you are indicating your acknowledgment and consent to the collection, use and disclosure of your personal information as identified in this policy, which we may revise periodically without notice. We will let you know of any changes by posting the revised policy with a new effective date. If you do not accept the terms outlined in this policy, please do not use our online, mobile and electronic services.

What personal information do we collect?

We may collect personal information when you use our websites, online, mobile, and other electronic services (collectively, digital channels), including:

For what purposes do we use and disclose your personal information?

We may use or disclose this information collected online to:

Use of web tools

We and our service providers may use various tracking tools, such as Cookies, Pixel Tags and Web Beacons. Through the use of cookies and other technologies, we can enhance your experience with improved design, personalized content that may be relevant to you, and effective navigation. 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 CI Direct Investing’s websites.

Your choices

Safeguards

Our security measures

We take our responsibility to safeguard customer information very seriously. To protect certain communications between your computer and our servers, we use a technology solution called “Secure Sockets Layer” (SSL). SSL ensures that the information transmitted is encrypted. In addition, we use the concept of “defense in depth”, in our cybersecurity program that has many layers, from employee awareness to having firewalls at the very edge of our network.

Your security measures

You are responsible for ensuring the security of your unique web login ID and password. You must avoid selecting an obvious password, such as a street address, date of birth, or telephone number and to change your password on a regular basis, in order to reduce the potential for unauthorized use. Any web login ID, password, or any other piece of information chosen by you or provided to you as part of Wealthbar Financial Services Inc.’s security procedures, must be treated as confidential and personal to you, and you must not disclose it to any other person or entity.
Do not respond to text messages, pop-ups, emails, or other internet requests that ask you to reveal personal information about yourself or your account when using the Services. Wealthbar Financial Services Inc. will never send you unsolicited messages or emails asking for your password, credit card, account numbers, etc. Wealthbar Financial Services Inc. will never ask you to validate or restore your account or access to the Services through unsolicited messages or emails.

Third-party links

For your convenience, the Services may provide links or pointers to third-party sites. You are subject to any terms and conditions of such third-party sites. Non- Wealthbar Financial Services Inc. websites are not subject to Wealthbar Financial Services Inc.’s privacy policy or security standards.

Contact us

If you have any questions or concerns about our privacy practices, the privacy of your personal information, or you want to change your privacy preferences, please let us know. We are committed to helping resolve your questions or concerns.

Step 1: Voice your question or concern

The best way to address the concern or question for existing clients, is to login and submit your request through our messaging platform, or by email to [email protected]. If you are not satisfied with the answer or resolution provided in Step 1, please proceed to Step 2.

Step 2: Escalate your concern to the Privacy Office

You can escalate your concern in the following ways:

CI Financial GroupPrivacy Officer Contact
WealthBar Financial Services Inc.Privacy Office
2 Queen Street East
19th Floor
Toronto, Ontario
M5C 3G7

Phone: 1-800-792-9355

Step 3: Further Escalation

If after contacting us you do not feel that your concern has been adequately addressed, you may wish to contact:

The Office of the Privacy Commissioner of Canada
Call: 1-800-282-1376
Visit: www.priv.gc.ca