Privacy Policy

Terms of Use

You acknowledge that this website is protected by applicable trademark, copyright, patent and other intellectual property laws. Accordingly, you may not copy, reproduce, distribute or alter any materials found on this website without Compass Private Wealth Inc.’s written permission, except for personal, non-commercial use only.

This website utilizes a variety of technologies (such as cookies and web beacons) to collect, store, and aggregate data about usage and browsing patterns. These technologies help Compass Private Wealth Inc. analyze and tailor the site for all users and better understand how this website is used. Except as noted herein, Compass Private Wealth Inc. does not collect any personally identifiable information about you unless you choose to give us such information during an online session.

If you do give us personal information during your session, we will collect, use and disclose that information to service your request and as otherwise described in our Privacy Policy below. By using this website, you agree to the collection, use and disclosure of your personal information in accordance with our Privacy Policy.

Your use of this website is governed by the laws of the Province of Ontario and the applicable federal laws of Canada. Compass Private Wealth Inc. is also registered as a Portfolio Manager in British Columbia and Québec, and nothing in this clause limits any rights you may have under the applicable laws of those provinces if you reside there.

Privacy Policy

Your privacy is a priority, and we are committed to protecting your personal information.

In the course of providing you with our services, we are required to collect, use and maintain certain personal information about you. This policy answers some questions about what personal information we collect, the purposes for which we collect it, what we do with it, how you can access it and how we protect it. This policy applies to your account(s) with Compass Private Wealth Inc. (“Compass”, “we”, “our” or “us”), and your usage of the Compass Private Wealth Inc. website, and is in addition to the client or other agreements governing your account(s) and/or investment(s). By opening an account with us, or using the Compass website, you are indicating your consent to the collection, use and disclosure of your personal information in the manner described below.

TYPES OF PERSONAL INFORMATION WE COLLECT

When opening an account with Compass, we collect the following types of information:

• information you provide on your account application or other forms, such as your name, mailing address, telephone number, email address, social insurance number (SIN), citizenship, date of birth, employment information, spousal information, financial and net worth information, and banking information, and information regarding your investment knowledge, objectives and strategies;
• information about your assets, investments, and transactions with us; and
• information we may receive about you from consumer-reporting agencies, including credit bureaus used by us where we may engage ID verification services.

Our website will also use “cookies”, a technology that permits the website to recognize future visits using the same computer. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of our website.

PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL INFORMATION

We collect and use the personal information we obtain from you during the account opening and account administration process for the following purposes:

• to open, maintain and administer your account(s) and investment(s) held through your accounts in compliance with applicable law;
• to verify your identity and protect against fraud;
• to provide you with and manage the services you have requested;
• to contact and correspond with you in connection with our services;
• to determine your eligibility for certain of our services or special offers or promotional activities, and to contact you and correspond with you regarding those services, activities or offerings;
• to improve our services to you; and
• to comply with, and monitor compliance with, applicable law.

For example, we collect your social insurance number (SIN) in order to meet certain investment income and tax reporting requirements under the Income Tax Act (Canada), to keep your information separate from that of other customers with whom you may share a similar name, and to comply with applicable legal and regulatory requirements. We collect your birth date to help us verify your identity and guard against impersonation. We collect only the personal information we need or are required or permitted by law to collect, and use it only for the purposes for which it was collected. We may also collect your information from other persons, only with your express consent, or as authorized by law.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Compass does not sell your personal information to third parties. Compass does not disclose your personal information to third parties other than in the following circumstances or for the following purposes:

• in connection with normal business operations to open, maintain, administer, or service your account(s) or investment(s), including, without limitation, for the purposes of facilitating the account opening process (including the electronic mailing of account opening materials and the scanning of account documentation, cheques, and related materials into client databases);
• the provision of client service (including services rendered by third party agents or affiliates), the provision of back office administrative services (including the mailing of transaction confirmations and account statements, as applicable, and record-keeping services), for audit or statistical purposes, or for the collection of any amounts owed by you in respect of your account(s) or investment(s);
• to entities within the Compass group of affiliated companies, in order to offer and provide you a wider range of services and better services, to ensure that any updated contact information you provide is processed efficiently, and to engage in surveillance, compliance, and reporting activities required by applicable law;
• to other suppliers or agents of ours who assist us in providing services to you;
• to legal counsel for the purpose of obtaining legal advice; where we are required or permitted to do so by law, including any law enforcement agency, or securities regulatory authority;
• in connection with a transfer of a business in which we are involved; and in connection with offers made to our clients or prospective clients, or other promotional activities or service offerings engaged in by us where (A) third party product or service providers assist us or otherwise participate in fulfillment of the offer or provision of the service; (B) we have contracted with a third party for the fulfillment of the offer or provision of the service or otherwise have an ongoing business relationship with such third party; (C) fulfillment of the offer or provision of the service requires disclosure of certain limited personal information for fulfillment purposes only (such as, for example, name, address or email address) to such third party; (D) the disclosed personal information is to be used for fulfillment purposes only and the third party agrees not to disclose the personal information to others; or (E) in an aggregated form (i.e. not individual) for the purpose of analyzing statistics and metrics about our business and operations.

CONSENT

By opening an account with us, or using the Compass website, you are indicating your consent to the collection, use and disclosure of your personal information in the manner described above.

Subject to these qualifications, you may revoke or withdraw your consent to our collection, use or disclosure of your personal information, or withdraw your consent to our further collection, use or disclosure of your personal information at any time on reasonable notice, by contacting us in the manner described below.

If you wish to revoke or withdraw your consent, we may be unable to provide you with some services, offers or information that may be of value or interest to you. We will be happy to explain any consequences of revoking or withdrawing your consent, and the options available to you.

CONSENT TO ELECTRONIC COMMUNICATIONS (CASL)

If you submit your contact information through this website, including through our contact form or assessment request form, you consent to receive electronic communications from Compass related to your inquiry. Where you have provided express consent to do so, we may also send you commercial electronic messages, such as newsletters, market updates, or promotional material, in accordance with Canada’s Anti-Spam Legislation (CASL).

You may withdraw your consent to receive commercial electronic messages at any time, at no cost, by using the unsubscribe mechanism included in each message or by contacting us using the information provided below. Withdrawing consent will not affect communications required to service an existing account or respond to a specific request you have made.

ACCESS TO INFORMATION

Compass makes every reasonable effort to ensure that your personal information is accurate and up-to-date. You can also access and update your personal information that we collect about you at any time by contacting us in the manner described below.

In your communication, please include your account number(s), the information previously provided by you, and the new information that you would like to have updated.

PROTECTION OF PERSONAL INFORMATION

Compass protects your personal information by storing it in locations that are designed to prevent the loss, misuse, unauthorized access, disclosure, alteration or destruction of that information. Compass protects your account information by placing it on the secure portion of our website, using firewalls and other security technology to protect our network and systems from external breaches. Our employees (for example, customer service personnel) have access to your personal information only on a need-to-know basis.

QUESTIONS, INQUIRIES OR COMPLAINTS

Our Ultimate Designated Person, Josh Nichols, is accountable for this policy. Any questions, inquiries or complaints regarding this policy should be directed to him at 519-836-9910 or by writing to us at:

Compass Private Wealth Inc.

1-34 Bett Court, Guelph, ON  N1C 0A5