Policy on the Management and Protection of Personal Information
Jean-François Bouchard, Apex Financial Services and its employees act as an intermediary between life and health insurers and mutual fund companies.
In carrying out our responsibilities, we must collect personal and confidential customer information that is necessary for the performance of our duties.
We are committed to protecting the personal information collected from customers. This policy explains the practices for the collection, use and disclosure of personal information with respect to customers, as well as the measures we take to ensure that it is handled appropriately.
The policies and practices we have put in place have been developed based on their compliance with the principles set out in the laws applicable in Quebec to ensure the protection of personal information and its confidentiality. In particular, the Act respecting the protection of personal information in the private sector (RSQ Chapter P-39.1) applies, as well as the related regulations, and we are committed to respecting these principles.
The term “personal information” means:
Personal information is any information that relates to a natural person and allows that person to be identified.
Therefore, this definition refers to any information that would allow you to be identified, such as: your name, address, telephone number, e-mail address, fax number or any other information that can be used to communicate with you, as well as financial information about you or your spouse, information related to your occupation and that of your spouse, as well as information about your credit, financial instructions or medical condition.
This concept does not apply to information relating to companies and other corporations.
A. INFORMATION COLLECTED
We collect personal information in accordance with applicable laws and in an ethical manner. We collect only information that is necessary and useful, directly or indirectly, to perform our functions to enable us to perform our duties and responsibilities.
B. 10 PRIVACY PRINCIPLES
PRINCIPLE 1: OUR RESPONSIBILITY TO THE CUSTOMER
We are responsible for all personal information under our control, including any information that is transferred to a third party for processing, storage or other purposes. As a result, we are required to protect the confidentiality of the personal information to which we have access. Our policies and procedures for the protection of this information are strict and we have designated an individual who is responsible for ensuring compliance with these policies and procedures. As a condition of employment, all our employees have adhered to ethical principles, one of the fundamental principles of which is to always maintain the confidentiality, security and privacy of the information in each client’s files. We also ensure that our staff receive adequate and relevant training on an ongoing basis and that they are regularly informed of the latest developments. changes to our company’s procedures regarding the management and protection of your personal information.
PRINCIPLE 2: IDENTIFYING PURPOSES
When you deal with one of our advisors (life and health insurance or group insurance and annuities) or one of our dealer representatives (mutual funds), they ask you for personal information for various purposes:
• To verify your identity and prevent fraud.
• To ensure that we understand your financial services needs.
• To check if a product or service is suitable for you.
• To determine your eligibility for products or services for the purpose of providing them to you.
• To register for and administer any product or service you have requested.
• And finally, to meet the requirements of legislation or regulations.
PRINCIPLE 3: YOUR CONSENT
When you open a mutual fund account or sign an application for life and health insurance or group insurance and annuities, by signing the appropriate documents, you certify that you consent to the collection, use and disclosure of personal information.
You have the right, if you choose to do so, to opt-out of the collection, use and disclosure of your personal information. You may also withdraw your consent at any time thereafter, subject to legal or contractual restrictions and reasonable notice. In many cases, the collection, use and disclosure of personal information is necessary for the proper management or administration of your records or for the proper administration of your records. the provision of ongoing services related to your case. In these circumstances, you should be aware that we may be forced to close your file or stop offering you a product or service.
You may withdraw your consent at any time if:
• You provide reasonable written notice to that effect.
• We are not legally obligated to obtain, use or disclose personal information.
• This does not prevent us from performing our contract to which we have committed ourselves to you.
PRINCIPLE 4: LIMITING THE COLLECTION OF YOUR PERSONAL INFORMATION
We collect only the information that is necessary and necessary to process your file. We may ask you for the following information:
• Social Insurance Number (SIN) – For income tax and other government purposes, including opening an income-generating account and for a registered investment of retirement income, in order to meet the requirements of the Canada Revenue Agency. We may use your SIN for administrative purposes, such as to match your personal information, or as an internal identification number to distinguish you from other customers who have a name similar to yours.
• Financial Information – To ensure that the advice we offer you and the investments you buy are right for you so that you know yourself well.
• Health Information – To determine your eligibility for certain insurance products.
• In some cases, you may choose not to provide us with certain information. However, in such a case, we may not be able to provide you with the product, service or information you request in the following cases where we are required by applicable regulations to obtain this information.
PRINCIPLE 5: LIMITING USE, DISCLOSURE AND RETENTION
Your personal information shall not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required by law. We shall retain personal information only as long as necessary for the fulfillment of the identified purposes. The destruction of this information is done in a secure manner in order to comply with the their protection in order to ensure their confidentiality.
Under no circumstances and under no circumstances do we sell or give lists of our customers to other companies for their own use.
To properly carry out the mandate entrusted to us, we may pass on the personal information obtained about you to third parties, in the following cases:
• We have obtained your consent to do so.
• We share your personal information with any other organization with which we have a business relationship in order to comply with and fulfill your requests.
• A securities regulator or other regulatory body has required it.
• We are required or permitted to do so by law.
We only maintain records containing your personal information if it is required for our business relationships, in accordance with our internal document retention policies or legal and regulatory standards.
Strict procedures are in place for the retention of your personal information and we will dispose of personal information that is no longer required for the identified purposes.
We may disclose personal information to legal or regulatory authorities in the event that we suspect money laundering, insider trading, manipulative or deceptive marketing practices or other criminal activities, to detect and prevent fraud, or to meet the requirements of laws or regulations of government authorities, regulators or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (e.g., court order). When we need to disclose personal information for these reasons, we open a file that identifies what information was shared, when, to whom and why.
PRINCIPLE 6: ACCURACY OF YOUR INFORMATION
We are committed to maintaining the accuracy of personal information and ensuring that it is complete and up to date. We try to take all reasonable steps to maintain their accuracy. If you become aware of any errors in our data or if your information changes, you must notify us immediately so that we can make the necessary changes. We will make the necessary changes to your file if you determine that the personal information in your file is incomplete, inaccurate or ambiguous.
We will do our best to notify those to whom we have provided information of these changes as soon as possible.
If we do not agree to make the changes you request, you can challenge our decision. Please refer to Principle 10 below for information on how to file a complaint.
To access your personal information, to correct personal information, to make an inquiry, or to make a complaint, please contact us in writing at the address set out in Principle 10.
PRINCIPLE 7: OUR PRIORITY: THE SECURITY OF YOUR PERSONAL INFORMATION
We have very strict security measures in place to protect your personal information from unauthorized access, regardless of the format in which we hold it. We strive to adapt our security measures to technological advances.
Methods of protection include:
• Physical security measures, such as access-controlled desks and locked filing cabinets.
• Electronic and technical security measures for computerized personal information, such as the use of passwords, database encryption, and personal identification numbers.
• Organizational processes such as restricting access to your personal information to a selected group of individuals.
• Contractual obligations with third parties who need access to your personal information, obligating them to protect the confidentiality and security of your personal information.
We have established a comprehensive range of security controls to protect personal information from unauthorized use, access, modification, copying, destruction and disclosure, loss or theft.
On our websites, cookies or other information tracking mechanisms may be used to improve the functionality or security of the sites or to provide the user with a more personalized viewing of the site. Please note that cookies cannot access your computer’s files or data under any circumstances.
PRINCIPLE 8: TRANSPARENCY
We need to make available to you information about our policies and practices for managing your personal information.
From time to time, we may make changes to our privacy policies or to the measures we have in place to ensure the security of such information. If we do, we will notify you as required by law.
PRINCIPLE 9: YOU HAVE ACCESS TO YOUR PERSONAL INFORMATION
You may have access to your file if you request it in writing to the Privacy Officer. This right of access and modification includes, but is not limited to:
• The right to consult your file free of charge.
• The right to obtain a copy of your file for a reasonable fee.
• The right to have incomplete, inaccurate or ambiguous information corrected.
If you would like to access or verify personal information or to whom we have disclosed it, you may request it. We may ask you for specific information to enable us to search for and provide that information to you. Depending on the nature of your request, you may also have to pay a small reproduction or search fee, but we will notify you first. In some cases, we may not be able to provide you with certain information we hold about you in accordance with applicable law. If we do, we will inform you of the reasons why we are unable to provide you with access to that information.
PRINCIPLE 10: INQUIRIES AND COMPLAINTS
You may contact us to inquire about or make a complaint about our privacy policies and practices.
We are committed to responding promptly and accurately to all your questions and concerns regarding the privacy and security of your personal information and our privacy policies and procedures.
If you complain about the exercise of your rights set out in this document, your file will be handled by the Office of the Privacy Officer, which will inform you of the procedure to follow. Each complaint will be investigated. If the latter is justified, the situation will be corrected and we will inform you. If the issue raised by your complaint requires a change to our policies and procedures, we will act accordingly.
If you have any requests or complaints, please contact us using these contact details:
Jean-François Bouchard
Chief Privacy Officer
1 rue des Écus, Blainville (Québec) J7C 5V7 jfbouchard@sfapex.qc.ca
