Privacy Policy
Purpose of This Policy
The personal information you provide to us is a crucial element of our business relationship with you. To uphold this commitment, we have established this Privacy Policy (“Policy”), which outlines our principles for preserving your information and privacy.
This policy pertains to the utilization and disclosure of any data gathered about you and how Bloomridge (“the Firm”) acquires such information during its operations. This policy remains in effect for the duration of our possession of your information, even after our business relationship concludes.
This policy applies whether you engage with us as an individual, corporation, trust, partnership, or other legal entity.
Our Chief Privacy Officer is responsible for overseeing these practices at Bloomridge. If you have any inquiries regarding this policy, please contact us at this address.
Chief Privacy Officer, Bloomridge
Corporation Bloomridge Inc. / Bloomridge Corporation Inc.
1500-1155 Metcalfe, Montreal QC H3B 2V6
Or contact your representative for any additional questions you may have.
Information We May Collect
Identity and Verification
First and last name, date of birth, contact information, civil status, email address, information from an acceptable identification document (driver’s licence, passport, Social Insurance Number or any government issued document — while providing your Social Insurance Number or Social Security Number is not mandatory, it can assist in verifying your identity with credit-reporting agencies and becomes necessary for tax-related matters when an account generates income), occupation, account numbers in different institutions you wish to share with us to conduct our activities, user ID, signatures, voice, and information relating to your role as an authorized representative, director, officer, or shareholder.
Financial Information
Income, salary and balances, products and investments and their terms and conditions (e.g., term, repayment frequency, limits, rates, expiration, etc.), credit reports and credit rating, and professional and financial background.
Account and Investment Profile
History of transactions and interactions in your accounts, investment instructions, knowledge and goals for investments and financial planning, and risk tolerance and investment objectives.
Health and Lifestyle Data
Where required to subscribe to insurance products or services through third-party insurers, and with your explicit consent: family medical history, activities, behavior and choices, and information related to travel, sports, and potentially hazardous recreational pursuits.
Interaction and Digital Records
Archiving, recording, and transcribing of telephone calls, video conferences, and chat sessions, records of office visits and meetings, security camera footage, data related to your devices (IP address, VPN, proxies, device type, and operating system), and approximate location derived from your IP address when accessing our websites.
Other Information
Your reason for doing business with us, language and communication preferences, and details regarding related individuals such as proxy holders, secondary account holders, beneficiaries, your spouse or common-law partner, dependents, and authorized users.
When you provide details about another person, we assume you have obtained their consent.
How We Collect Your Information
Directly from you — when you communicate with us, open an account, or update your preferences — and indirectly, where necessary and permitted by law, from: other financial institutions or lenders, your custodian, credit reporting agencies, regulatory bodies and self-regulatory organizations, and publicly available sources or records.
Use and Disclosure of Your Information
How We Use and Share Your Information
We use and share your information to: confirm your identity, update your details, and ensure the accuracy of the information you supply; regularly evaluate your financial situation to ensure our advice and services remain aligned with your needs; determine your eligibility for products and services or ensure that the guidance, products, and services we offer align with your needs; establish your investor profile, financial requirements, objectives, and investment strategies; establish, manage, administer, and deliver the requested products and services; combine the financial information held across your accounts to create a comprehensive overview of the products you currently possess, enhancing the quality of our service; conduct research and data analytics to generate statistics, enhance our products and services, and innovate new offerings through the analysis of information collected via our websites and mobile apps; personalize your experience, incorporating analytics of your profile, transactions, and other data to gain a deeper understanding of your preferences and requirements, and to offer improved advice; promote products and services that might interest you; conduct our business operations efficiently; assess your eligibility for incentives such as fee waivers and discounts; prevent, detect, and manage fraud, along with unauthorized or illegal activities, including money laundering and cyber threats; enable the due diligence of our operations in preparation for potential business transactions; manage various risks, including credit and business risks, and adhere to relevant laws and regulations; communicate with you through the contact information you have provided, which may include mail, email, text messages, phone calls, and social media; and employ specific information use and disclosure authorized by law.
To Whom We May Disclose Your Information
Certain situations may necessitate the sharing of your information with third parties for valid reasons. This could be mandated by legal requirements, essential to safeguard your interests in cases of fraud, or to enable your participation in a partner program or the provision of services on our behalf. In all instances, our commitment is to restrict the information shared to what is essential and to seek your consent when necessary.
We never sell client information to third parties.
We might disclose your information to: our primary custodians and their affiliated entities, as well as other financial institutions where your funds are held, for the purpose of verifying your identity, compliance requirements, and facilitating the ongoing management of your accounts; a representative or entity acting on your behalf, such as a securities broker or transfer agent; credit reporting agencies, where necessary and with your prior consent, in connection with credit-related services; an insurer or agent acting on behalf of our organization; individuals who share a joint account with you or have a role in your business association with us; third parties, in the event of legal proceedings where the disclosure of your personal information is required; a regulatory body, government authority, or self-regulatory organization as mandated by law; and technology and professional service providers performing functions on our behalf, including those described under Use of Technology Tools and Communication Records below.
Service Providers
We are deliberate in selecting service providers, who fall under the following classifications: technology services (including applications, data storage, backup, hosting, and support services), professional services, financial and banking services, insurance services, communications services, mail services, and analytical and marketing services.
Service providers are selected with care and are required to handle your information responsibly and in a manner consistent with applicable privacy laws.
Use of Technology Tools and Communication Records
To deliver a high-quality and responsive service, Bloomridge uses technology tools that may process information shared during client interactions. This includes tools that generate automated summaries of voice and written communications. These summaries are retained in our client relationship management system to document the substance of our interactions with you and to support continuity of service.
These tools may process data on servers located outside of Canada, including in the United States. Please refer to Cross-Border Data Transfer below for further details. Summaries generated through these tools are not used for any purpose unrelated to the management of your client relationship. If you prefer that automated summarization tools not be used during your interactions with us, please notify your advisor or our Chief Privacy Officer and we will accommodate your request.
Consent
We use your information with your consent or as permitted by law. Your consent for the collection, usage, and disclosure of your personal information is acquired in the following circumstances: when you request a new product or service, when we require the use of your information for a purpose different from those for which you’ve already granted consent, and when you engage in specific interactions with us, such as contacting customer service or completing online forms.
Furthermore, there are situations, as specified by law, where we do not need to seek your consent. These include cases where we must: adhere to a court order or another enforceable request, investigate a breach of contract or a violation of the law, and prevent, halt, or identify instances of fraud.
By opening an account with the Firm, and unless you advise us otherwise in writing, you are providing consent to collect, use, and disclose your information as described in this policy.
Your Rights
Right to Accept or Refuse to Provide Your Information
Your information is yours. Subject to legal, business, or contractual obligations, you may withdraw your consent at any time regarding how we collect, use, or disclose it. We will act on your request promptly.
Nonetheless, certain information is necessary for us to provide specific products and services. If you decline to provide it, we may be unable to serve you fully. For instance, if you choose not to disclose your Social Insurance Number (SIN), we will be unable to provide products that necessitate it, such as registered products like an RRSP.
Right to Refuse the Use of Your Information for Specific Purposes
You can refuse to let us use your information or withdraw your consent for the following purposes:
Send you promotional offers
Bloomridge may, on occasion, send you promotions that could pique your interest. You have the option to withdraw your consent for receiving these promotions at any time. Please be aware that there might be a delay before you cease receiving our promotional offers, even those associated with ongoing promotional campaigns.
Share your financial data between institutions
With your authorization, we may share your financial data between Bloomridge and other financial institutions where your assets are held in custody, provided that we are serving as the advisor or portfolio manager for your account(s).
Digital data collection
With your authorization, we may gather your digital data (such as device information and browsing patterns) through optional cookies or similar technologies when you access our online services. If you prefer not to have this data collected, you can click on “Cookie preferences” located at the bottom of our websites.
How to retract your consent
You can withdraw your consent to receive our promotional offers and your consent to share your financial information with Bloomridge at any time. Please reach out to us or contact your representative, and we will promptly process your request. Additionally, you can opt out of using cookies on our websites at any time.
What you will still receive after withdrawing:
You will continue to receive: mandatory notices that we are legally obligated to provide, and service-related messages included on account statements from your custodian and information concerning your existing products and services.
Right to Access Your Information
You have the right to inquire about the information we possess regarding you, except when legal restrictions apply.
To access your information, you can initiate a request through various channels, including online, by phone, via email, or by getting in touch with your advisor. We will address your request in a timely manner and will inform you if additional time is required.
Right to Have Your Information Corrected
You have the ability and responsibility to rectify any inaccuracies in the information we have on record about you. Ensuring the accuracy and completeness of your information is crucial for us to deliver a high-quality service. Therefore, we depend on your cooperation to keep the information we hold up to date by promptly notifying us of any changes.
Security and Retention
Time-Limited Retention
We maintain your information, whether in physical or digital form, for the duration necessary to fulfill the initial purposes for which the information was collected or as long as mandated or allowed by applicable laws. The retention periods are determined by considering the purpose, nature, and sensitivity of the information.
Bloomridge is bound by various legal obligations concerning the retention of personal information, including regulations related to securities, taxation, and anti-money laundering. Generally, in order to comply with these obligations, your client profile details (such as your name, address, and date of birth) will be kept throughout your association with us and for an additional ten years following the termination of our business relationship. Additionally, we will maintain your transactional data and notes for seven years after the conclusion of transactions.
Certain circumstances might necessitate extended retention periods, such as in cases involving disputes or claims, where your information could be retained for up to ten years. When your information is no longer required, we will make reasonable efforts to securely destroy it.
Cross-Border Data Transfer
Your information may be stored and processed in Canada and other countries, including the United States. It is important to note that, in certain instances, your information might be subject to the laws and access regulations of foreign authorities. However, our practices regarding your personal information will at all times be governed by this policy.
Information Security Program
We work to protect your information against loss, theft, unauthorized access, and misuse. To address evolving information security threats, we maintain a comprehensive security program encompassing: the security of our infrastructure, which involves secure access to our premises and safeguarding the locations where our equipment is stored; restricting access to your information so that only employees with specific job responsibilities that necessitate access are permitted to do so; and implementing robust password management and firewall configurations.
We strongly advise against sharing your passwords, codes, or personal identification numbers (PINs) with anyone. Our employees will never ask for this information.
Policy Updates
This policy reflects our current practices and will be updated as those practices evolve. We will notify you of material changes through our website or by other appropriate means.
How to Reach Us
For inquiries, comments, or complaints: contact your investment advisor or representative directly, or get in touch with our Chief Privacy Officer, whose contact information is provided at the start of this document.