1. What is the purpose of this policy?
Our primary objective is to maintain transparency with you. This policy pertains to the utilization and disclosure of any data gathered about you and how Bloomridge (referred to as “the company”) 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.
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, 1155 Metcalfe, 15th floor, Montreal QC H3B 2V6
Or contact your representative for any additional questions you may have.
2. What type of information we may collect and from whom
2.1. The type of information we may collect
Information to identify yourself
- 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)
- Account numbers in different institutions you wish to share with us to conduct our activities
- Information we have about you as an authorized representative, director, officer or shareholder
*While providing your Social Insurance Number or Social Security Number is not mandatory, it can assist in verifying your identity with credit-reporting agencies. Moreover, it becomes necessary for tax-related matters, particularly when an account generates income.
Information to verify your identity:
- User ID
- Account information
- In person
Financial information to verify your eligibility for products and services and analyze your creditworthiness when advising on credit services offered by other financial institutions.
- 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
- Professional and financial background
- Your reason for doing business with us
- Language and communication preferences
- Details regarding individuals other than yourself, such as a proxy holder, secondary account holder, beneficiaries, your spouse or common-law partner, dependents covered by an insurance product or registered plan, an authorized user of your account, and the contact information of individuals you think might have an interest in a product or service from Bloomridge.
* When you furnish us with details concerning another person, we will presume that you possess the necessary authorization and have acquired consent from the concerned individual for the collection, utilization, or disclosure of their information in accordance with the objectives stated in this policy.
Information about your operations
- History of the transactions and interactions in your accounts
- Investment instructions
- Knowledge and goals for investments and financial planning
- Risk tolerance and investment objectives
Health and lifestyle data required for subscribing to insurance products or services through third-party insurers, with your explicit consent. This includes:
- Your family’s medical history.
- Your activities, behavior, and choices.
- Information related to your travel, sports, and potentially hazardous recreational pursuits.
Data used for training, quality assurance, identification, security, or documenting your transaction consent, such as:
- Archiving, recording, and transcribing telephone calls, video conferences, and chat sessions.
- Keeping records of your visits to our offices and one-on-one meetings.
- Images obtained from security cameras located in and around our office premises.
Details regarding digital engagements (websites, applications, chat services, text messaging, social media platforms).
- Data related to your devices (e.g., IP address, VPN, proxies, device type, and operating system).
- Information concerning your approximate location derived from your IP address when accessing our websites.
*We restrict the gathering of your information to the extent required for us to effectively assist you.
2.2. How we collect your information
We can gather your information in two ways. The first is direct collection, which occurs when you communicate or engage with us or when you modify your account preferences and settings. The second method is indirect collection, which involves obtaining information from the sources mentioned below. When necessary, we will seek your consent.
- Other individuals related to your products and services
- Other financial institutions or lenders, insurers ( when we need to verify the accuracy of information provided)
- Brokers, dealers or other stakeholders in securities or other fields
- Credit reporting agencies
- Publicly available sources or records
- Regulatory bodies and self-regulatory organizations ii
- National Bank or its subsidiaries (custody services)
- Content generated through the use of our websites, mobile apps and social media platforms.
3. How we use and share your information and with whom
3.1. How we use and share your information
We utilize and share your information for the following purposes:
- Confirm your identity, update your details, and ensure the accuracy of the information you supply.
- Regularly evaluate your financial situation and creditworthiness, particularly when you hold a credit product.
- Determine your eligibility for products and services or ensure that the guidance, products, and services we offer align with your needs.
- Employ automated decision-making processes (for further details, refer to section 5.5).
- 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 by the Bank and its subsidiaries 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 customer experience, incorporating analytics of your profile, transactions, and other data (including information gathered through our websites and mobile apps) to:
- Gain a deeper understanding of your preferences and requirements.
- Identify and customize products, services, and promotions tailored to your interests and situation.
- Offer improved advice based on the analysis of your needs and preferences.
- Promote products and services that might interest you, whether from National Bank, its subsidiaries, or select partners, including personalized advertising on social media platforms.
- Inform you about new features available on our mobile apps.
- 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.
- Employ specific information use and disclosure authorized by law..
3.2. 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 place great importance on maintaining the integrity, security, and confidentiality of your information. Please be assured that we never sell client lists to third parties.
We might disclose your information to:
- Our primary custodian, National Bank, and its affiliated entities, as well as other financial institutions where your funds are held and where advisors are involved, 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.
- Other financial institutions, lenders, credit insurers, or credit reporting agencies.
- 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.
- Authorized individuals as per legal requirements.
- Third parties, if necessary during legal proceedings.
- As delineated below, service providers we engage for specific functions such as check printing, issuance of bank cards, production of investment statements, management of loyalty programs, and execution of marketing services on our behalf.
3.3. Service providers
We exercise meticulous consideration when choosing service providers, who fall under the following classifications:
- Technology services (including applications, data center, data storage, backup, hosting, and support services).
- Professional services.
- Financial and banking services.
- Insurance services.
- Communications services.
- Mail services.
- Analytical and marketing services.
All suppliers who have access to your information are required to enter into a confidentiality agreement with us. They commit to utilizing your information exclusively for the purposes specified in the agreement and ensuring it receives the same level of protection that we afford to your data.
4. When we may need your consent
We exclusively utilize 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.
- 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.
- Prevent, halt, or identify instances of fraud.
5. What are your rights and how to exercise them
5.1. Right to accept or refuse to provide your information
Your information is your own. Subject to legal, business, or contractual obligations, you have the prerogative to revoke your consent regarding the collection, usage, or disclosure of personal information. We will promptly address your request.
Nonetheless, certain types of information are indispensable for us to furnish specific products and services. If you decline to provide such information, it may be arduous, if not unfeasible, to establish or sustain a business association with you, or even to offer certain products. 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.
5.2. 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.
We may also employ an encoded form of your email address or other contact details to form personalized audience groups on social media and digital platforms. This allows us to showcase advertisements tailored to your preferences and interests on these platforms. You can decline the utilization of your information for targeted advertising by adjusting your preferences within your social media account settings or by getting in touch with us.
Periodically, we may reach out to you to inquire if you wish to update your preferences, ensuring our records stay current and align with your actual choices.
It’s important to note that even if you opt out of this use, you may still encounter some of our advertisements on social media platforms. However, these ads will not have been tailored based on your contact information.
- 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).
- 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. This data helps us assess and analyze website traffic to enhance your online experience. It also empowers us to provide you with tailored offers and services. If you prefer not to have this data collected, you can simply click on “Cookie preferences” located at the bottom of our websites. Alternatively, you can log in to our mobile app and, under the “My Preferences” section, select “Manage my digital data collection.”
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 and mobile apps at any time.
What you will still receive after withdrawing: You will continue to receive:
- Mandatory notices that we are legally obligated to provide.
- Service-related messages included on account statements from your custodian and information concerning your existing products and services.
You may also receive information about our products and services through verbal or in-person interactions with our representatives, particularly from those with an advisory duty when necessary.
5.3. Right to access your information
You have the right to inquire about the information we possess regarding you, except when legal restrictions apply.
How to retrieve your information: 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 within 30 days, or within a timeframe exceeding 30 days if mandated by legal requirements. You will be informed if the processing period extends beyond 30 days.
5.4. 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.
6. What are our security safeguards for storing your information
6.1. 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 banking, 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.
6.2. Places where we keep your information
Bloomridge, along with its service providers and other third parties to whom your information is disclosed under this policy, may conduct operations beyond the borders of Quebec and Canada. As a result, your information may be securely utilized and stored in various provinces and countries. It’s important to note that, in certain instances, your information might be subject to the laws and access regulations of foreign authorities, including those in the United States.
6.3. Information Security Program
We dedicate significant efforts to safeguard your information against potential risks like loss, theft, unauthorized access, use, disclosure, and other security breaches. To address evolving information security threats, we maintain a comprehensive security program. This program encompasses several protective measures, including:
- Ensuring the security of our infrastructure, which involves secure access to our premises and safeguarding the locations where our equipment is stored, among other aspects.
- Restricting access to your information so that only employees with specific job responsibilities that necessitate access are permitted to do so.
- Implementing robust password management and firewall configurations.
You also play a crucial role in protecting your information. We strongly advise against sharing your passwords, codes, or personal identification numbers (PINs) with anyone. It’s important to note that our employees will never request this information from you. Additionally, we recommend refraining from transmitting personal information via email.
7. What other terms and conditions go along with this policy
If you engage in transactions with, or your data is gathered by a partner financial institution situated in the European Union, specific entitlements under the General Data Protection Regulation (GDPR) pertain to the management of your information. It’s important to note that this policy does not diminish your rights under the GDPR. A comprehensive explanation of your rights and the handling of your information will be furnished to you at the moment the information is gathered.
8. How we can make changes to this policy
We reserve the right to modify this policy periodically. Any changes will be communicated to you through a notice displayed on our websites and by employing other suitable methods to reach out to you.
9. How to reach us with a question, comment or complaint
For inquiries, comments, or complaints, you can:
- Contact your investment advisor or representative directly.
- Get in touch with our Chief Privacy Officer, whose contact information is provided at the start of this document.