Privacy policy
About this policy
Our firm is a member of Integrated Advisory, facilitated by Integrated Advisory Professionals Network Inc.
This policy provides notice of how Integrated Advisory™ and its Network Members (referred to as “Members” through this document) collection of information and uses practices. It applies to the information we collect from you when you interact with us.
This applies both to online & offline information collection; including websites operated by us. It clarifies how it might be shared and how you can change your privacy choices. Your use of this platform indicates that you agree to our collection, use, and disclosure of your information as outlined in this Privacy Policy.
-
Your privacy is important to us.
Integrated Advisory is a group of individual and independent participant entities (advisors, consultants, service providers) known as “Integrated Advisory Members” who while maintaining their independence from each other, cooperate and work together in providing wide-ranging and value-adding services to you in the wealth creation, wealth protection and asset management space along with services related to that.
Given your distinctive needs, and the growing complexity of the industry, there is a huge need to assist clients like you efficiently and to seamlessly obtain services in a wide range of areas. That includes (but goes beyond) tax advisory, asset management, insurance, estate planning, and legal services.
In providing such a wide range of services, and tailoring products and services to you, the gathering and use of personal information is required. How Integrated Advisory and it’s Members each gather and collect personal information, how it is used and stored, and when it gets disclosed and to whom is described in this Privacy Policy.
-
“Personal Information” includes anything that helps identify you specifically and individually. Normally, such information is provided directly by you or authorized agent (for example your accounting firm, or law firm). Contact information (for example, an email address), information that is already available publicly or information that is aggregated or anonymized that nonetheless includes information about you is not considered to be personal information.
Personal Information gathered by one Integrated Advisory Member or Participant can be shared across the Network, unless you specifically forbids that. However, and as emphasized through-out this Privacy Policy, that is done strictly to provide more comprehensive and tailored advice.
-
By providing a Member within Integrated Advisory with your personal information, you consent to the collection, use, disclosure and retention of that information by the Integrated Advisory Member in accordance with their Privacy Policy and as otherwise permitted by applicable law. You can withdraw that consent at any time, subject to legal or contractual restrictions with reasonable notice. Note that withdrawing consent might inhibit your ability to proceed with your intended interactions and transactions with Integrated Advisory.
For Integrated Advisory and its Members to provide services to you, you must consent to the sharing of Personal Information. That is done per the privacy policies of each Member, (which are consistent with this Privacy Policy) or through a Retainer with that Member with whom you had initial contact, or through whom Integrated Advisory is introduced. Existing Member clients would be informed of the Network and the sharing of their Personal Information, along with other confidential information (which would include things like financial information). Unless you specifically objected to that, consent would be deemed to have been given.
That does mean gathering and storing such information. So, in using Integrated Advisory (and any Member of the Network), you are consenting to the collection, storage, and disclosure of the same across the entire Network. Any Integrated Advisory Member may access that information if services in relation to you are required or requested from another Member. In such a case, Personal Information will be disclosed and used as is needed, be that for provision of services, for marketing purposes or because of the requirements of other Members, cooperative partners and other third parties.
Please see Section 7 to learn about your options regarding withdrawal of consent.
-
Within the scope of dealings with Integrated Advisory and its Members, from the outset and as relationships develop, more of your information will be gathered and stored. That comes primarily from you directly. Information is also gathered through other sources, like when you visit a Member website or an affiliated website, including those of partners and other service providers who deal with Integrated Advisory and any of its Members. Personal Information is also gathered from other parties a client might share information with if that party has consent to release information.
To emphasize though, Members of Integrated Advisory may share information with other Members, and other parties with whom the Network engages.
(a) Information You Provide
Client information / Personal Information includes (but is not restricted to):
contact information (such as name, email address, residential address, and phone numbers), when you make an inquiry or contact us,
identifying information, which includes things like government issued ID, social insurance number, birth date, driver’s license, employment information, bank account information and other financial information. That can include payment card information, information about salary and investments, insurance policies, financial investments, property holdings and information gleamed from financial, background & credit checks.
information about family and / or close associates, which can include information about a spouse, partner, and other family members; and,
correspondence and other communication between us.
You are at liberty to disclose (or not disclose as the case may be) any information so desired. However, certain minimum information is needed to provide helpful and valuable assistance and services.
It will always be assumed that the information you provide about other people is being done with their full knowledge and consent. That includes information about minor children along with anyone else under a client’s care or guardianship who does not have the capacity to provide informed consent.
(b) Automated Collection
The Integrated Advisory may automatically collect certain information regarding your use of the Integrated Advisory websites such as dates, times those websites are accessed, browsers, operating systems, software and devices that you use to access our websites and details of your use of the website.
Integrated Advisory and Member firm websites, emails, and advertising may use technologies such as cookies, web beacons, tokens, pixels, or tags to collect information to help theIntegrated Advisory and its Members improve products, services, client communications & advertising, as well as to prevent fraud. Integrated Advisory and its Members may use information collected through technological means to recognize you as a user of Integrated Advisory and Member websites, to improve websites, to confirm successful delivery of messages to and opened by you and to provide targeted marketing. You can decline or disable cookies if a web browser or on-line device permits. However, in doing that, access to certain websites (or certain features on them) might be denied. Additional information on cookies can be found in Section 5 c) below.
(c) Information from Other Sources
On occasion, Personal Information about you may be gathered from third parties. That will only be done with your consent, subject to the provision of requisite consent to the third party. It will also be done if it is legally required or permitted.
For instance:
In dealing with another Member, their subsidiary, or another cooperative partner or service provider to the Network, consent may be needed to obtain a credit check.
Personal Information may be obtained from a referral source, such as an existing client or a lawyer or banker who has been authorized to provide information.
-
(a) Provide Value Adding Products & Services
The nature of products and services offered to you are customized to you. Services are not mass market oriented. That is why obtaining Personal Information is vital to the value and potential success of any product or service offered through Integrated Advisory by a Member or Participant. Some of the reasons personal information is collected:
to establish and govern a Member’s relationship with you, to ensure your needs, goals and objectives are better understood;
to maintain contact with you;
to provide a smoother and integrated client experience;
to provider better and more efficient interactions;
to better target more useful information towards you (including by email and other electronic messages);
to help develop better products and services;
to respect legal rights to privacy;
to protect the legal rights of each Integrated Advisory Member and Participant; and
to comply with legal and regulatory requirements.
Personal information is also used to better identify other content and information that might be useful to you. That allows an Integrated Advisory Member to:
help determine what sort of other products and services might be of interest to you;
communicate more effectively about suitable products and services, inclusive of via advertising and marketing messages;
inform you about promotions;
provide updates on matters of interest; and,
engage in and conduct surveys on the quality of products and services.
Personal Information might also be used to create non-personal information. That in turn may be used, disclosed and transferred to other third parties and partners an IAN Member might cooperate with.
(b) Confidential Profile
Each Member may develop and maintain a confidential client profile to use for internal purposes connected to improving your overall client experience. That would enable the Member (and in turn, other Members) to be better able to tailor products and services for you.
(c) Interest-Based Advertising
As mentioned above, Integrated Advisory and its Members will make use of tracking software like cookies and web beacons to store information about each client’s use of websites and other social media platforms. That also allows other third party service providers whom the Members cooperate with or work with to send you advertisements that may be of interest to you when you access other websites, social media sites or other online services
You can opt out of receiving interest-based advertising on a website, social media site or other online services by using their advertising preference settings. If you do so, you may still see Integrated Advisory and Member ads on the site, but those ads will not be based on tracking technologies.
-
Integrated Advisory Members may disclose Personal Information to partners, service providers and others beyondIntegrated Advisory who nonetheless cooperate and work with that Member. This is subject to your consent, which may of course be denied or withdrawn at any time with prior notice. Even if consent is later withdrawn, each Member is obligated to disclose Personal Information if that is required by law (for example, responding to a Court Order or other investigation).
(a) General Information Sharing
Members of the IAN disclose your personal information for purposes relating to or arising from your interactions with Members of Integrated Advisory and as otherwise set out in this Privacy Policy or permitted by applicable law. Only employees of the Members of Integrated Advisory or trusted service providers who need access for business reasons, or whose duties reasonably so require, will be granted access to your personal information. Integrated Advisory and its Members will not sell, rent, or trade your personal information to any third party. Refer to section 7 of this Privacy Policy to view your options regarding the withdrawal of consent.
(b) Specific Consents
A Network Member may disclose Personal Information to other persons in accordance with express or implied consents that have been given (including given orally by you) during interactions and transactions with any Integrated Advisory Member.
(c) Subsidiaries, Affiliates and Business Partners
Personal Information may be shared within Integrated Advisory, which can include a Member’s subsidiaries and affiliates. That is done per the discretion of the Member, as is necessary and needed to provide the products and levels of service required. In certain circumstances, personal information may be shared with business partners with your consent or as otherwise permitted by applicable law.
Given their independence from each other and the Network as a whole, one Member cannot and will not take any responsibility or be liable for any breaches (howsoever arising) of the confidentiality obligations or undertakings of another.
(d) Suppliers and Service Providers
Given the nature of the industry, the Network through each of its Members will generate a lot of data. That includes but is not restricted to Personal Information. As such, third party storage companies are engaged to assist with the safe storage and retrieval of such information. Such third parties include (but are not restricted to) cloud service providers and payment processors. Such entities do have their own confidentiality undertakings, policies, and provisions, which is confirmed on their being retained. However, as emphasized above, neither the Network nor any Member can or will take any responsibility or be liable for any breaches (howsoever arising) of their confidentiality obligations or undertakings.
(e) Legal Requirements
In the event an Integrated Advisory Member is required by law, or by legal procedures like Court Orders, or subpoenas to disclose Personal Information, that will be done. Disclosure to law enforcement agencies and to the Canada Revenue Agency as required or authorized by applicable law or in connection with national security or other issues of public importance, may also be made.
Integrated Advisory and its Members have no control over, or responsibility or liability for, the use, disclosure or retention of your personal information by the agencies, independent organizations or other persons to whom Integrated Advisory and its Members discloses the information in the foregoing circumstances, and the collection, use, disclosure and retention of the disclosed information by those agencies, independent organizations or other persons is not subject to this Privacy Policy.
-
When you interact with Integrated Advisory or one of its Members online or through a website or social media platforms, you consent to the collection, use, disclosure, and retention of our personal information as set out by this Privacy Policy.
You can withdraw consent at any time.
(a) Withdrawing your consent for integral purposes:
You may withdraw your consent for purposes that are integral to the provision of our products and services, subject to legal or contractual restrictions and on reasonable notice to Members of the Integrated Advisory, but then you might not be able to proceed with your intended interactions or transactions with Members of Integrated Advisory or otherwise receive the full benefit of Integrated Advisory Members products and services. If you withdraw your consent to purposes that are integral to the ability to provide products and services, those products and services may need to be limited or withdrawn.
(b) Withdrawing consent for additional purposes:
Other purposes such as advertising, are not integral to the provision of products and services. Your withdrawal of consent to those purposes will not impact the provision of our products and services to you. You may withdraw your consent to your personal information being used or shared for the following additional purposes:
to communicate with you for the purposes of providing you with advertising and marketing messages pertaining to additional products or services that may be of interest to you. You can always limit the electronic communications sent to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” at the bottom of any commercial electronic communication we send you. Please note that even if you opt out of promotional communications, we may still need to contact you with important information about your product or service; and
to conduct surveys on the quality of our products and services.
To withdraw your consent, you may contact the IAN Privacy Officer by mail or email at: IAN ADDRESS - 350, 205 Quarry Park Boulevard S.E., Calgary, AB T2C 3E7; email: Privacy@integratedadvisory.ca or the IAN Members Privacy Officer.
-
Personal Information is normally stored in Canada. Some Integrated Advisory Members and service providers may process, store, and use Personal Information outside of your province, territory or in other countries. As a result, Personal Information governance may be subject to the laws of other jurisdictions. The personal information protection laws of those other countries might be different from the laws of the jurisdiction in which you reside, and might permit courts, government, law enforcement agencies, regulatory agencies, and security authorities to access your personal information without notice. Integrated Advisory and its Members use all reasonable safeguards, including contractual requirements with our service providers, to protect your personal information wherever it is located.
-
Personal Information is stored and kept as data only for the period necessary to fulfill the purpose for which it was collected. However, it is also stored and maintained subject to applicable law. Legal considerations will trump any client withdrawal of consent or demands that Personal Information be deleted or destroyed.
Subject to legal requirements, contractual and other obligations, requests to delete or destroy Personal Information will be done within a reasonable period. Please note that some information about you may need to be retained to satisfy legal and security obligations. For example, some information may remain in back-up storage even if you ask Integrated Advisory and its Members to delete it.
-
Personal Information is stored and kept as data only for the period necessary to fulfill the purpose for which it was collected. However, it is also stored and maintained subject to applicable law. Legal considerations will trump any client withdrawal of consent or demands that Personal Information be deleted or destroyed.
Subject to legal requirements, contractual and other obligations, requests to delete or destroy Personal Information will be done within a reasonable period. Please note that some information about you may need to be retained to satisfy legal and security obligations. For example, some information may remain in back-up storage even if you ask Integrated Advisory and its Members to delete it.
-
We rely on you to ensure that the personal information provided to Integrated Advisory and its Members is accurate, complete, and up to date for the purposes of its use. You are relied upon to promptly notify Integrated Advisory and any Members of any changes to the personal information that you provided.
You have the right to access your own Personal Information and to have it corrected by contacting the retaining Member or sending notice as set out in section 9 above. However, that will require time to respond. Also, responses unfortunately cannot be provided to any request that a Member deems to be repetitive, frivolous, vexatious or impracticable, that infringes or jeopardizes the privacy of other persons, or for other reasons permitted by applicable law. All reasonable requests will be responded to.
-
Member websites and correspondence (including emails and messages) and those of the Network may include advertisements for products and services offered by Integrated Advisory Members, independent businesses or links to websites or mobile apps operated by independent businesses that enhance products and services offered by a Member. They also provide useful and educational information. However, neither Integrated Advisory nor any of its Member takes any responsibility or liability (howsoever arising) for, or control over, those other websites, mobile apps, online services or businesses, their products or services, or their collection, use, disclosure or retention of Personal Information.
Such sites would normally have their own privacy policies. However, this Privacy Policy does not apply to the collection, use, disclosure, or retention of Personal Information by those websites, mobile apps, online services and independent businesses. Also, neither Integrated Advisory nor any of its Member can or will be responsible for any breach of privacy laws or rules by any of the aforementioned. If you have questions about how those websites, online services or independent businesses collect, use, disclose or retain personal information, please contact the owner or operator of the website, service, or business.
-
Integrated Advisory website(s) and those of its Members do have and include links to other social media websites. Information posted or shared on them is accessible to other persons and companies, who may and do target visitors. Social media websites have their own privacy policies and practices, and you are responsible for the personal information that you post to those websites.
When a link to a social media website is clicked on, that means departure from the IAN website or that of a Member. Any information posted or left behind is your sole responsibility. Neither Integrated Advisory nor any of its Members takes or has any control whatsoever over what you choose to post or share. Integrated Advisory and its Members have no control over, or responsibility, or liability for, the collection, use, disclosure, or retention of the personal information that you disclose in those situations, and this Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites.
-
This Privacy Policy only addresses the collection, use, disclosure and retention of personal information by The WealthCo Group of Companies. Social media websites have their own privacy policies and practices and you are responsible for the personal information you post to those websites.
When you use certain aspects of The WealthCo Group of Companies’s websites or other services to access or post information to social media websites (e.g. there may be links to The WealthCo Group of Companies’s Facebook, Twitter, Instagram or LinkedIn pages), the personal information that you post or share in connection with these third party websites is visible to other persons and can be read, collected, used and disclosed by other persons, including to send unsolicited messages to you. When you click on a link to a social media website, you will leave the The WealthCo Group of Companies websites and go to that social media website. Any information provided to such third party social media websites and other websites is governed by their own privacy policies, which you may read on the applicable website. You are solely responsible for the personal information that you choose to post or share in those situations. The WealthCo Group of Companies has no control over, or responsibility or liability for, the collection, use, disclosure and retention of the personal information that you disclose in those situations, and this Privacy Policy does not apply to the collection, use, disclosure or retention of your personal information by those websites.
-
Neither the Network nor any Network Member knowingly collects Personal Information from children under 13 years of age without the consent of a legal guardian. If you believe we might have any information from or about a child where we should have obtained parental consent, please contact Integrated Advisory’s Privacy Officer using the contact information set out in section 19 below.
-
The agreements (including any website terms of use) that you accept on application or registration to use a product and service contain important terms and conditions, inclusive of those that limit the liability of a Member (noting Integrated Advisory has no liability just as no Member has liability for the actions or omissions of another). Other terms and conditions include those governing dispute settlement along with various representations and warranties that a client is deemed to make, particularly concerning things like the accuracy of the information provided.
Those terms and conditions are binding and will be enforced accordingly. Moreover, this Privacy Policy is in addition to and over and above any other agreement entered. However, if any provision of this Privacy Policy conflicts with a provision of a written agreement with a Member, signed by the Member, then the latter will prevail.
-
Your continued dealings with Integrated Advisory and its Members after any change to this Privacy Policy will signify your consent to the collection, use, disclosure and retention of your personal information by Integrated Advisory and its Members as set out in the changed Privacy Policy. Accordingly, you should check the “Last Updated” date of this Privacy Policy (at the top of this Privacy Policy) and review any changes since the last version. The new policy will be governing and binding.
-
You consent to Integrated Advisory and its Members sending you emails (to the email address you provided) regarding this Privacy Policy and related matters.
-
Comments or questions about this Privacy Policy can be directed to the Member that introduced you to the Network or to: Integrated Advisory Privacy Officer by mail or email at: 350, 205 Quarry Park Boulevard S.E., Calgary, AB, T2C 3E7; email: Privacy@integratedadvisory.ca or the IAN Members Privacy Officer.