Our Privacy Philosophy
“You” refers to anyone who visits our website(s), our clients and anyone who engages with our content. It’s our duty to inform you about what we’re doing with your personal information and why, and ensure you are properly informed so you can give us meaningful consent.
You have the right to withdraw your consent from us collecting and using your personal information, but this may limit our ability to provide you with our services or products, if applicable. See below for details around same.
Types of Information Collected
The type of information that may be collected by FinPipe, as applicable, includes but is not limited to:
- Contact information: this information allows us to identify you as well as send you materials. It lets us communicate with you for instructions and requests. It includes your name, mailing address, email address, and telephone number.
- Banking information: including your bank account information, billing address, or other banking and financial information required to complete your order.
- Date of birth: this information allows us to fulfill our legal obligation to establish your identity and helps protect against error identity theft, and fraud.
- Employment History: we collect this information to better understand your unique financial situation and investment needs, and to help us fulfill our Know Your Client and Suitability determination obligations.
- Profile information: may include your username and password, requests made by you, your interests, preferences, feedback, and survey responses.
- Transaction information: includes details about payments to and from you and other details of subscriptions and redemptions you have requested from us, including product information and dollar values.
- Marketing and communications information includes communication preferences and your preferences in receiving marketing or other communications from us and third parties.
- Computer information: this includes information like device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behaviour, length of time spent on the services, and frequency of use; and
- Other information you voluntarily provide to us, our service providers, or our contractors.
Information will be collected by fair and lawful means. We won’t take more information than we need, and you decide how and what you want to share.
Why We Collect Your Information
At FinPipe, we collect and use personal information for reasons like:
- Business and website operations: to administer and protect our business and this Website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
- Marketing and advertising: to be presented on our website. We may also administer and offer tailored content, and other promotional materials to you based on your interests.
- Business development and market research: we use data to understand demographics, interests, usage patterns, and other characteristics of clients and to track and analyze trends and patterns.
How We Collect Your Information
Personal information may be collected in a number of ways, including through our website, in person, by mail, by email, from our applications or other software, and from third parties whom you have authorized to disclose personal information to us.
If you provide information about a third party or authorize a third party to do so, we will assume you have taken proper measures to obtain informed consent.
Cookies can be used to: (i) recognize you when you visit the Website, remember your preferences, and give you a personalized experience that’s in line with your settings, (ii) make your interactions with the website faster and more secure, and (iii) bring you advertising and customized experiences through personalization. Further, cookies are used for authentication, security, and research.
If you post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or other applications, your communications may be viewable by the public.
Who We Share Your Information With
FinPipe may share your information with third parties. FinPipe will do so to support with providing our services, administering our business, and for such other purposes as set forth below, including:
- Administrative and technical support: including cloud storage providers, IT support, and data analytics providers.
- Securities and tax regulators: including applicable governmental and regulatory entities required as part of securities and tax law compliance.
We may also disclose personal information in situations where we are legally required or permitted to do so. These situations may include criminal investigations, government tax reporting requirements, court orders, or instances where we believe the rights and safety of others may be at risk. We may be ordered by a court to disclose personal information to a third party or to the court, or to preserve personal information pending the outcome of a legal hearing. We may also be legally required to disclose information in connection with the collection or repayment of a debt, to assist in the prevention of fraud or other criminal activity, when we obtain legal advice from a lawyer, or in an emergency that affects the health or safety of an individual.
In the instances described above we may be required to share your personal information with or without your consent. In limited circumstances, we may be legally prohibited from advising you that your information was shared in this way.
If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let the Chief Privacy Officer know immediately.
We make every reasonable effort to keep your personal information as accurate, complete, and up to date as necessary. We encourage you to verify the accuracy and completeness of your personal information in our records.
Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.
Protecting Your Personal Information
Our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information.
To ensure that your personal information is protected, we utilize security safeguards that are on par with industry standards. We keep electronic files in a secured environment with restricted access and use.
Despite all the foregoing security measures, online storage and online communications are not entirely secure. We encourage all individuals to provide only the information they are comfortable with providing a third party, keep watch for communications that are suspicious, and report any suspicious activity to us as soon as possible. As a community, we can all help keep it safe.
You may withdraw your consent for our use and collection of your personal information at any time, however this may limit our ability to provide services or products to you, if applicable.
Personal Information Outside of Canada
Personal information provided to our service providers may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored, or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.
Addressing Your Inquiries and Concerns
Attention: Chief Privacy Officer
100 York Boulevard, Suite 550
Richmond Hill, Ontario L4B 1J8
Last revised: June 2023