ModernAdvisor Canada Inc. (“ModernAdvisor”, “we”, “us”, “our”) takes the protection of personal information seriously. We have adopted a comprehensive privacy policy and have implemented practices to protect the confidentiality of clients’ personal information.
Personal information is any information that identifies an individual. This includes an individual’s name, address, date of birth, citizenship, financial records, social insurance number, credit history, personal e-mail address and telephone number. Clients provide consent to ModernAdvisor to collect personal information when opening their account and completing ModernAdvisor’s account opening forms (“Client Profile”) We will collect no more personal information than is absolutely necessary to perform the functions described in the following section.
In our capacity as a portfolio manager, ModernAdvisor clients provide us with their personal information. Understanding a client’s financial situation, family situation, and goals helps us ensure that all investment recommendations are tailored to that client and are suitable for them.
A client’s personal information allows us to:
A client’s personal information will only be used for the purposes for which it was collected. ModernAdvisor shares personal information with other parties as required by law and with third parties assisting us in providing services, including the custodians that hold custody of your investments, and credit bureaus in order to verify your identity in accordance with FINTRAC requirements. ModernAdvisor has legal agreements with such third-party providers to ensure the proper handling and protection of personal information. Additionally, we may be required to provide personal information when responding to a search warrant, court order or other legally valid requests.
As part of the account opening process, we are required by law to verify your identity in accordance with FINTRAC requirements. In order to do that, we use an identity verification product provided by one or more credit bureaus. Part of this involves a soft inquiry (or soft credit check) which verifies personal information you provide to us (name, address, birthdate, and SIN) with the credit bureau’s credit files. Unlike a hard inquiry (or credit check), no information on your credit history, credit score, or payment history is provided to us, nor will this affect your credit score. Unlike with a hard inquiry, a soft inquiry does not show on your credit file and is not visible to lenders. Only you would see Modern Advisor Canada Inc. (or ModernAdvisor) on the list of parties that requested access to your credit file when you view your credit file.
Clients are able to withdraw consent to use their personal information by contacting us. Legal or other requirements may prevent clients from withholding consent and a decision to withhold personal information may limit the services or products ModernAdvisor is able to provide. Clients should contact ModernAdvisor’s Chief Compliance Officer to withdraw consent to any use and disclosure of their personal information.
Clients have the right to verify the accuracy and completeness of their personal information and may request that it be amended. A client who wishes to change or update their personal information may do so at any time. Please note that we may not make the change if the changed information is no longer needed to fulfill the stated purpose.
Under certain circumstances, ModernAdvisor may not be able to provide clients with access to specific portions of the information. For example: (i) information containing references to other persons, (ii) information containing proprietary information confidential to ModernAdvisor, (iii) information that has been destroyed or (iv) information that is too cotly to retrieve.
Personal information in our possession is stored exclusively in electronic format in the offices of ModernAdvisor in Vancouver, British Columbia, on Google Drive, or on Amazon Web Services (“AWS”) secure servers. AWS is a leader in web infrastructure trusted by including Netflix, Expedia, Pinterest, Reddit, Intuit, Citrix and NASDAQ. Personal data stored with AWS is always encrypted both at rest and in transit using technology such as SSL. AWS servers are automatically configured with a firewall preventing attacks on the application source code, or the database. AWS data centres have multiple layers of operational and physical security to ensure the integrity and safety of data.
The disclosure of your information in accordance with this policy and applicable law may result in your personal information being transferred outside of Canada, including to the United States. The laws of other countries regarding the collection, use and disclosure of personal information may be different from the laws of Canada.
AWS and Google servers are located in the United States which means data stored on their servers are subject to US laws, including the US Patriot Act (“USPA”). The USPA gives US government and law enforcement agencies the ability to search for data retained by cloud service providers. All personal data stored by ModernAdvisor on AWS and Google servers is encrypted.
Policies, procedures, guidelines, and safeguards have been put in place at ModernAdvisor to ensure personal information is protected in accordance with Canadian privacy legislation (“PIPEDA”) Security measures including passwords and restricted access to our offices and records have been put in place to protect personal information against unauthorized access, theft or misuse. Only the employees that need to access clients’ personal information to fulfill their duties are provided with access on a “need to know” basis. sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. You can get more information about cookies here.
Each ModernAdvisor employee with access to client personal information is responsible for ensuring the confidentiality of all personal information to which they have access. As a condition of employment, every employee must sign a code of conduct, which includes comprehensive provisions ensuring the protection of personal information.
Any personal information collected from clients will be used for the purposes identified at the time of collection and will be retained for as long as it is necessary to fulfill the service or as required by law.
ModernAdvisor’s Chief Compliance Officer is responsible for ensuring that ModernAdvisor complies with its privacy policy. If you have any questions, concerns or complaints, contact information for ModernAdvisor’s Chief Compliance Officer is provided below:
Email: MAcompliance@guardiancapital.com
Phone: (416) 350-8119
Mail:
Modern Advisor Canada Inc.
1880 - 1075 West Georgia Street
Vancouver, BC V6E 3C9
Attn: Wealth Management Compliance
