Personal Information and Obtaining Consent
Personal information is any information that identities 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.
As ModernAdvisor is not currently registered as a Portfolio Manager we are only able to show users of our website a preview of our services. This preview does not require users to enter any personal information. Users can provide their e-mail address if they would like to be contacted when ModernAdvisor is ready to offer its investment management services to the public.
Who do we disclose personal information to?
A user’s e-mail address will only be used for the purposes for which it was collected. ModernAdvisor may use this information as required by law and with third parties assisting us in providing services. 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 request.
Users are able to withdraw consent to be contacted using their e-mail address by contacting us. Users should contact ModernAdvisor’s Chief Compliance Officer to withdraw consent to any use and disclosure of e-mail address.
Where is personal information kept?
Personal information in our possession is exclusively stored in electronic format in the offices of ModernAdvisor or on Amazon Web Services (AWS) secure servers. AWS is a leader in web infrastructure trusted by organizations 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.
Protecting Personal Information
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 users’ personal information to fulfill their duties are provided with access on a “need to know” basis.
Each ModernAdvisor employee with access to a user’s 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 users will be used for the purposes identified at the time of collection and will be retained for as long as is necessary to fulfill the service or as required by law.
Passive Data Collection
ModernAdvisor may receive passively-collected information through a variety of methods, including “cookies” to collect information.
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then 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.
We also collect non-personally identifiable information through the use of tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the Website. We use tracking pixels to show ads to you across the Internet, specifically on the Google Content Network (GCN). As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system.
We may also use tracking pixels and URLs when sending emails to help us measure open rates for e-mails and link clicks. This tracking information is used internally only to help us provide relevant content and is never shared with any third parties.
Analytics And Marketing
ModernAdvisor uses analytics tools and other third party technologies, such as Google Analytics, to collect non-personal information in the form of various usage and user metrics when you use our Website.
We also use online advertising to reach new potential clients and remarketing tools that allow us to target ads to specific groups of people who have previously interacted with ModernAdvisor’s Website.
Google allows individuals to opt out of its advertising cookies from its Ad Settings Page
Questions and Concerns
Email: firstname.lastname@example.orgMailing address:
300-1110 Hamilton Street
Vancouver, BC V6B 2S2
Attn: Chief Compliance Officer