Privacy Policy for the Asset Allocation Analyst Web Site

EquiSoft remains committed to providing you (our clients) with best of class client service. As part of this commitment, we protect your privacy and the confidentiality of the information that you have entrusted to us.

In order to maintain your trust and confidence in us, EquiSoft’s Privacy Policy is designed to outline for you in a question and answer format important details about how we safeguard the privacy, confidentiality and security of your information.

1. Why does EquiSoft need to collect information about your advisors’ client investments?

Put simply, we serve and execute our duties in the exercise of our business relationship with you, our client.

We never collect more information than is absolutely necessary to meet the requirements outlined in the sentence above.

2. What information do we collect?

  • Personal information in the form of your client demographics, their children (if applicable), and spouses, (if applicable) when imported from the back-office system (if applicable) by the user of our software application, and entered in the client demographic screen and/or any other online forms related to the software application, filled out and saved in the current session for future recall. Imported or manually entered personal information may include your clients’ name, address, social insurance number, birth date, and employment contact information. Financial information may include annual income and net worth. Investment value information relates to information imported from the back-office (if applicable) or entered manually related to amounts held in a variety of accounts either registered, or non-registered saved in the current operational session for future recall, broken down by asset name;
  • Information you provide during telephone conversations with one of our representatives; Information you provide in e-mails or contact forms that you send us; Information that your browser provides about the browser type and configuration your computer uses so that you can view our website properly; Information you provide upon registration for Access to our software application; Log File Information. In an ongoing effort to improve the quality of our software application and website, we review server-generated logs, which provide information on software application and website use, browser types and limited demographic overview information with a view to determining usage trends only; Personal and financial information you provide in response to surveys, questionnaires, focus groups or other marketing initiatives.

3. What do we do with your information?

We use this information:

  • to properly identify you;
  • to professionally serve your business needs;
  • to establish your account and to maintain, record and store your account information;
  • to understand your usage trend/situation in order to provide you with suitable and appropriate service levels;
  • information that is either entered manually or imported from the back-office, is saved and made available in our software application for future recall by saving it in a current session, later available as the “last session”;
  • to develop and offer additional products and services that we feel may be of interest to you.

4. With whom is your information shared?

EquiSoft is not in the business of selling or distributing our clients' information to others. Client confidentiality and privacy remains a fundamental principle of ours and of the Canadian investment industry. When information is shared, EquiSoft remains the owner of all information shared and will not resell any data. However, we may share your information with others outside EquiSoft in certain limited circumstances including:

  • With Third Party Service providers whom we hire to perform services on our behalf. We provide them with a limited amount of information in order that they may provide services including, but not limited to, data processing, and market research. They are prohibited from using the information for purposes other than to carry out the services they have been engaged to provide. These third party service providers are not permitted to disclose this information to others. Sharing this information with these third parties is critical to EquiSoft providing you with best in class client service.
  • With Other Third Parties: Is some cases they may be providing critical back-office importation capability to our software application, in other cases they may be entities providing special promotions as in the case of product sponsors, or partners with whom we’re developing/improving upon new/existing software applications. Under all such circumstances your consent will first be required regarding any information sharing, and if such consent is received from you than the information shared will be the strict minimum required in order for them to provide the service promised, and will be in aggregate form in order to guarantee anonymity.
  • When Permitted or Required by Law. EquiSoft is compelled to disclose personal information in response to a law, regulation, court order, subpoena, valid demand, search warrant or other legally valid request or enquiry.

We may disclose information to our accountants, auditors, agents and lawyers in:

  • Business Re-organization As EquiSoft continues to grow; we may in the future re-organize or streamline parts of our operations. Because our business consists in large measure of our client relationships, we may disclose personal information to a third party in connection with an amalgamation, re-organization, and transfer or financing of parts of our business.

5. Where do we keep your information?

EquiSoft records and retains your personal information in electronic, microfilm or paper format at our Head Office location in Montreal, Quebec, Canada.

Your personal information may also be transferred to other off site locations as part of our disaster recovery practices.

6. How is your information protected?

The security of your personal information is our top priority. We employ extensive physical, electronic and internal procedural controls to protect your personal data. EquiSoft has comprehensive security standards to guard against unauthorized access to your personal information. For example:

  • We require users to identify themselves on the Online "Sign-In Page" before granting access to the software application, this could be a third party’s, i.e. as in a back-office provider’s sign-on page or EquiSoft’s depending on the circumstance.
  • We protect your account and log in information using highly secure "firewalls";
  • During the logon and authentication process, we send and receive your information in "encrypted" form to ensure maximum security;
  • In the event we receive a court order(s) or legal enquiries, we carefully review the document to confirm they are valid, and we send only the minimum information required. We disclose only the personal information legally required under the terms of the court order or legal enquiry;
  • EquiSoft employees ensure all personal information is handled properly and safeguarded adequately.

While we make every attempt to provide the most secure environment for your data, there are a number of things you as a client can do to ensure the protection of your personal data. We encourage you to take every reasonable precaution to safeguard your personal computer from known security threats.

7. How is EquiSoft minimizing access to the personal information?

We do not access personal or financial information for any purpose other than to best serve you and to identify how we can best meet your needs.

We do not ask for more information than we need to meet your needs and our legal requirements.

EquiSoft warrants and guarantees that client data and investment values (hereinafter referred to as “data”) acquired in the context of the use of the Asset Allocation Analyst by the dealer and their advisors is kept strictly confidential for an indefinite period, (or the longest period permitted under law). Unless legally required under operation of law, under no circumstances shall this data be disclosed or disseminated to parties outside of authorized personnel in the execution of their duties at EquiSoft, and related business partner(s) involved in the delivery of such services who at all times will also be party to a similar non-disclosure agreement.

8. How does EquiSoft collect, use and protect your personal information received online?

  • Visiting our informational sites: When you visit one of our informational websites and navigate through the content provided we learn what pages were visited, what pages were downloaded, the address of the site you visited prior to accessing our site and your Internet protocol address. We only use this information to gather overall site statistics (for example total number of visitors to the site). No attempt is made to identify you as an individual.

Information such as how people are using our site, which sections are of most interest and which pages are visited more frequently assists us in adapting our site to better suit your needs and make accessing information easier. No personal information about you is retained by us.

  • Cookies: Cookies are small text files that are placed on your computer when you visit a website.

    There are two types of cookies currently in use: "session cookies" and "persistent cookies". Session cookies store information only for the duration of your visit to a site. They are not written to the hard drive of your PC but rather are stored in your computer's memory. They do not exist after you have left the site. We currently do not use session cookies in any of our sites.

    Persistent cookies are written to your hard drive and remain there until they expire or are deleted by you. We use persistent cookies to store non-sensitive information. We use them to improve our site by tracking general information only (for example which pages are viewed most often). We recommend that you accept cookies while using www.assetallocationanalyst.com if your browser settings prompt you to do so.

Each time you use our software application service, we record your login id when you enter the system and when you leave.

  • E-mail: When you send us an e-mail we use that address to respond to your query via e-mail. We will store your e-mail and our reply for future reference should there be further correspondence.

    If you have asked us to put you on our e-mail mailing list to provide you with certain information on a regular basis you may ask us to remove you from that list at any time (using the unsubscribe instructions provided with each e-mail).

    Please remember that e-mail sent via the Internet is generally unencrypted and a potential security risk. We will only request that you transmit confidential information over the Internet where the communication is encrypted. You should use caution when forwarding emails and ensure that you do not include confidential information within the body of the messages.

9. What privacy rights do you have?

Except in limited circumstances, you may request from us access to your personal information that we hold. You may also question or challenge the accuracy and completeness of this information. We will respond to your request within 30 days.

Please note that we may not be able to provide you with your information in the following circumstances:

  • if it contains references to other persons; and
  • if the references are subject to legal privilege; and
  • if it relates to an investigation of a breach of agreement or law; and
  • if it cannot be disclosed for other legal reasons.

You are also permitted to withdraw your consent that allows us to share your personal information in certain circumstances (for example, the sharing of your information with third parties). You may withdraw such consent at any time by contacting us by e-mail or telephone at the address and number noted below. However, your decision to withdraw or revoke your consent may limit the products or services that we are able to provide to you.

10. Who do you contact about privacy concerns at EquiSoft?

  • EquiSoft has appointed a Chief Privacy Officer to handle all privacy issues. If you have any questions, concerns or issues about our Privacy Policy or about confidentiality issues or other issues raised here, you may contact us in writing as follows:

    Attention: Chief Privacy Officer

    By mail
    EquiSoft
    700 Wellington Street Ste. 1400
    Montreal, Quebec
    H3C 3S4
    		 By e-mail

  • You may also contact the Privacy Commissioner:

    The Privacy Commissioner of Canada
    112 Kent Street
    Ottawa, Ontario
    K1A 1H3
    Phone: 613 995-8210 or 1-800-282-1376
    www.privcom.gc.ca     		In Québec:

    La Commission d'accès à l'information
    575, rue Amable, bureau 110
    Québec (Québec)
    G1R 2G4
    Phone: 418 528-7741 or 1-888-528-7741