Westmount Wealth Management Inc.
PRIVACY POLICY
Protecting your Privacy
This privacy policy (this Privacy Policy) applies to Westmount Wealth Management Inc. and its affiliates (herein after referred to as WWM, we, us, or our) and explains how we collect, use, and disclose personal information in Canada through our website located at www.westmountwealth.com through services provided to our clients, and through other interactions with consumers.
In general, “personal information” is information about an identifiable individual, subject to more particular definitions or interpretations under applicable law. This information may include, but is not limited to, your name, mailing address, e-mail address, financial information, and telephone number. This Privacy Policy does not apply to personal information about employees, partners, or other temporary or permanent staff, consultants, volunteers, or other individuals working for WWM (each, a WWM Member), or to any information that is not personal information as defined in or interpreted under applicable law.
The Personal Information We Collect
The personal information that we collect is often called the Know Your Client or KYC information. It can be broken down into three broad areas:
Your identity
This information includes your name, address, birth date, current employment and social insurance number. It helps us verify who you are, but it is also necessary information for the creation of any registered accounts and to meet our obligations under the federal Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and other federal laws aimed at the prevention and detection of money-laundering and terrorist financing.
Your financial situation
This information includes your current income level, your existing investment portfolios and other assets, and any debt you may have against these. We will also collect information about your existing banking relationships. It helps us establish the base line from which we will help you reach your financial goals.
Your goals, priorities, liquidity needs and risk profile
Once we have all of the other information, we can begin to construct a plan. For this step, we need to understand what your financial goals are and when you expect to start taking money out of your accounts.
A crucial part of this analysis is to understand how comfortable you are with taking risks to achieve your goals. We have developed a multi-dimensional risk assessment tool that helps us to understand this element of who you are. Once we have determined a risk score for you, we will use it to help assess the suitability of all investment advice or actions we provide to you.
We also collect personal information in the event that you respond to one of our employment opportunities.
How We Collect Your Personal Information and How We Use It
In general, we collect and use personal information in the following manner and for the following purposes:
Account Opening and Processing of Transactions
When you open an account with us, we collect personal information about you that is kept on file in accordance with industry regulations, including your name, date of birth, address, citizenship, income, investments, debts, marital status, dependents, and social insurance number.
The information that we collect allows us to open your account, act on your behalf, process your transactions, and provide you with reporting. Where applicable, it also allows us to identify you, to protect you against possible fraud, to assess your investment needs, and to comply with legal and regulatory requirements.
If you are an individual client of WWM, we are required to collect, use and disclose your Social Insurance Number for income tax reporting purposes.
We also collect an email address, a password, and information for security questions to allow you to login into your account on our website.
Marketing Communications
We may obtain your consent to use your information to send you marketing communications by mail or email that promotes products and services that may be of interest to you in accordance with Canada’s anti-spam legislation (“CASL”). You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below. Please note that you may continue to receive certain transactional or information electronic communications from us.
Customer Service
When you contact us with a comment, question or complaint, you may be asked for information that identifies you (such as your name, address and a phone number) along with additional information we need to help us promptly answer your question or respond to your comment or complaint. We may retain this information to assist you in the future and to improve our customer service and product and service offerings.
Employment
If you apply for a position at WWM, we will collect the personal information contained in, and generated in relation to, your application package, such as your work experience, education information, and contact information in order to evaluate your application and assess whether to offer you a position at WWM. For candidates who are not offered or do not accept a position, we normally retain this information for a reasonable period in the event that an appropriate position becomes available or that you reapply to WWM. If you accept a position at WWM, the information will be retained in accordance with our privacy procedures applicable to the personal information of WWM Members.
How We Disclose and Share Your Information.
We will only disclose your personal information in accordance with this Privacy Policy and pursuant to applicable privacy legislation.
Service Providers
WWM may transfer your personal information to our third-party service providers who will use it to administer or provide products, services or information on our behalf such as to host our website, operate certain of its features, send marketing messages or other communications, or manage and analyze data and our advertising effectiveness. We use reasonable measures to require the organizations with whom we share your personal information for these purposes to use your personal information only to perform the services we have contracted them to provide. At times, we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require the transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third-party's jurisdiction, including laws with respect to disclosure of such information.
Affiliates
We may also share your personal and financial information among WWM’s affiliates, like Westmount Wealth Planning Inc. (a wholly owned subsidiary), which may offer you insurance related products and services and financial planning services. If you access products and services by one of our affiliates, we may share personal information with the affiliate, subject to your consent, in order to provide the applicable products and services.
Legal/Compliance
We and our Canadian and other service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud or as otherwise required or permitted by applicable Canadian or other law. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
Website
In general, you can visit our website without telling us who you are or submitting any personal information. However, as most websites do, we track usage patterns on our website. Each time you visit our website, our server records your Internet service provider, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URLs you came from. We use this information to better understand and optimize our website service.
We also collect some personal information through cookies, tracer tags and web beacons on our Website.
Cookies, Tracer Tags & Web Beacons
Our website uses a technology called “cookies”. A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. We use cookies on the pages on our website where you are prompted to log in or that are customizable. If you have registered with our website, these cookies (1) may let us know who you are, (2) may be necessary to access your account information (stored on our computers), and (3) will provide us and our service providers with information that we will use to personalize our website in accordance with your preferences. We and our service providers also use cookies to help us understand our website activity, to improve our website and provide better customer service.
You may set your web browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our website, you may not be able to take advantage of all of the features and functionality of our website.
Analytics
Our website also uses web analytics services such as Google Analytics. They use cookies to help us analyze how visitors use the website. For example, with Google Analytics, the information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by a Google server. Google uses this information for the purpose of evaluating your use of our website, compiling reports on website activity for us, and providing us with other services relating to our website activity and internet usage. You can prevent the storage of data relating to your use of our website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
You can also obtain additional information on Google Analytics’ collection and processing of data and data privacy and security at the following links:
https://policies.google.com/technologies/partner-sites; and
https://support.google.com/analytics/topic/2919631
Third Party Links
For your convenience, we may offer links from our website to other websites. However, WWM is not responsible for, nor do we accept any liability for, the personal information collection, use, and disclosure practices of other entities to which our website may link. You should consult the privacy policies of these other entities before providing any personal information on their websites.
Your Consent
We collect, use and disclose your personal information with your consent or as permitted or required by law. Your consent may be expressed or implied, depending on the circumstances and the sensitivity of the personal information in question. If you choose to provide personal information to WWM, we assume that you consent to the collection, use, and disclosure of your personal information as outlined in this Privacy Policy. If you do not consent, please do not provide your personal information or, where applicable, exercise the opt-in or opt-out options offered.
Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use and disclosure of your personal information or you may withdraw your consent to our further collection, use, and disclosure of information about you, by contacting us via email at compliance@westmountealth.com Note that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide certain of our services. There are instances where WWM may collect, use, or disclose your personal information without your consent, for example, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records.
You can opt-out of receiving marketing offers at any time by clicking on the unsubscribe link included in our marketing email communications or by contacting us as set out under Contact Us below.
Retention of Personal Information
We will use, disclose or retain your personal information only for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by Canadian privacy laws.
International Transfer and Storage of Information
Note that some of the service providers that process or handle personal information on our behalf may be located outside of Canada. As a result, your personal information may be transferred, stored and/or processed outside Canada in connection with the purposes described in this Privacy Policy. While your personal information is outside of Canada, it is subject to the laws of the jurisdiction in which it is held and may be accessed by government authorities in that jurisdiction pursuant to those laws. For more information on our policies regarding foreign processing of personal information, contact our Privacy Officer (contact information is at the end of this policy).
Security
WWM has implemented reasonable physical, organizational, and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Authorized WWM Members, agents, and mandatories have access to your personal information. You can generally visit the WWM website without providing any personal information. However, given that electronically submitted data is not one hundred percent (100%) secure, we make no warranties as to the security of any such personal information that you submit, which you do at your own risk.
Access, Correction, Inquiries and Complaints
We maintain a file of your personal information for the above-mentioned purposes. If you wish to request access to, or correction of, your personal information in custody or control of WWM, please make your request in writing to us at the address below. We may need to verify your identity before searching for or providing you with personal information. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, or if it is otherwise not properly the subject of an access request. It is important that your personal information be accurate and up to date. Please inform us as soon as possible of any changes to your personal information. If you have any questions, requests, or complaints about our personal information practices, please contact us via email at compliance@westmountwealth.com .
Changes To This Privacy Policy
WWM reserves the right to change this Privacy Policy at any time, and we will take reasonable steps to advise affected individuals of any material changes, if necessary. However, you should review this Privacy Policy from time to time to ensure that you are aware of and accept any changes made. You may contact us at the address, email address, or telephone number below to obtain a current copy of this Privacy Policy.
Contact Us
Please contact our Privacy Officer if:
you have any questions or comments about this Privacy Policy;
you wish to access, update, and/or correct inaccuracies in your Personal Information; or
you otherwise have a question or complaint about the manner in which we or our service providers treat your Personal Information.
You may contact our Privacy Officer by email compliance@westmountwealth.com or by mail at the following address:
Westmount Wealth Management Inc.
#1900- 650 West Georgia St
Vancouver, B.C. Canada V6B 4N7