Privacy policy

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© 2024 Aretec Wealth

Privacy Policy

We take your privacy very seriously.

Here are the details of our policy.

Aretec Wealth Inc. – Canadian Privacy Notice

Last Updated: 10/09/2024

Aretec Wealth Inc. (“Aretec”, “us”, “we” or “our”) has established this privacy policy to comply with applicable federal and/or provincial legislation regarding the collection, use, disclosure and protection of Personal Information (as defined below) of individual investors in prospectus exempt securities or separately managed accounts (collectively “Clients”). We are committed to protecting Personal Information and Aretec employees are responsible for and obligated to always protect such information.

Personal Information

“Personal Information” is defined as information that identifies an individual and includes, but is not limited to, their name, email, address, age, marital status, race/nationality, financial records, religion, or social insurance number.

Clients are requested to notify Aretec as soon as possible of any changes, deletions or corrections to their Personal Information so that Aretec may keep such information up-to-date.

Purposes of Collection, Use and Disclosure of Personal Information and Client Consent

Aretec collects and maintains Personal Information about Clients in connection with the offering and sale
of interests in Aretec offered private investment funds, the opening and operating of managed accounts,
Client communications, or otherwise as required by law. Aretec collects and maintains Personal
Information in order to:

  • Establish, service and administer Client accounts (such as providing tax receipts, transaction confirmations, statements; investment fund financial statements, and other information that may be requested or needed to service these accounts including through our online client portal);
  • Establish the identity of a Client or an authorized individual;
  • Assess a Client’s eligibility in a prospectus exempt fund;
  • Execute transactions;
  • Manage and monitor our website (including the online client portal);
  • To provide you with personalised content and services, such as tailoring our products and services, our digital customer experience, and offerings, and deciding which offers or promotions to show you on our digital channels.
  • To communicate with you in a variety of ways (for example, by email, telephone, text message, direct mail or through our online client portals) about our programs, products, services, special offers, promotions, or events that may be of interest to you. If you no longer wish to receive our commercial electronic messages, please follow the unsubscribe procedure included in each of these messages.
  • File with applicable Canadian regulatory authorities a report setting out a Client’s name, address, telephone number, email address and other information relating to a Client, the class and series of Interests issued, the date of issuance, the purchase price of Interests issued to a Client and other details of the distribution;
  • Protect us and our Clients from error and fraud;
  • Comply with anti-money laundering/anti-terrorist financing and other regulatory requirements; and
  • Establish Aretec’s legal rights or defend against legal claims.

Personal Information collected from a client includes name, address, date of birth, and social insurance number; we typically collects this information from the following sources:

  • Investment management agreements;
  • Subscription agreements submitted by an investor or prospective investor;
  • Transactions with Aretec or any of its affiliates;
  • Communications between Aretec and a Client;
  • Online activity information, such as browser type, Internet service provider (ISP), information about your device and operating system, referring/exit pages, pages viewed on and other information about how you use (or that you otherwise transmit to us) on our sites, including our client portals; and
  • Other information provided.

Personal Information shall not be used or disclosed for purposes other than those for which it was collected. We may disclose Personal Information to third parties and to our affiliates, when necessary and without the consent of a Client, including:

  • financial service providers, such as banks and others used to finance or facilitate transactions by, or the operations of, an Aretec offered fund and/or managed account;
  • other service providers to a fund and/or managed account such as fund administrators, accounting, legal, or tax preparation services; and
  • regulatory, tax or other government authorities and agencies. We will only disclose Personal Information to a governmental entity or other regulatory or self-regulatory organization when required to do so by such laws and regulations, or by court order.

The collection of Client information will be limited to that which is necessary for Aretec to provide services to a Client and for third-party service providers to be able to provide services to us, offered funds and/or managed accounts. Before we may use Personal Information for a purpose not previously identified to a Client, the new purpose shall be identified and consent will be obtained from the Client before the information is used for the new purpose (or the client may opt-out), unless the use is otherwise required by law.

Security Safeguards

Aretec maintains physical, technological, and organizational controls consistent with regulatory standards to safeguard Personal Information in its possession. Reasonable security safeguards have been implemented to help protect Personal Information from loss, misuse, unauthorized access or disclosure. These measures include, but are not limited to:

  • Restricted physical and system access controls;
  • Safeguards to detect and prevent security system failures;
  • Use of secure user authentication protocols for access to records with Personal Information;
  • Use of reasonably up-to-date firewall protection and operating system security patches;
  • Use of reasonably up-to-date versions of system security agent software including malware protection and virus definitions;
  • Reviewing safeguarding controls of service providers who receive Personal Information as part of the provision of our services; and
  • Employee training on our privacy obligations.

Aretec remains responsible for Personal Information it has disclosed to third parties and endeavors to protect this information through contractual agreements. Aretec does not sell or lease Personal Information to third parties nor does it share Personal Information with third parties for their marketing purposes.

Notwithstanding the aforementioned controls, there remains a residual risk of a breach of security safeguards which could result in a real risk of significant harm. See section “Breaches and Risk of Harm” below for Aretec’s reporting and notification procedures to deal with a privacy breach which results in a real risk of significant harm to an individual.

In the event of a sale, transfer, or reorganization of Aretec, we may disclose Personal Information to the acquiring organization, but will require the acquiring organization to agree to protect the privacy of Personal Information in a manner that is consistent with this privacy policy.

Personal Information will be retained for at least seven years following the end of the relationship (unless there are legal requirements that require its retention) after which all documentation will be destroyed in a manner commensurate with its sensitivity.

Website

We may collect certain types of information electronically through an individual’s contact with our website using technologies (either our own, or third-party technologies) such as cookies and web beacons. We may collect your Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages and the pages you viewed on our site.

Cookies

For Aretec to better understand your needs and improve our website by offering a better and more personalised service, remembering your preferences, and generally improving your experience, we collect information such as the number of hits on our site, the pages most frequently accessed and information about access to our secure website. This information is collected by Google Analytics, from which we compile overall statistics in order to improve our site and the services we provide to our clients.

Cookies are small text files that are placed on your computer by websites that you visit. Cookies can be categorised in accordance as set out below:

  • Strictly necessary cookies – these cookies are essential in order to enable you to move around a website and use its features and enable services you have specifically asked for. Consent is not generally required for these cookies.
  • Performance cookies – these collect information about how visitors use a website, for example, by recording which pages users go to most often (usually on an anonymous basis).
  • Functionality cookies – these cookies allow a website to remember the choices a user makes, such as a user name or language preference.
  • Targeting or advertising cookies – these collect information about a user’s browsing habits and are generally placed by advertising networks with the website operator’s permission.

Most browsers are initially set to accept cookies. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit our site. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If you wish to withdraw your consent at any time, you must delete your cookies using your internet browser settings. The “options” or “preferences” options in your internet settings function within your browser should tell you how.

Please consult the following for information or useful advice on managing your cookie settings. For information on how to do this on the browser of your mobile phone please refer to your device manual.

Cookies used by Google Analytics uses are “_gid” and “_ga”:

  • _gid – distinguishes users for 24 hours
  • _ga – distinguishes users on a domain and lasts 2 years

The website only collects cookies for logged in users (website administrators or the domain owner). If at a later date we find that we require the use of any additional plugins that do collect cookies, we will advise you and update this cookie policy accordingly.

Client Access to and Choice Regarding their Personal Information

Aretec’s Chief Compliance Officer has been appointed Chief Privacy Officer (“CPO”). The CPO oversees privacy governance including the development of policies, adherence to procedures, training, and education, reporting to Aretec’s Board, and dispute resolution. Clients may contact Aretec’s Chief Privacy Officer in writing if they wish to:

  • access their Personal Information;
  • correct their Personal Information;
  • withdraw consent to any use and disclosure of their Personal Information (however, this may limit the
    Client’s opportunity to access Aretec’s services or products);
  • obtain more information or have concerns; and
  • file a complaint relating to how Aretec has handled their Personal Information (if a Client is dissatisfied with the results of an investigation of a complaint, they may bring the complaint to the attention of the Office of the Privacy Commissioner of Canada (“OPC”)).

Costs associated with the provision of Personal Information further to a Client’s written request are borne by the Client. Requested information will generally be provided within 30 days of the request being made. Aretec’s Chief Privacy Officer may be contacted at:

Aretec Wealth Inc.
1128 Yonge Street, Suite 300
Toronto, ON M4W2L8
Phone: (416) 637-6423
Email: hello@aretecwealth.com

A Client may change their communication preferences with Aretec (e.g. chose to not receive marketing information), changing their browser settings on their device, or restrict collection, use or disclosure of Personal Information with reasonable notice to Aretec in writing and subject to legal or contractual restrictions.

The disabling of browser setting may restrict the use some of the features of the firm’s websites, or the withdrawal of consent may affect Aretec’s ability to continue to provide a Client with the products and services that they have or would like to receive because the continued use and disclosure of Personal Information is a necessary part of making the product or service available. In some circumstances, legal requirements may prevent a Client from withdrawing consent, such as Aretec’s obligation to report taxable investment income to the local tax authority.

Breaches and Risk of Harm

Aretec is subject to reporting and notification obligations in the event a privacy breach occurs which results in a real risk of significant harm to an individual. A privacy breach is the loss of, unauthorized access to, or disclosure of, Personal Information resulting from a breach of an organization’s security safeguards. A real risk of significant harm includes but is not limited to damage to reputation or relationships, identity theft, humiliation, or financial loss.

In the event of a privacy breach, Aretec will investigate and assess the implications of the breach as soon as feasible. Where Aretec has determined the breach creates a real risk of significant harm to an individual, Aretec will investigate the matter, report to the OPC and notify affected individuals as soon as feasible, and take remedial measures as applicable.

Contact Us

If you have any questions or complaints about how we handle your Personal Information, please contact us as indicated below:

Attn: Chief Privacy Officer
300- 1128 Yonge Street
Toronto, ON M4W2L8
Email: hello@aretecwealth.com
Phone: (416) 637-6423