Privacy Policy
Updated September 12, 2023
Nest Wealth is committed to protecting the privacy and confidentiality of personal information in our possession and control.
This Privacy Policy explains the measures we take to fulfill these commitments and describes the manner in which we collect, use, disclose and treat personal information through our website and platform.
This Privacy Policy applies to Nest Wealth Asset Management Inc. (NWAM) and Nest Wealth Solutions Inc. (NWS). The foregoing entities are collectively referred to as “Nest Wealth”, “we”, or “us”.
NWAM is a registered Portfolio Manager which provides discretionary portfolio management services to Canadian investors in the jurisdictions where it operates. NWS is a provider of enterprise digital wealth management technology which is utilized by advisory firms in North America.
Nest Wealth is committed to protecting the personal information of its customers and personnel and this policy discloses how personal information is used by our organization. We also:
- Limit personal information we collect to what is required and only use it for those purposes;
- Only use personal information for the purposes it was obtained and obtain consent before using it for another purpose;
- Ensure that service providers and contractors that have access to personal information are bound to protect the information and not use it for any unauthorized purposes;
- Train our employees to ensure that personal information is handled appropriately and that employees understand their obligations.
“Personal Information” is any information about an identifiable individual. It may include information such as name, age, date of birth, home address, social insurance number, marital status, income, account number, client identification number, personal email address and messages, and Internet Protocol (IP) address and other indicators.
Personal Information does not include business contact information of an individual which is collected, used, or disclosed solely for the purposes of communicating or facilitates communication with the individual in relation to their employment, business, or profession.
Personal Information also doesn’t include any information that is aggregated or anonymized.
What Personal Information Do We Collect?
Our wealth management services, platform and websites, collect and use several types of essential and required information, except where indicated below, in connection with the services that we provide. Each category of personal information collected and the specific purposes for this collection and use is outlined below.
| Personal Information Collected | Usage / Purpose |
| Personal identity information (name, address, contact information, date of birth, occupation, identification documents) |
We collect this information to:
|
| Financial and Banking Information (assets, liabilities, income, expenses, void cheques, bank account information, transactional history, account types and balances or limits, names of financial institutions, and related financial information that we collect from you or your financial institution.) |
In order to use our discretionary portfolio management services, we have a legal obligation to understand your financial circumstances in order to provide investment advice. We also require banking information to allow you to fund your account and to send money to your bank account. As an employee of Nest Wealth, we collect banking information to facilitate payment of your services and for administration of benefits programs on your behalf. |
| Beneficiary Information |
If you sign up for a registered retirement account, we may ask you to provide certain beneficiary information such as your spouse’s name and occupation, children’s or dependents’ names, and ages that we collect from you on your application forms. If you provide information about a minor, you must be designated as a person with parental authority of the minor in order to provide consent to share their personal information on their behalf. |
| Investor profile questionnaires | This may include asset holdings and values, and investment knowledge and objectives that you provide in risk information forms we ask you to complete. |
| Tax Information (Social Insurance Number) | We require SIN for certain types of account / tax reporting and will share it with the appropriate government agencies. We may also share it with identification services to identify you in accordance with local anti-money laundering laws and regulations. |
| Information about your transactions with us and communications with us | We retain information about your interactions with our customer service and advisory teams in accordance with local securities requirements. |
| Infrastructure, network and account/platform log data | Our network, infrastructure and account/platform logs may contain your personal information such as your email address and IP (Internet Protocol) addresses. This log data is used for security monitoring and to provide a verifiable trail of transactions and activity occurring on our systems. |
| Platform and Website Usage | Website visitors do not have to indicate who they are or submit any personal information. However, as you browse the website and use our platform, certain information relating to your browsing patterns, logins and technical data about the equipment you are using to access the website is automatically collected using cookies, server logs and other similar technologies. Please see our Cookie Policy for further information. We use this information to help us understand activity, enable essential functions on our platform and the website, and to monitor and improve the security and functionality of our platform and the website. |
| Analytics | We may use third parties, including Google Analytics and Mixpanel, to help us gather and analyze information about website and platform usage. We use this information to better understand, evaluate and improve the user experience and the convenience of our Website and services. We may also de-identify your information by removing personal identifiers such as name, address and account numbers for the purposes of analytics and reporting to help us identify trends and insights to improve our services. |
| Fraud Prevention | We may use your personal information to help protect you and us against fraud and error. This includes for purposes of preventing, detecting, or suppressing financial abuse, fraud, or criminal activity. This may include working with external agencies / regulatory bodies to investigate and resolve potential cases/allegations of fraud. |
Collection of Personal Information
The Personal Information we have about you may be collected directly from you (or anyone authorized by you to act on your behalf under a power of attorney or other legal authority), and from sources within or outside of our organization including:
- our interactions with you (including telephone and emails);
- data entered by you on our wealth management platform;
- data provided from our service providers in connection with your use of our services;
- your usage activity on our platform and websites;
- your financial planner or other professional advisor such as accountant/lawyer;
- government bodies, agencies, and registries;
- regulatory bodies;
- law enforcement authorities;
- public records;
- job boards;
- credit reporting agencies
We do not sell your personal information.
Your personal information will not be used, disclosed or retained for purposes other than those for which the information was collected, except with the permission of the individual, or as permitted or required by law.
Consent
When you provide your personal information through our website, Nest Wealth platform and external sources as noted above, you are consenting, acknowledging and agreeing to the collection and use of your personal information for the purposes as described above. If you do not provide the essential information, Nest Wealth will not be able to provide these services.
Withdrawal of Consent
You can refuse to consent to our collection, use or disclosure of personal information, or you may withdraw your consent to our further collection, use or disclosure of your personal information at any time by giving us reasonable notice, subject to limited exceptions. If you wish to withdraw consent, you may do so at any time by contacting our client support team at support@nestwealth.com
Depending on the circumstances, your withdrawal of consent may prevent us from providing you, or continuing to provide you, with some products and services, the ability to access certain products and services, or information that may be of value to you.
In addition, we may have legal, regulatory or contractual obligations to collect, use or disclose certain of your personal information, in which case you may not withdraw your consent.
You also cannot refuse to consent to our collection, use and disclosure of personal information required by our regulators.
We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately.
Retention Periods For Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Automated Decision Making and Profiling
We may use automated decision making systems to process your personal information and we may rely on decisions made or profiles provided by these automated systems for AML verification or security purposes (i.e. identifying your identity or fraud detection / prevention purposes). Upon request, Nest Wealth will provide you with information on the functioning of the automated decision making system and processes.
Keeping Your Data Safe
The security, integrity and confidentiality of your Personal Information is important to us. Nest Wealth maintains a comprehensive information security program that meets generally accepted industry standards. Our program includes appropriate administrative, technical, and physical safeguards, procedures, and practices to protect personal information submitted to us, both during transmission and once we receive it. When you enter information in our systems, we encrypt the transmission of that information using secure socket layer technology (SSL). We restrict access to personal information to employees and authorized service providers who require access to fulfill their job requirements.
Disclosure of Personal Information
In order to provide you with our products and services, we may need to share your Personal Information with other parties who are under an obligation to protect the confidentiality of that information. The shared information will be limited to such information which is necessary to facilitate the arrangement.
Your Personal Information may be disclosed:
- in accordance with any applicable consent obtained from you;
- as part of a business transaction that we are considering or involved in (including the purchase of a business or the sale of part of all of our business);
- to respond to a court order, search warrant, or any other valid demand or request;
- to satisfy any applicable legal or regulatory requirement;
- to suppliers, service providers, agents or other organizations that perform services for you, for us or on our behalf;
- to any authorized individual with legal authority including Power of Attorney;
- to Nest Wealth personnel who have a legitimate business purpose for using it;
- where otherwise permitted by law.
Disclosures Between Provinces and Outside of Canada
The suppliers, service providers, and other organizations we may use could be located outside of your province of residence and Canada. Consequently, you should expect that your Personal Information may be collected, accessed, used, disclosed, and stored outside of your province and outside of Canada. In such cases, your Personal Information may be accessible or disclosed to or accessed by law enforcement, regulators, or authorities in the jurisdiction(s) where the Personal Information is being accessed, used, disclosed or stored.
If your personal information is transferred to a service provider outside of your home province or country, we will take measures to protect your personal information with appropriate contract clauses or other applicable safeguards.
Disclosures to Affiliates
Nest Wealth Solutions Inc. provides the digital platform that is offered to customers of Nest Wealth Asset Management Inc. Consequently, information about NWAM customers provided through the platform is shared with Nest Wealth Solutions Inc.
If your personal information is transferred to a service provider outside of your home province or country, we will take measures to protect your personal information with appropriate contract clauses or other applicable safeguards.
Disclosures Between Provinces and Outside of Canada
The suppliers, service providers, and other organizations we may use could be located outside of your province of residence and Canada. Consequently, you should expect that your Personal Information may be collected, accessed, used, disclosed, and stored outside of your province and outside of Canada. In such cases, your Personal Information may be accessible or disclosed to or accessed by law enforcement, regulators, or authorities in the jurisdiction(s) where the Personal Information is being accessed, used, disclosed or stored.
If your personal information is transferred to a service provider outside of your home province or country, we will take measures to protect your personal information with appropriate contract clauses or other applicable safeguards.
Disclosures to Critical Service Providers
Platform Infrastructure: We utilize reputable Infrastructure as a Service (IaaS) providers for hosting our core digital wealth platform and supporting databases, utilities and services, as well as services of other third party providers for database services, network and systems monitoring and support, security administration and software development and release services.
Custodians: When you open an account with Nest Wealth, you will also be required to open a brokerage account with National Bank Independent Network (NBIN) or Fidelity Clearing Corporation (FCC) – these are custodians that we use to provide trade execution, clearing and other services on our behalf. We must also notify them of any updates or changes to your account information. When you open an account, you will receive more information about these custodians in your account opening package.
Identity Verification: We may share your information with credit reporting agencies (Equifax / Transunion) for the purposes of client identification.
Portfolio Management: We utilize a third party service provider for customer portfolio rebalancing and day-to-day trade executions.
Client Services: We utilize client relationship management (CRM) software providers to facilitate customer communications and day-to-day customer support operations. We may also utilize other tools to facilitate video calls or telephone calls with our customers.
Electronic Signature Providers: Our platform includes integrations with electronic digital signature providers required to complete things like account application digitally and other documentation that may be required to open an account with us.
Disclosing Your SIN: Your SIN may be shared with third parties for income tax reporting purposes, as required by law. In addition, depending on the product or service you have with us, we may be required by law to verify the identity of all clients, account beneficiaries, and power of attorneys.
Accessing and Correcting Your Personal Information
Depending on the product or service you have with us, you may be able to access your Personal Information online directly through your Nest Wealth client portal.
In addition, upon written request, we will provide you with details regarding your Personal Information including what information we have about you, and how it has been used and disclosed. Please note that there may be instances where access may be restricted as permitted or required by law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations.
You have the right to request the correction of your Personal Information. If you identify any inaccuracy in your Personal Information, or you need to make a change to that information, please contact us immediately at support@nestwealth.com so that we can update our records.
If you wish to access, correct, or withdraw consent to the use of your Personal Information, you can contact our client support team at support@nestwealth.com or email our privacy team at privacy@nestwealth.com
Updates to Our Privacy Policy
We will post any changes we make to our Privacy Policy on this page. We will include the date the Privacy Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our website and this Privacy Policy specifically to check for any changes.
Contact Us
If you have any questions or concerns about this policy or privacy and confidentiality matters, please contact our Chief Compliance Officer at privacy@nestwealth.com
If, after contacting Nest Wealth, you feel your Personal Information concerns have not been adequately addressed, you may contact the Office of the Privacy Commissioner of Canada – https://www.priv.gc.ca/en/report-a-concern/
In Quebec, the organization responsible for protecting privacy is the Commission d’accès à l’information du Québec – https://www.cai.gouv.qc.ca/