While we do our best to ask our clients for no more personal information than necessary, we are required to collect specific personal information from our clients in order to provide our services and fulfil our legal/regulatory obligations. In general, we collect information for the following primary purposes:
- To fulfil our fiduciary obligations as a Portfolio Manager;
- To verify your identity in accordance with applicable Anti-Money Laundering (“AML”) and Securities legislation;
- To be able to open and service your account;
- To be able to facilitate electronic fund transfers to and from your account or from other brokerage institutions;
- To detect and prevent fraud and other unauthorized or illegal activities;
- To meet legal and regulatory requirements;
- To fulfil tax reporting obligations
Personal and Financial Information Collection
We collect information about your financial and personal circumstances when you open an account with us to ensure our investment recommendations are appropriate for you. We also collect information from you such as your name, address, date of birth, occupation, and may collect additional information from consumer reporting agencies to verify your identify in accordance with local AML regulatory requirements. We may also collect your Social Insurance Number (SIN) for income tax reporting purposes or for registering specific account types with the government.
For registered accounts, we may be required to collect information about any beneficiaries that you choose to designate to your accounts such as your designated beneficiary’s name and date of birth.
Other Collection and Use of Personal Information
Affiliate Program: If you participate in our affiliate program, we collect the email address of the individual(s) who you wish to refer to Nest Wealth. We use this information to send the recipient information about the referral program.
Marketing Communications: From time to time, we may obtain your consent to send you emails and other communications about products and services that may be of interest to you. You can unsubscribe from these communications at any time by emailing firstname.lastname@example.org or by using the unsubscribe mechanisms provided in these communications. Please note unsubscribing will not unsubscribe you from account or transactional documents which are delivered to you for non-marketing purposes.
Relationship Manager: If you contact our Relationship Managers, you may be asked for information that identifies you or information that we need to accurately investigate your questions or requests. We may retain this information to assist you in the future and/or to fulfil applicable recordkeeping requirements around client communications.
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.
Service Providers: We may transfer your personal information to third party service providers who provide services on our behalf such as identity verification needed to service your accounts. Companies we hire to provide support services are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of your personal information to the performance of the specific service we have requested.
Business Transactions: We may transfer any information we have about you as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding).
Securities Regulations: We and/or our custodian may share your name, contact information and holdings with issuers of securities that you hold in your account and other persons/companies as required in accordance with securities law. Such issuers may require your personal information in order to deliver financial reports, tax documents and other relevant materials to you or to comply with applicable regulatory obligations.
We may disclose or report personal information in limited circumstances where we believe in good faith that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulators or law enforcement authorities.
Online Media: When you engage with our content on or through third-party media such as Google and social networking sites, you may allow us to have access to certain information associated with you (e.g., name, username, email address, profile picture, handle, etc.). We may use this information to deliver personalized advertisements/content online. We may also use social media sites to collect information about you with your consent to deliver educational content such as e-books.
Controls & Security
We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords, keys, and one-time-use tokens. We authorize employees and service providers to have access to clients’ personal information only on a “need to know” basis in order to fulfill their job requirements.
We also use bank-level security measures to ensure your data is collected and stored safely. We encrypt all communication between your browser and our servers, store all of your data on secure servers, and continuously test our processes and procedures to ensure your data is secure and safe.
We train our employees to keep clients’ personal information strictly private and confidential and oblige all staff to protect clients’ personal information.
Your online access to certain of your personal information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
Restriction on Disclosure of Personal Information
You have the right to access and update your personal information under our custody subject to certain exceptions prescribed by law. You may update certain profile information you have provided to us by logging in to your account or by contacting us. We may, at our discretion, request certain personal information for the purposes of verifying your identity prior to disclosing or discussing your personal details.
Third Party Website Links
Who can I contact if I have questions about Privacy?
*FCC is an indirect, wholly-owned subsidiary of 483 Bay Street Holdings LP, which is a joint venture between FIL Limited and Fidelity Canada Investors LLC. FCC and two other separate related legal entities that are also Canadian securities registrants – Fidelity Investments Canada ULC and Fidelity (Canada) Asset Management ULC – conduct business under the “Fidelity Investments” brand, which is a trademark of Fidelity Investments Canada ULC and a registered business name of FCC. However, each Canadian securities registrant operates and conducts its business independently of each other.
Fidelity Clearing Canada ULC is a member of the Investment Industry Regulatory Organization of Canada (IIROC) and the Canadian Investor Protection Fund (CIPF).