The Privacy Policy (“Policy”) provides important information on the collection, use, and disclosure of personal information. The terms “OFIC”, “we”, “our” or “us” refers to OceanFront Investment Counsel Inc. and its employees and agents. The term “Client”, “you”, or “your”, refers to you as the Account Holder, and if applicable, anyone who is an authorized individual on the Account. An Account Holder also includes authorized individuals for non-individual entities such as corporations or trusts. The term “Personal Information” refers to any identifiable information, whether directly or indirectly, and includes information like your name, date of birth, social insurance number, employment and financial information, online account password, and contact information such as a phone number, mailing address, and/or email address.
Your personal privacy is important to us and as part of our commitment to safeguard information about you that you have entrusted to us, we share the following details with you so that you understand how your Personal Information is collected, used, and disclosed. Furthermore, we believe in transparency and accountability, and we encourage you to review our Policy regularly to stay informed about any updates or changes.
Collecting and Using Personal Information
We collect and use Personal Information for the opening of Accounts, which enables us to act on your behalf to execute trades and perform transactions in the Account. The Personal Information also allows us to provide the necessary reporting to comply with Canada Revenue Agency’s (“CRA”) requirements and fulfill our regulatory obligations. For more information, refer to the Suitability and Know Your Client (“KYC”) section in the Relationship Disclosure Information.
We may record videos during client meetings, or telephone calls for record keeping purposes or for other purposes we may deem reasonable to fulfill legal or regulatory requirements or improve client service. These recordings may capture Personal Information including images, voice, and other identifiable data. You will be informed about the recording in advance and will have the opportunity to object to it before the recording takes place unless the recording is a legal requirement.
Your Consent
We obtain your consent to the collection, use, and disclosure of your Personal Information through the act of providing us with the information. Implied consent may also be obtained through actions such as using our services or inactions such as failing to opt out when given the opportunity. If you decline to provide your Personal Information, you may be ineligible to access or receive certain products and services.
Service Providers
Your Personal Information may be shared with our third-party service providers to manage products and services on our behalf relating to the operation of your Account. We may also use credit bureaus and other third-party software solutions to meet our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (“PCMLTFA”) for identity verification. We may also share your Personal Information with other parties like your accountant or other financial institutions if we have your permission to do so.
We take reasonable steps with third-party service providers, with whom we share your Personal Information, to ensure that they use it solely to fulfill the services contracted with them. These service providers are not permitted to use your information for their own purposes.
At times, we may use third-party service providers outside of Canada, including the U.S.A., that require cross-border or international data transfer. When transferring Personal Information outside of Canada, we ensure that service providers adhere to contractual obligations that align with Canadian privacy standards. While the data is subject to the laws of the jurisdiction where it is stored, we take reasonable steps to protect its confidentiality and integrity.
Affiliates
With your consent, we may share your Personal Information with other related affiliates and their employees or agents to facilitate access to products and services such as financial planning, insurance, and other financial services.
Marketing Materials
We will send you marketing materials, including the promotion of 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 electronic marketing materials at any time by clicking the unsubscribe link included in the marketing campaign or by contacting our office. Please note that utilizing the unsubscribe feature does not prevent you from receiving essential account-related communications, such as statements or regulatory updates.
Legal/Regulatory Requests
Your Personal Information may be disclosed in response to a regulatory inquiry, audit or investigation, or a legally valid request, which may include lawful inquiries from authorities, inside or outside your home jurisdiction. Personal Information may be disclosed when necessary for the initiation, execution, or defence of a legal claim, as well as to investigate or prevent actual or suspected harm or loss.
We may also share your name, contact information, and holdings with issuers of securities that you hold in your Account and other individuals/companies as required by securities law, for the purpose of sending you financial reports, tax documents, and other relevant materials.
Furthermore, we may disclose Personal Information in limited circumstances where we believe, in good faith, that the disclosure is required, permitted under the law, or advisable to protect our interests.
Electronic Transmission
Unless otherwise agreed, we will use the Internet, including email, to provide you with applicable account information including documentation, statements, and reporting. Because of the inherent risks associated with the electronic transmission of information over the Internet or otherwise, we do not guarantee the security and integrity of any electronic communications sent or received. While it is our policy to check our emails with anti-virus software and other security software, we do not guarantee that transmissions will be free from malware or other security vulnerabilities. We do not accept responsibility or liability for any damages as a result of communicating over the Internet or other electronic means. OFIC does not accept any responsibility or liability for any damages that result from you sending us sensitive or confidential information.
Website Use
We utilize cookies and other automated methods to gather specific details about visitors to our website, including the number of users and the most frequently viewed web pages. This information enables us to optimize our website and tailor our messaging to better suit our visitors. The data collection is facilitated through various means, such as cookies, web beacons, and similar technologies. Additionally, we may use Google Analytics to track website performance and collect visitor insights. You may choose to disable cookies or opt out of Google Analytics tracking by adjusting your browser settings or using available browser plugins. For more information, please visit our website’s privacy settings page.
Our website may contain links to third-party websites, which are provided solely for your convenience. When you click the link, you leave our website and will be redirected to another site for which we are not responsible. OFIC does not accept any liability for the collection, use, and disclosure practices of Personal Information by third parties.
Safeguards to Protect Information
We maintain reasonable security procedures and standards to prevent unauthorized access to confidential information. We provide training to our employees about the importance of confidentiality and privacy. Personal Information in our possession is kept in our office, on encrypted cloud-based storage, and in secure offsite storage facilities.
Your online access to the account portal is protected with a password of your choosing. 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.
Data Breach Notification
In the event of a data breach involving your Personal Information, we will notify affected individuals as required by law. Notifications will include the nature of the breach, the potential impact, and steps being taken to address the situation.
Keeping Your Information Current
Assist us in ensuring the accuracy of your information by promptly informing us of any changes to your Personal Information. If you discover any inaccuracies in the Personal Information we have on record, please let us know and we will make the necessary corrections. In cases where an ongoing dispute exists regarding your Personal Information, your change request will be duly noted.
Access to your Personal Information
We will provide you with general access to your Personal Information as required by law. To request access, please submit your inquiry in writing. Any applicable fees will be communicated in advance, and a response to your inquiry will be provided within 30 days of receiving the request. Please note that in some situations, we may not be able to provide you with your Personal Information from our records, as it may contain reference to other persons, is subject to legal privilege, or contains proprietary information.
Dispute Resolution
If you believe that your request for access to Personal Information has been unjustly denied, or if you have concerns about the accuracy or completeness of your records, you may escalate your concern by contacting our Privacy Officer at compliance@oceanfrontwealth.com. The Privacy Officer will review your concern and provide a written response within 30 days. If you remain dissatisfied, you may contact the Office of the Privacy Commissioner of Canada (“OPC”) to file a formal complaint.
Retention of Personal Information
We retain Personal Information only for the duration necessary to fulfill the original purpose of its collection, in compliance with regulatory or legal requirements. If there is a dispute or legal obligation, records may be retained for a longer period to address or resolve the matter.
Changes to the Policy
We will provide you with this document when you open your Account. The Policy undergoes regular revisions to keep current with regulatory or industry changes. We retain the right to change this Policy at any time, and any changes will take effect upon disclosure to you.
Contact Information
Should you have any questions or concerns regarding your privacy, or the information outlined in this policy, please reach out to our office using the contact information listed above. Alternatively, you can email the Privacy Officer at compliance@oceanfrontwealth.com.
