Updated on: July 20, 2022
At Orthogonal Capital Management, we need to collect personal information from clients and prospective clients in order to properly fulfill our responsibilities to our clients. Understanding the needs, goals, financial position and family circumstances ensures that all of our investment recommendations are suitable for the client. We are required to collect personal information in order to meet our obligations under securities laws and anti-money laundering regulations. We are committed to protecting Your privacy and the confidentiality of Your personal information in our possession. This policy explains the measures we take to fulfill these commitments.
This Privacy Policy may be updated periodically to reflect changes to our personal information practices. We encourage Clients to refer to the policy regularly. The latest version is available on our website as well as upon request.
WE ASK CLIENTS FOR NO MORE PERSONAL INFORMATION THAN NECESSARY.
The “Know Your Client” information we collect from Clients includes only the information we need to fulfill our contractual, regulatory, and income tax obligations. Some of the information we request will include:
Information to establish the Client’s identity, for example:
- name,
- address,
- date of birth,
- citizenship,
- etc.
Information required to understand one’s financial situation and personal background, for example:
- income,
- investments,
- debts,
- marital status,
- dependents,
- etc.
Information required to comply with our tax reporting obligations, for example:
- Social Insurance Number
- Citizenships
Our account application forms elicit only the information needed, where required, to register these accounts with the government.
We will confirm with Clients that the personal information we have about Clients is accurate from time to time. Most of the information will be collected from Clients directly. We may however, collect additional information from other sources, including, without limitation, credit reporting agencies, other investment dealers or other financial institutions. We do not disclose any non-public personal information to any third party except as required by law or as outlined in this policy.
We do not sell, trade or rent our clients’ personal information.
WE LIMIT ACCESS TO CLIENT’S PERSONAL INFORMATION.
We record clients’ personal information electronically on computer servers to which only authorized persons have access, and only by means of secure passwords. We authorize employees to have access to clients’ personal information only on a “need to know” basis. We have installed hardware and software security to keep our servers clean and secure. We maintain a duplicate copy of our data at an offsite location for disaster recovery purposes. This data is password protected. If we retain paper copies of clients’ personal information, we store it in locked filing cabinets. We keep the computers and filing cabinets in which such information is stored in areas of our business premises locked when not in use.
We retain Client information for no longer than necessary for the purposes set out in this policy or to meet our legal and regulatory requirements.
WE PREVENT UNAUTHORIZED DISCLOSURE OF YOUR PERSONAL INFORMATION.
We train our employees to keep clients’ personal information strictly private and confidential. We require all of our staff to certify that they will follow our policies and procedures which obliges them to respect and protect clients’ personal information. We ensure that departing staff understand they remain contractually obliged to respect the privacy of clients’ personal information. We shred paper documents containing clients’ personal information before discarding such documents.
Client online access to a subset of one’s personal information is available, all of which is password protected.
WE EXPECT SIMILAR SAFEGUARDS FROM OUR SERVICE PROVIDERS.
We may use service providers to provide us with various services such as technology, administration, custody, printing, marketing, legal and accounting. In some cases, our service providers may collect information about Clients on our behalf. We will require them to have a similar privacy policy or to agree to acknowledge and abide by ours.
When Clients open an account with Orthogonal Capital Management, Clients will open an account and sign an account agreement with a custodian. The custodian provides safekeeping of one’s securities as well as trade execution, clearing and other services. We will share personal information with that custodian. The information we share will ensure that we can provide Clients with the services and information that Clients expect from us and that we are required to provide under applicable regulations.
We may disclose certain personal information to third party service providers and to affiliated entities in order to carry out the purposes outlined above (e.g. storage and retention of personal information, etc.). This may include the storage of personal information on servers that may be located outside of Canada such as in the United States, (which means that such information will be available to law enforcement and/or regulatory authorities according to the applicable laws of such foreign jurisdictions). Prior to sharing personal information with a service provider, Orthogonal Capital Management will use diligence to ensure that such recipients safeguard the personal information and use the information only for authorized purposes.
CLIENTS CAN REVIEW WHAT PERSONAL INFORMATION WE HAVE ABOUT CLIENTS.
Clients may obtain access to the personal information we hold about Clients at any time and review its content and accuracy and have it amended as appropriate. We may have to restrict the information we provide as required by law. To request access, Clients should send a written request to Your advisor or to the Chief Compliance Officer of Orthogonal Capital Management.
OUR 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, and 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.
Hotjar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
PRIVACY IS A PARAMOUNT FOR OUR BUSINESS.
Our Chief Compliance Officer is responsible for ensuring that we adhere to our privacy policy. The Chief Compliance Officer is responsible for training our employees in our privacy policies and for monitoring the fulfillment of our privacy commitments. For further information on Privacy at The Firm please reach out to [email protected]
