Privacy Policy — New North Advisory

New North Advisory Ltd. (“New North”) and its wholly owned subsidiary [∙] (“[∙]” and together with New North, the “Company”, “we”, “us”, “our”) respect your privacy and are committed to protecting your personal information by complying with this policy (the “Privacy Policy”). This Privacy Policy outlines the Company’s policies and practices regarding app and website users’ (“Customers” or “you”) personal information. This Privacy Policy will continue to apply for as long as we hold your personal information, including after the termination of any of your services with us. Please read this Privacy Policy carefully to understand the Company’s policies and practices for collecting, processing and storing your personal information. By providing the Company with your personal information, you are consenting to the collection, use and sharing of your personal information as set forth in this Privacy Policy.

For the purposes of this Privacy Policy, “personal information” is defined as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

We may update this Privacy Policy periodically to reflect changes to our personal information policies and practices. We strongly encourage you to refer to this Privacy Policy often for the latest information about our personal information policies and practices. Your continued use of the Company’s app or website after we make changes indicates that you accept and consent to those changes. We will notify you in advance of any material changes to this Privacy Policy.

Personal Information: How and What We Collect

The Company requires certain personal information to assist us in assessing your financial needs, ensuring proper details for communication and account administration, and allowing us to fulfill our legal and regulatory obligations.

The information that we may request may include, but is not limited to, the following: name, mobile phone number, address, email address, Social Insurance Number (SIN), date of birth, spousal information, financial information, investing preferences, employment information, banking information, or other information relevant to the services that we provide.

We collect personal information about you through:

direct interactions with you when you provide personal information to the Company, for example, by completing forms or information requests through the Company’s app or website;
automated technologies or interactions, when you use the app, for example, usage details, internet protocol (IP) addresses and information collected through cookies;
formal or informal conversations, for example, through email exchanges and referrals; or
information provided by third parties.

In general, you can visit our website without indicating who you are or submitting any personal information. However, we may collect and log the IP addresses of all visitors to our website and other related information such as page requests, browser type, operating systems and average time spent on the app or website. Further, when you sign up to use our services, we may also collect personal information about our SMS or email campaigns and your interactions with them. For example, we may store information regarding what SMS messages are sent to you and whether you respond to them or interact with them. We use this information to help us improve the Company’s services.

Non-Personal Information: How and What We Collect

The Company uses cookies and other similar technologies to collect non-personal information. Cookies are small files that apps and websites place on your smartphone or computer as you browse the app or website. Like many companies, we use cookies to discover how Customers are using our services and to enable us to provide Customers with a better and more personalized experience.

We may use third parties, such as Google Analytics, to collect non-personal information about the areas visited on our website and obtain user metrics when you use our online or in-app services.

Protection of Personal Information

We are committed to protecting your personal information. The Company will not use Customers’ personal information for purposes other than for which it was collected. Access to Customers’ personal information will be restricted to those authorized employees who need to have access to that information for the purposes of meeting their employment obligations.

Any personal information collected by the Company in physical form will be kept behind a locked door or within a locked cabinet and personal information collected in digital or electronic form will be kept behind a password-protected computer system or will be otherwise secured. Any personal information that we store is encrypted using the highest security standards and is retained for no longer than necessary for the purposes set forth in this Privacy Policy or to otherwise meet legal requirements. Notwithstanding the foregoing, SMS messages may not be encrypted. Accordingly, your continued use of the Company’s app and/or website constitutes an acknowledgement that such SMS communications and receipt thereof involves certain security risks which you are knowingly undertaking.

The Company will share only the personal information which is reasonably required in the normal course of business with third parties such as our custodians, securities regulators, auditors, legal counsel, or law enforcement agencies, each of whom are bound by similar privacy policy standards. For example, when you sign up for our paid subscription plan through the Company’s app, some of your personal information (i.e., your phone number and email address) may be shared with our custodian (currently, Interactive Brokers). We will not sell, rent or lease your personal information.

How We Use Your Personal Information: General

The purposes for which we use the personal information collected includes but are not limited to:

providing you with the app and its content;
providing you with information and services that you may request;
tailoring the app and website experience;
fulfilling the purposes for which you provided the personal information or that were described to you when such personal information was collected;
better understanding your financial needs and delivering the services that best meet those needs;
helping us choose the portfolio that best fits you and your needs;
verifying your identity and other information you provided to us;
helping us manage and assess the Company’s risks and operations;
detecting, preventing and suppressing errors, fraud, financial abuse and other unauthorised or illegal activities; and
meeting the Company’s legal and regulatory requirements.

How We Use Your Personal Information: SMS and Email Notifications

When you use the Company’s services we collect your full name, mobile phone number, email address and your SMS/email opt-in or consent status.

We use your mobile phone number and/or email address to send communications related to:

verifying your identity and other information you provide to us through an authentication code sent to your mobile phone number;
notifying you of your appointments, finances and goals (the “Non-essential Notifications”); and
providing you with general updates or bulletins from the Company.

We will not use your mobile phone number and/or email address for any purposes other than those for which you have provided consent.

If at any time you wish to stop receiving SMS messages and notifications from us, you can withdraw your consent to our use of your mobile phone number for Non-essential Notifications by switching off your SMS notifications for this purpose within your account profile settings or replying “STOP” to any SMS message received from us. If at any time you wish to stop receiving email notifications from us, you can withdraw your consent to our use of your email address for Non-essential Notifications by switching off your email notifications for this purpose within your account profile settings.

Standard message and data rates may apply for SMS communications, depending on your mobile carrier and plan. Email communications may involve standard data usage. By continuing to opt in for such communications from the Company, you acknowledge that you are solely responsible for any fees charged by your carrier.

How we use your Personal Information: Collaboration Feature

When you enrol in our paid subscription you will gain access to our collaboration feature which enables you to invite other subscribers on the Company’s Platforms (the “Collaborators”) to view and engage with elements of your account including but not limited to your name, mobile phone number, email address, market values, financial values and account details (the “Collaboration Feature”). When you use the Company’s Collaboration Feature you acknowledge and consent to the Company sharing your personal information with the Collaborators.

You may revoke a Collaborator’s access to your account on our Platforms at any time by [removing the Collaborator from the invited subscribers list in the Collaboration Feature. If at any time you wish to stop using the Collaboration Feature in its entirety, you may withdraw your consent to use the Collaboration Feature by switching off the Collaboration Feature within your account on our Platforms.]

Accessing Your Personal Information

You may request to access your personal information that the Company maintains by contacting our Chief [Compliance] Officer in writing. Except as otherwise noted in this Privacy Policy, we will not disclose any personal information to a third party without your prior written consent.

If you have any questions regarding the Company’s Privacy Policy, please direct your enquiry to the attention of the Chief [Compliance] Officer by any of the following methods:

Phone: [∙]

E-mail: [hello@findyournorth.ca]

Mail: [∙]

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