Introduction

At Aldermonte Vestaria, we understand that your financial information deserves the highest level of protection. This privacy policy explains how we collect, use, and safeguard your personal data when you interact with our family investing services. We're committed to transparency about our practices and ensuring you maintain control over your information.

Our approach to privacy reflects Canadian values and complies with federal and provincial privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA). We believe that clear communication about data practices builds the trust essential for successful long-term financial relationships.

Information We Collect

Personal and Financial Information

When you work with our family investing services, we collect information necessary to provide personalized financial guidance and comply with regulatory requirements. This includes your name, contact details, employment information, income details, investment objectives, and risk tolerance.

Website and Digital Interactions

Our website collects standard technical information including IP addresses, browser types, and page visit patterns. We use this data to improve our digital services and understand how families interact with our educational resources. We also track which investment topics generate the most interest to better serve our community.

How We Use Your Information

Your information serves several important purposes in our family investing practice. We use personal and financial data to develop customized investment strategies that align with your family's long-term goals and risk tolerance. This includes ongoing portfolio monitoring and periodic strategy adjustments.

• Creating personalized investment recommendations based on your family's financial situation
• Monitoring portfolio performance and making strategic adjustments when appropriate
• Providing regular account statements and performance reports
• Ensuring compliance with Canadian securities regulations and tax reporting requirements
• Communicating important market updates and investment opportunities
• Improving our services through analysis of client preferences and outcomes

Information Sharing and Disclosure

We maintain strict controls over information sharing, recognizing that financial privacy is fundamental to client relationships. Information sharing occurs only in specific circumstances necessary for service delivery or regulatory compliance.

Authorized Service Providers

We work with carefully selected partners to deliver comprehensive family investing services. These include custodial firms that hold client assets, compliance monitoring services, and secure document storage providers. All partners sign comprehensive data protection agreements and undergo regular security assessments.

Regulatory Requirements

Canadian securities regulators may require access to client information during examinations or investigations. We also provide necessary information to tax authorities as required by law. In all cases, we limit disclosure to the minimum information required and notify clients when legally permitted.

We do not sell client information to third parties or share data with companies seeking to market their services to our clients. Your relationship with Aldermonte Vestaria remains confidential and protected.

Your Privacy Rights

Under Canadian privacy law, you maintain significant control over your personal information. We've designed our processes to make exercising these rights straightforward and responsive to your needs.

Exercising Your Rights

To exercise any privacy rights, contact our privacy officer directly using the information provided at the end of this policy. We respond to most requests within 30 days and provide clear explanations if any limitations apply to your request.

You also have the right to file a complaint with the Privacy Commissioner of Canada if you believe we've handled your information inappropriately. We encourage clients to contact us first, as we're committed to resolving privacy concerns quickly and transparently.

Data Security and Protection

Protecting client information requires multiple layers of security, from technical safeguards to employee training and regular system audits. Our security measures meet or exceed industry standards for financial services firms.

Technical Safeguards

All client data is encrypted both in transit and at rest using bank-level encryption standards. Our systems undergo regular vulnerability testing and security updates. Access to client information is restricted to authorized personnel who require the data for their specific job functions.

Physical Security

Our Markham office maintains secure access controls, surveillance systems, and locked storage for any physical documents. Employees receive regular training on privacy protection and data handling procedures. We maintain detailed logs of all access to client information systems.

In the unlikely event of a data security incident, we have established procedures for immediate response, client notification, and regulatory reporting as required by law.

Data Retention and Deletion

We retain client information for specific periods based on regulatory requirements and business needs. Most client records are maintained for seven years after account closure, which aligns with Canadian securities law requirements.

Active client information is reviewed annually to ensure accuracy and relevance. When retention periods expire, we securely delete or destroy information using methods that prevent unauthorized recovery. Clients may request earlier deletion of certain information types where legally permissible.

Account Closure Process

When you close your account with Aldermonte Vestaria, we begin the retention countdown immediately. You'll receive confirmation of account closure and information about how long specific data types will be retained. Essential transaction records remain accessible during the retention period for tax or regulatory purposes.

International Data Transfers

While we primarily store and process client information within Canada, some service providers may store backup data in secure facilities outside the country. When this occurs, we ensure these providers meet Canadian privacy standards and provide equivalent protection for your information.

Any international transfers comply with PIPEDA requirements and include contractual protections that maintain your privacy rights. We can provide specific details about data storage locations upon request.

Website Privacy and Cookies

Our website uses essential cookies to provide secure access to client portals and remember your preferences during visits. We don't use tracking cookies for advertising purposes or share website usage data with third-party marketing companies.

You can control cookie settings through your browser preferences. Disabling certain cookies may limit website functionality, particularly access to secure client areas. We provide clear information about cookie types and purposes through our website's cookie notice.

Updates to This Policy

We review and update this privacy policy annually or when significant changes occur in our data practices or regulatory requirements. Material changes are communicated to clients through direct mail or email, with at least 30 days notice before implementation.

Minor updates, such as contact information changes or clarifications of existing practices, are posted to our website with updated effective dates. We maintain previous versions of our privacy policy for reference and comparison.