Privacy Policy

Introduction

PearTree Financial Services Ltd. and its wholly owned subsidiary, PearTree Securities Inc. (collectively “PearTree”) are committed to protecting the privacy and confidentiality of the personal information of people with whom we do business in compliance with applicable privacy legislation. PearTree has created this Privacy Policy in order to establish rules which govern the collection, use, maintenance, protection and disclosure of personal information.

Collection & Use of Personal Information

PearTree will only collect personal information if and to the extent required for the purposes identified below or as otherwise required or permitted by privacy legislation. “Personal information” refers to any information about you (or other identifiable people) including information that may specifically identify you or them. The personal information we collect may include your name, address, telephone number, social insurance number, birth date, occupation, spousal information, employment information, information related to your financial institution(s) and your estimated family income and net worth. During the course of providing services to you, other types of information such as tax records and other documentation necessary to support claims or requests for various types of payments and benefits may be collected. Information may also include identification, such as a valid driver’s license or passport.

PearTree presently collects personal information for each client for the following purposes:

To comply with “Know Your Client” and anti-money laundering documentation requirements, including the collection, use and disclosure of such information (e.g. to regulatory authorities or authorized persons);
to prepare client reporting such as trade confirmations, tax slips, account statements, etc.;
to assess a client’s eligibility to invest in accordance with identified trade exemptions;
to assess the suitability of investments by a client;
to share personal information with third parties such as legal advisors or accountants in order to co-ordinate the purchase or sale of securities;
to maintain records to meet contractual or regulatory obligations;
to report to regulatory authorities, or government agencies as needed to comply with applicable statutory and regulatory requirements; and/or
for any other purpose related to the products and services of PearTree to which clients may consent.

This information comes either directly from you, or from your advisers, dealers or agents. Information may also be shared with us by other parties to a transaction, or their advisors, dealers or agents.

Pursuant to rules and regulations issued by FINTRAC or other regulatory authorities or governmental agencies, PearTree may, for the purpose of identifying you or performing other compliance screening, verify information you provide us by referring to an independent and reliable identification product held at a credit reporting agency. Specifically, PearTree may utilize due diligence screening service providers such as CanChek for compliance screening, and Equifax Canada Co’s identification solutions to confirm your identity if you are not physically present to open your account.

Finally, PearTree collects and uses personal information for the purposes of sending you communications regarding general market information, business updates, invitations and opportunities to participate in PearTree offerings by internet, mail, e-mail or other methods.

Security and Retention of Personal Information

PearTree protects client information using controls and safeguards that are appropriate to the sensitivity of such information. It implements security measures to protect personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.

We will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law.

Consent

It is assumed that individuals who transact in securities through PearTree consent to the firm’s reasonable collection, use, disclosure and retention of their personal information in order to perform those services and to fulfil PearTree’s regulatory obligations and contractual responsibilities.

PearTree considers an individual to consent to the collection, use, disclosure and retention of their personal information when the individual personally (or through an authorized agent) voluntarily provides their information for completion of the New Client Application Form, Investor Information Form and subscription documentation.

An individual may withdraw their consent for the use and/or disclosure of their personal information at any time, by contacting PearTree and specifying what personal information they no longer wish PearTree to use or disclose. However, this is subject to legal or contractual restrictions and reasonable notice. Implications to withdrawing consent include PearTree’s inability to continue transacting with the client.

Sharing Information with Service Providers and Other Third Parties

When participating in a transaction, personal information may be disclosed either directly or indirectly to (a) stock exchanges or securities regulatory authorities; (b) the applicable registrar and transfer agent; (c) Canada Revenue Agency; and (d) any other parties involved in the transaction and may be included in the transaction record books. PearTree may be required by law to disclose personal Information to tax authorities, regulators and/or other government agencies.

In some circumstances, for example where it is necessary in connection with the provision of a service and client consent (if required) has been obtained, PearTree may disclose personal information to the issuers of securities purchased by clients (and parties related to such issuers) or financial service providers, such as banks and others involved in financing or facilitating transactions by PearTree.

To the extent that PearTree enters into arrangements with service providers to handle (including processing or storing) personal information, the firm remains legally responsible for the privacy of such information. In all other cases, PearTree will only provide personal information to third parties if PearTree has the individual’s consent or where disclosure is required or permitted by privacy legislation.

PearTree will not make personal information available in any manner to third parties for unauthorized purposes such as advertising or other solicitation.

When you access or use our website, we may also collect non-personal information that is anonymous and aggregated and cannot be attributed back to you. In particular, we partner with Google Analytics to evaluate usage of our website to help us improve our services, performance, and user experiences. Analytics providers may use cookies and other technologies to perform their services, and may combine the information that they collect through the website with other information that they have collected. This Privacy Policy does not cover the collection, use, and disclosure of tracking data collected by third party analytics providers. For further information please see the relevant provider’s privacy policy.

How to Contact Us About Privacy Matters

If you would like to review or update the personal information in PearTree’s records, or if you have
any inquiries about this Privacy Policy, please make your request in writing to PearTree Financial Services Ltd., 110 Eglinton Avenue West, Suite 400, Toronto, Ontario M4R 1A3 Attention: Chief Compliance Officer

Changes to this Privacy Policy

We will post changes to this Privacy Policy on our website along with the effective date of the changed policy. We recommend you review this policy periodically.

This Privacy Policy was last updated in October 2024.