Forthlane Investment Management Inc., Forthlane Family Office Services Inc. and Forthlane Partners Ltd. (collectively, “Forthlane”, “we”, ”us”, “our”) are committed to maintaining and protecting the personal information that we collect, use and disclose in the course of providing our services and operating our business. We have created this Privacy Statement in order to better serve our clients and others by making them aware of their rights regarding the handling of their personal information in accordance with the laws and regulations under applicable privacy legislation in Canada. This Privacy Statement sets out in general terms how we collect, use, disclose and protect the personal information of our clients, other individuals and our website users (“you”). By providing personal information to us (whether via our website, client portal, by email, in person or over the phone), you agree to the practices set out in this Privacy Statement.
This Privacy Statement governs our dealing with “personal information”. Generally speaking, personal information means any information that can identify an individual such as age, gender, home or cell telephone number, address, date of birth, education, family status, purchasing and spending habits, investments, tax returns, financial information, religion or ethnic background. In general, personal information does not include business contact information such as your name, title or position, business or business e-mail address, telephone or facsimile number and information available from public records.
We reserve the right to change this Privacy Statement at any time and we will take reasonable steps to advise affected persons of any material changes, if necessary. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. You should review this Privacy Statement from time to time to ensure that you are aware of and accept any changes made. The most up-to-date version of our Privacy Statement is available in its entirety on our website. We encourage you to review this Privacy Statement whenever you visit our website to stay informed of how we are processing personal information.
We are responsible for all personal information in our possession and control. This includes personal information we receive directly, such as from individual clients or other individuals and personal information we receive indirectly from clients or others. We have designated a privacy officer who is accountable for our compliance with our Privacy Statement. We are also responsible to ensure that third parties who provide services to our firm and who may have access to personal information are also in compliance with our Privacy Statement.
NATURE OF INFORMATION COLLECTED:
The nature of the personal information we collect and use is dependent upon the information and services requested. Subject to applicable law, personal information may include:
- contact information (e.g. name, address, e-mail address and telephone number)
- nature of the client or potential client’s issues, family situation, financial and account information and other incidental information relating to the services we provide
- marketing information (e.g. meal preferences, event feedback and survey responses)
- recruitment information (e.g. education and employment history or details of professional memberships)
- client identification verification information (e.g. passport number or evidence of beneficial ownership)
- special categories of personal information (e.g. ethnic origin, political opinions or religious beliefs)
- information relevant to your assets and the use thereof, sources of income and expenditures, including details of property and asset ownership, employment, benefit or tax information and any other information you give to us when consulting with us
- information about you contained in communications within Forthlane and between us and you, whether online or offline
- information we may collect with your consent or as permitted or required by law
PURPOSES OF COLLECTING INFORMATION:
Forthlane collects, uses and discloses personal information for the primary purpose of operating our business and providing clients with wealth management services and other related services, including for the following purposes:
- to establish and manage client relationships, including performing services and carrying out obligations under any agreements between you and us
- sharing personal information with third parties for the purpose of providing our services, including to investment, insurance, legal, banking, government agencies or accounting advisors provided we have your consent to do so
- helping to prepare bank and investment account open/close/transfer forms and related documents on behalf of our clients
- preparing investment plans and investment performance reports
- communicating with clients concerning the work we do for them or concerning matters that we feel would be of interest to them
- distributing newsletters and other materials to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers
- to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, process payments and evaluate credit standing
- to contact and communicate with clients and other individuals to better understand our service and marketing requirements
- to distribute our publications and invitations to events to individuals who have consented to receiving these
- for recruitment purposes to consider the hiring of individuals as employees or consultants of Forthlane
- to facilitate the use of our website and respond to requests for information from visitors to our website
- to develop and manage our business, operations and service offerings including to maintain, develop and manage our document management systems and databases
- as permitted by, and to comply with, applicable legal or regulatory requirements such as anti-money laundering laws
When personal information has been collected and is to be used or disclosed for a purpose not previously identified, the new purpose will be identified and consent obtained prior to its use.
INFORMATION ABOUT SERVICE PROVIDERS:
We may collect information about third-party agents, vendors and suppliers who provide goods, services and information to Forthlane. This information would include name and contact information as well as any information (such as banking information) that we need to pay suppliers for their services and other relevant information, such as experience and qualifications.
PRIVACY AND OUR WEBSITE:
Cookies – We may use a browser feature called a ‘cookie’ to collect information when an individual visitor accesses our website. Such information would include non-personal information about you and your use of the site. We would not match or correlate this information with any personal information that you submit on the website. We will not be able to identify individual visitors unless a visitor specifically informs us of his or her identity by submitting personally identifying information, such as by registering for a mailing list or sending us correspondence from the website. We may use information collected by cookies for the purpose of: (i) tailoring content that we share with you; (ii) to authenticate you, enable access to information and otherwise administer the website; and (iii) for analytical purposes to better understand digital interactions with Forthlane. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
Online Communications – You may choose to voluntarily submit personal information to us for the purpose of asking a question, obtaining information, reviewing or downloading a publication or attending an event. We use such personal information you provide only for the purpose for which you have provided it. If you have provided us with contact information in the past, we may combine the information with information submitted on the website. We provide an on-going opportunity to unsubscribe to contact from Forthlane by contacting us.
E-mail Communications – We may periodically send out e-mail communications to businesses and individuals in our contact database. If you do not wish to receive further materials from us you may ask us not to contact you for this purpose by contacting us.
Links – Our website may contain links to other websites. Operators of such sites may also collect personal information. Please consult the privacy policies for such third party websites. Forthlane is not responsible for the manner in which such third parties collect, use or disclose personal information.
SHARING YOUR PERSONAL INFORMATION:
Forthlane will not share your personal information with third parties other than in the following circumstances or for the following purposes:
- in connection with normal business operations to open, maintain, administer or service client accounts, including without limitation the provision of services to clients (including by third-party service providers who provide website, hosting, maintenance and other services to us) and the provision of back office administrative services
- to legal counsel for the purpose of obtaining legal advice
- to any law enforcement agency or other governmental agency, if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws
- in the event of an acquisition, merger, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets
We will obtain consent for the use, collection and disclosure of personal information, either express or implied. We assume that an individual has consented to our reasonable collection and use of personal information consistent with purposes for which the information was given when the individual initiates contact with us or voluntarily provides personal information to us. We also assume that clients who retain us consent to the reasonable collection, use and disclosure of their personal information to our staff for the purposes for which we were retained. We will consider the sensitivity of the information and the individual’s reasonable expectations in determining how consent must be given. If you provide personal information about another person to us (including dependents, other family members, beneficiaries or related entities), we assume you have the consent of that individual to enable us to collect, use or disclose their information as described in this Privacy Statement. We will only provide information to third parties when we have authorization to do so or where legislation requires that we do so. All personal information is held in strict confidence. We do not make personal information available in any manner to third parties for any purpose such as advertising or other solicitation.
ENSURING PRIVACY WHEN DEALING WITH THIRD PARTIES:
To the extent we enter into arrangements with service providers, agents and independent contractors who we have engaged to store, handle or process personal information on our behalf, we will require such third-party services providers – by contractual or other means – to observe the intent of this Privacy Statement and provide comparable privacy protection while the information is processed or handled by them. Such service providers only receive information that is reasonably necessary for them to perform their functions.
We will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Statement and in order to comply with our legal and regulatory obligations. We will keep the personal information that we collect at our head office in Toronto, Ontario or the data servers of our service providers within Canada and the United States.
If you wish to request access to your personal information in custody or control of Forthlane, please make your request in writing to our Privacy Officer at the address listed below. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your personal information. Any such identifying information shall be used only for this purpose. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information or if it is otherwise not properly the subject of an access request.
We will attempt to ensure that your personal information is kept as accurate, complete and as up-to-date as possible. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your personal information, when required.
At any time, you can challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information.
RESPONSE TO WRITTEN REQUESTS:
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner in respect of this time limit.
We will not charge any costs for you to access your personal information in our records without first providing you with an estimate of the approximate costs, if any.
Copies of our privacy statement will be made available to all clients and others as requested. Should you feel we are not in compliance with the above principles, our Privacy Officer will investigate. If a complaint is found to be justified, we will take appropriate measures including, if necessary, amending office policies and practices.
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate physical, organizational, contractual and technological safeguards in an effort to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards. If you believe personal information has been compromised, please contact our Privacy Officer at the address listed below.
COMMENTS & Questions:
All comments or questions about our privacy practices should be forwarded to our Privacy Officer as follows:
Attn: Privacy Officer
145 Adelaide St. West, 2nd Floor
By e-mail: firstname.lastname@example.org
Updated: Feb. 12, 2020