Ullman Wealth Management Inc. (“Ullman Wealth”) is subject to the Personal Information Protection and Electronic Documents Act (Canada) which regulates the way private sector organizations collect, use, and disclose personal information. In the conduct of our business, we hold or have access to sensitive personal information of you, our clients, which must be handled and safeguarded in an appropriate and professional manner.
1. What is Personal Information
Personal information is information about an identifiable individual, presented in any form. This may include but is not limited to information such as a person’s age, name, address, gender, financial records, opinions, evaluations, and identification numbers including file number(s) and social insurance number.
It does not include the name, job titles, and business address or telephone number of an employee of an organization or personal information that can be found through publicly available information. Personal information does not include information that has been anonymized so that it does not identify a specific individual.
2. Why Ullman Wealth Needs Personal Information
We collect personal information from our clients to meet requirements under Canadian securities legislation as well as anti-money laundering and anti-terrorist financing regulations. Pursuant to such legal requirements, we are required to establish and maintain a sufficient level of client knowledge to, among other things:
a) accurately confirm the identity of an individual or the beneficial ownership of a legal entity;
b) determine broad investment policy such as investment objectives, risk tolerance and target asset mix for managed accounts; and
c) assess suitability or eligibility regarding individual investment opportunities on an ongoing basis.
Meeting these requirements necessitates a clear understanding of the personal and financial circumstances of our clients. This understanding and need for information may at times also extend to individuals other than direct clients, such as in the case of the trustee of a trust or a third party individual who may be granted authority over an account.
3. Consent Regarding Collection, Use and Disclosure of Personal Information
Personal information may be collected, used, and disclosed through the filling out of our forms or otherwise providing information in order to obtain products or services from us. By filling out these forms or otherwise providing information, either yourself or on behalf of another individual, or by using our website or our services, you consent to the collection, use and disclosure of your personal information and, where applicable, the personal information of another individual in accordance with the terms and conditions of this policy.
We may also collect information from third parties that demonstrate that they have the right to disclose such information to us or where you have provided consent to such disclosure. When you inquire about or apply for our services, we may collect certain information. The information collected may include your name, mailing address, email address, phone number, driver’s license number, date of birth, social insurance number, or other information that is necessary in providing our services.
Personal information collected by Ullman Wealth will be used or disclosed for various purposes, including:
a) the purpose for which it was originally collected;
b) situations where use or disclosure may be required by law;
c) to deliver the services that you have engaged us to provide;
d) to understand your needs and make customized information available regarding other products and services offered by Ullman Wealth;
e) to evaluate and assist partners and affiliates of Ullman Wealth with respect to your eligibility for other services offered by such partners and affiliates;
f) to perform analytics or request feedback to improve and manage our relationship with you; and
g) to confirm or authenticate your identity and ensure that your information is current and correct.
In certain circumstances we may ask for your express consent which may be provided in writing, electronically (by clicking a button or checking a box), email, or orally when speaking with our staff.
When we collect, use, or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. Applicable law allows us, for legal or business purposes, to retain personal information for as long as is reasonable, but also imposes obligations upon us to ensure that procedures are in place to destroy the personal information when it is no longer required.
You may withdraw your consent at any time subject to any legal or contractual restrictions and reasonable notice by contacting us using the contact information below. However, by providing limited personal information we may not be able to provide you with certain services that are contingent on providing such information.
4. Security of Personal Information
Ullman Wealth has implemented safeguards designed and maintained to protect your personal information, regardless of the format it is in. We ensure that your personal information is protected against theft or loss, unauthorized access, use, copying, modification, disclosure, or disposal.
5. Online Services
When you send us an email, we learn your email address as well as any other information you may have included in the email. While we may use your email address to reply to you, we do not make your email address known to anyone outside Ullman Wealth without your consent. We may also send certain required information to you via email if you have requested that we do so. You may, at any time, tell us to stop sending information to you by email. Please keep in mind that information sent via email is generally unencrypted.
6. Application Software
Clients may utilize application software developed by Ullman Wealth or our partners to access or receive information including about their accounts. When interacting with us in this manner we or our partners may collect information such as location, page requests, operating system and average time spent using the application. This information is used to help understand how our clients utilize the application and to monitor and improve the functionality and services provide to you. We may also periodically send you information related to your account or relationship with us through the application, such as disclosures, notices, or reports that we are required to send you or that you have consented to receiving from us.
7. Privacy and Our Website
In general, we do not collect any of your personal information that can identify you when browsing our website. However, we may automatically collect general anonymous information related to your use of our website, such as the date and time you visit the website, and the pages you visit on the website. In addition, we collect “cookie” information from your browser to identify your computer and provide us with a record of your visits to our website.
We may use third party web masters to help us gather and analyze information about the areas you visit on our website in order to enhance your user experience and to help us analyze the use of our website. These third parties use “cookies” to collect and generate information about your visits to our website (including your IP address) that is transmitted to their servers in an anonymous form for processing. The use of these tools does not allow us or our analytics service providers to identify individuals. The technology used to gather “cookie” information is provided by the internet browser you use and maybe turned off by using your browser preference settings.
The non-personal information collected is used to improve the content of our website and to enhance the user experience. The only personal information collected from our website would be the personal information you voluntarily provide so that we may contact you regarding our services that you have inquired about.
From time to time, our website may contain links to other websites that may collect your personal information. We do not assume any responsibility for the privacy practices of the third parties operating such websites. You should read the privacy policies of these websites and in light of their policies, decide whether or not you want to provide your personal information to the operators of these third party websites.
8. Third Parties and Service Providers
With your consent, we may obtain personal information about you from third parties. This information helps us to assess your eligibility for certain products and services. In addition, your personal information will be disclosed to certain external sources that provide services to us such as our custodian, financial institutions, and other parties. For example, service providers who we hire to undertake activities, such as processing trades for your account and sending monthly statements to you, may have access to certain account information including your name and address in order to perform their required functions. We require that service providers have appropriate safeguards to ensure that your information remains confidential.
We are also obliged by law to provide your information to regulatory bodies within the investment industry, to government agencies or law enforcement agencies with a legal right to collect such information, or when we are in receipt of a valid court order or search warrant. As well, we may disclose your personal information in connection with a future transfer or sale of all or part of our business.
We do not disclose your information to any other organization to use for their own purposes. We do not sell client information to, or trade client information with anyone; nor do we share client information with organizations outside of our relationship with you that would use it to contact you about their own products or services.
9. Access to and Accuracy of Personal Information
Having accurate information about you will enable us to give you the best possible service. We expect that you will provide us with updated information when you move or change telephone numbers or have any other material changes in your information. If you detect any errors in information (such as the information appearing on your copy of your application form), please let us know immediately.
We will provide you with access to your information upon your request. Naturally, we will have to assess your request to ensure that any access we provide to you does not contain references to other persons, contravene legal restrictions on disclosure or violate our legal rights or privileges. We will respond to any request for access in accordance with the timelines, rights and obligations set out under applicable law.
10. Contacting or Communicating with Us
We have appointed Steven Harris, our President, as our Chief Privacy Officer.
If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Chief Privacy Officer by telephone at (416) 927-0000, and by email at firstname.lastname@example.org.
If you are dissatisfied with our handling of your personal information, we invite you to contact our Chief Privacy Officer in writing, setting out the reasons for your concern. If you remain dissatisfied, you may wish to contact the Office of the Privacy Commissioner of Canada using the below contact information.
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec, K1A 1H3