Privacy Policy

Background

Ullman Wealth Management (“UWM”) is guided and governed by the Personal Information Protection and Electronic Documents Act (the “Act”) which regulates the way private sector organizations collect, use and disclose personal information.  In the conduct of its business, UWM holds or has access to extremely sensitive personal information of its clients and staff must be committed to handling and safeguarding this information in an appropriate and professional manner at all times.  This Privacy Policy has been prepared with this objective in mind.

 

What is Personal Information?

Personal information includes 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 user.

 

Why UWM Needs Personal Information

UWM collects Personal Information from clients to meet certain requirements under Canadian securities legislation and anti-money laundering / anti-terrorist financing regulations.  UWM staff are required to establish and maintain a sufficient level of client knowledge to conduct the following activities:

·                to accurately confirm the identity of an individual or the beneficial ownership of a legal entity;

·                to determine broad investment policy such as investment objectives, risk tolerance and target asset mix for managed accounts;

·                to assess your suitability or eligibility regarding individual investment opportunities on an ongoing basis; and

·                to comply with all other legal or regulatory requirements that UWM may be subject to from time to time.

Meeting these requirements necessitates a clear understanding of the personal and financial circumstances of clients.  This understanding and need for information may at times also extend to individuals other than direct UWM 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.

Consent Regarding Collection, Use and Disclosure of Personal Information

Personal information may be collected, used and disclosed by the Company 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 products or 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 or apply for our products and services, we may collect certain information. The information collected may include (but is not limited to) your name, mailing address, email address, phone number, driver's license number, date of birth, or other information that is critical in providing our services.  However, we will collect only personal information necessary for the purposes stated in the section titled, "Why UWM Needs Personal Information."

Personal information collected by UWM will be used or disclosed for various purposes, including but not limited to:

•                the purpose for which it was originally collected;

•                situations where use or disclosure may be required by law;

•                to deliver products and services of UWM that you have engaged us to provide;

•                to understand your needs and make customized information available regarding other products and services offered by UWM;

•                to evaluate and/or assist partners and affiliates of UWM with respect to your eligibility for other products and services offered by partners and affiliates of UWM;

•                to perform analytics or request feedback to improve and manage our relationship with you; and

•                to confirm or authenticate your identity and ensure that your information is correct and current.

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, facsimile, or orally over the telephone when speaking to UWM Staff.

When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. The Act also 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 products and services that are contingent on providing such information.

Security of Personal Information

UWM 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. Our current measures of protection include (but are not limited to):

•                physical measures including restricted access to premises;

•                organizational measures including training of staff and internal limitations on accessibility of information;

•                internal password and security policies;

•                confidentiality agreements with any third parties we engage with;

•                technological measures including the use of firewalls and encryption of data; and

•                investigative measures should we determine that a privacy breach has occurred as a result of inappropriate collection, use, or disclosure of personal information.

Online Services

When you send us an e-mail, we learn your exact e-mail address as well as any other information you may have included in the e-mail. While we may use your e-mail address to reply to you, we do not make your e-mail address known to anyone outside Ullman Wealth. We may also send certain required information to you via e-mail if you have requested that we do so. At any time you can tell us to stop sending information to you by e-mail. Please keep in mind that information sent via e-mail is generally unencrypted. Please do not send us sensitive or confidential information via e-mail.

Application Software

Clients may utilize application software developed by UWM or its partners to access information about their accounts.  When interacting with us in this manner we may collect information such as location, page requests, operating system and average time spent using the application.  We use this information to help us understand how our clients utilize the application and to monitor and improve the functionality and services we 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.

Privacy and Our Website

In general, we do not collect any of your personal information that can identify you when browsing our website. However, certain non-personal information such as an IP address, cookies, Internet tags and navigational data may be collected. 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.

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.

We may also disclose your personal information to service providers. However, we will ensure that service providers have similar safeguards and a similar privacy policy or that they agree to abide by ours. 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 as a result of a future transfer or sale of all or port of our business.

Requests for Access to Personal Information

Pursuant to the Act, an individual may submit a written request to us to provide them with the Personal Information we hold or process on their behalf. We will respond to requests in the time allowed under the Act, and will make a reasonable effort to assist applicants, and to respond as accurately and completely as reasonably possible. Requests may be subject to certain fees and disbursements in accordance with the provisions the Act.

Requests for Correction of Personal Information

An individual may also submit a written request to us to correct errors or omissions in the personal information of the individual that is in our custody or control. When provided with a written request, UWM will:

•                correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information; or

•                decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

Contacting or Communicating with Us

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 UWM’s Chief Compliance Officer by telephone at (416) 927-0000.

If you are dissatisfied with our handling of your personal information, we invite you to contact our Chief Compliance 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

1-800-282-1376   https://www.priv.gc.ca/en