Privacy Policy
This Privacy Policy describes how and why Markette Ventures Inc. (“we”, “us”, or “our”) protect and handle your personal information. From our beginnings, we have been committed to keeping your information safe and the business you do with us in the strictest confidence. Here are some important terms that we use in this Privacy Policy:
• “Personal information” or “your information” means information that is about an individual that can be identified.
• “You” and “your” means you directly, whether you are a client, prospective client, beneficiary, website visitor or otherwise interacting directly with us, or when another person provides us with your information.
This Privacy Policy applies whenever you interact with us. If you have any questions regarding the Privacy Policy, you can submit them to our Privacy Officer using the information provided at the end of this Policy under “Contact Us”.
How we handle your personal information
The type of personal information we collect depends on various factors, such as the type of products or services you request or use, any applicable legal and regulatory obligations and the channel through which you communicate with us. This information includes:
• Contact information that allows us to communicate with you, such as your address, telephone number, email or other electronic address, or social media account username.
• Identity information that allows us to establish and verify your identity, including government-issued identification, name, date of birth, occupation and answers to security questions. In addition, we are required to obtain your Social Insurance Number (SIN) when opening an investment account.
• Biometric information, such as the measurement of facial features and voice patterns. We may use biometric information to verify your identity.
• Financial information that allows us to determine the appropriateness of products or services, such as employment and financial history, income, net worth, and investment knowledge and objectives.
• Transactional information about your accounts and how you use different products or services, such as transaction history.
• Information that you provide about other people. This could be information about spouses, common-law partners or dependents. It could also be information about an authorized user of your account. If you provide us with information about another individual, we will assume you have the authority to provide this information and have obtained their consent to its collection, use and sharing for the purposes set out in this Privacy Policy.
• Online activity information, like your IP address and how you use our app or website, which is obtained from your online interactions with us. See “Interacting With Us Online” below for details.
Where we collect this information from
Most of the information we collect comes directly from you. However, we may collect your information from other sources. These other sources include:
• Other clients or business partners who provide referrals
• Government agencies, law enforcement authorities, regulators and fraud prevention organizations
• Other financial institutions, such as when we interact with your bank to transfer funds or investment dealers leveraging our platform to personalize your subscription agreements.
• People who have the legal authority to act on your behalf, such as under a power of attorney
• Individuals whose information you provide us, like a trusted contact person
How and why we handle your information
We collect and use your information to:
• Verify your identity
• Communicate and manage our relationship with you
• To understand your needs for our products
• Manage and assess our operations and risks
• Train our personnel
• Protect both you and us against error, fraud and unauthorized use, and to investigate potential misconduct
• Better understand you and your objectives so that we can offer products and services to meet your needs
• Assess the eligibility of an individual to invest
• Maintain records for Markette
• Conduct internal analytics to identify trends, improve or develop new products and services, and inform how we do business
• to process billing and collection of any fees
• to conduct surveys and obtain feedback from you
• Assess and engage in business transactions
• To process your inquiries or respond to questions, comments or concerns regarding your transactions
• Protect our property, interests, and legal rights
• Comply with legal and regulatory requirements
To perform these activities, we may share your information with third parties to perform services on our behalf. We use service providers to:
• Support our internal business operations (like our compliance and human resources functions)
• Verify your identity, including with biometrics
• Assist with IT functions, such as operating and protecting our website, client portal, app and other IT assets
• Improve our ability to communicate and manage our relationship with you
• Help identify products and services that may be of interest to you
Accuracy
Personal information must be as accurate, complete, and up to date as necessary for the purposes for which it is to be used.
Interacting with us online
We use certain technologies and tracking tools on our website and app, such as cookies. Cookies are snippets of data stored by a web browser (for example, Chrome, Safari or Firefox web browsers). We also use pixels, beacons, web analytics services, and other technologies. These tools provide us with information about your usage of our website and app. This information helps us operate, improve and protect our website and app. We, and third parties we permit, may use these tools to track which of our ads you interact with on our website and on the websites of companies who help us advertise. We may use this information for analytics and reporting, to learn more about how you interact with us, and/or promote our products and services. You can manage the cookies you permit using our Privacy Preferences Center.
When using our app, we may collect technical information about your usage of the app and your device. Device information can include a device ID and what kind of operating system your device is using. The ability to access certain personal information can be managed through your device settings and the app’s settings. Your device support will have instructions for how to manage these permissions.
Google Analytics. We use Google Analytics to better understand your use of our website. Google Analytics collects information on user behaviour on our website, which includes how many times a user visits our website, what pages they visit, and where they were referred from. Advertising identifiers for mobile devices are also collected. Google may use the data collected for its own purposes, including to contextualize and personalize the ads of its own advertising network. To learn more about how Google uses data when you visit websites using Google Analytics, click here. You can deactivate the Google Analytics function with a browser add-on, which you can download here.
Disclosing your information
We may disclose your information under the following circumstances:
• To issuers or their their legal counsel when we assist you in subscribing for a prospectus exempt offering. The issuer’s privacy policy will have details about how they handle your personal information.
• To financial institutions in connection with our products and services, such as when we transfer funds to your bank account or investment dealers leveraging our platform to personalize your subscription agreements.
• To trusted contact persons, powers of attorney (or individuals authorized to act on your behalf), regulators or law enforcement authorities to prevent or investigate financial abuse or other unauthorized activity
• To government agencies, regulators, or law enforcement to comply with legal requirements, prevent fraud and other illegal activity, and respond to requests for information that we determine to be legitimate
• Any other person or organization with your direction or consent
Our privacy practices
How we protect your information
We have implemented administrative, technical and physical safeguards designed to protect personal information in our custody and control against unauthorized access, use, modification and disclosure. Only authorized personnel have access to your information. Our procedures and systems are designed to protect your information from error, loss and unauthorized access. We also have policies for the destruction and retention of your information (see “Destruction and Retention” below) and the handling of privacy-related questions and complaints (see “Your Rights” and “Contact Us” below). Each and every one of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. As a condition of employment, our employees are required to sign a confidentiality agreement binding them to this responsibility. We keep your information only as long as required by applicable rules and regulations, and we monitor our compliance in conjunction with privacy legislation.
International storage
We store and process your personal information in Canada. However, the disclosure of your information in accordance with this policy and applicable law may result in your personal information being transferred outside of Canada, including to the United States. The laws of other countries regarding the collection, use, and disclosure of personal information may be different from the laws of Canada. Governmental and law enforcement agencies within these jurisdictions may have access to your personal information.
Destruction and retention
We retain your information only as long as we need it for the purposes we collected it. We have procedures to help us determine the appropriate length of time we will retain your information. The length of time we retain the information depends on the product or service, the sensitivity of the information, and the purposes for which we use it. Typically, we will retain personal information that relates to a client for a period of seven years following the end of the client relationship or a longer period required or permitted by law. This period may extend beyond the end of your relationship with us in certain circumstances, including:
• when we need your information to respond to issues that may arise at a later date,
• for legal or regulatory purposes, and
• for security and business modelling purposes.
We have procedures to guide what we do when we no longer need your information for these purposes. We may securely destroy, delete, erase it, or convert it to an anonymous form. You can contact us using the contact information below if you have questions about how long we retain your information.
Automated decisions
In some cases, we may use technology to make automated decisions about you in real time. When this occurs, we may notify you in advance of the decision, for example, in the client onboarding process. We will also tell you how you can contact us to learn more about the automated decision process, but you can always contact our Privacy Officer using the information provided below if you have any questions.
Your privacy choices and rights
Your consent
By engaging us to provide dealer services to you or submitting information to us in connection with our services, you are indicating your consent to our collection, use and disclosure of your personal information in the manner described in the above Section “How and Why We Handle Your Information.
Your choices
Subject to legal, business or contract requirements, you can withdraw your consent to our collection, use and sharing of information at any time by giving us reasonable notice. However, withdrawing your consent may limit or prevent us from providing you with, or being able to continue to provide you with, specific products and services. For example, if you choose not to provide us with your SIN, we will not be able to provide you with any product where the collection of a SIN is required by law.
Some other choices you have include:
• Unsubscribing from marketing or promotional emails
• Managing your cookies preferences (see “Interacting With Us Online” above)
• Telling us about your other communication preferences, by contacting our Privacy Officer
In certain circumstances, your consent cannot be withdrawn. For example, you may not withdraw your consent where our collection, use and sharing is permitted or required by law, is required to ensure we have correct and up to-date information about you, such as your current address, or is necessary to manage our business, including the sharing of information when we assign our rights to others for business transactions.
Your rights
In addition to exercising your privacy choices above, you can request to access or correct your personal information, ask questions about our privacy practices, or submit a complaint, using the information under “Contact Us” below. Our Privacy Officer will consider your question, request or complaint, and respond to you as appropriate.
Please note that you may be required to verify your identity before we provide you with access to any of your personal information.
Contact us
To submit an access or correction request, exercise your privacy choices, ask a question or submit a complaint, please contact our Privacy Officer using the following information:
Markette Ventures Inc. C/O Markette Privacy Officer, Suite 2100, 40 Temperance Street, Toronto, ON, M5H 0B4
Updates to this policy
This Privacy Policy was last updated February, 2024 and may be updated periodically to reflect changes to our personal information practices. We strongly encourage you to refer to this Privacy Policy often for the latest information about our practices.