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Privacy Policy

1. Why did we adopt this policy?

The personal information ("information") you entrust to us is essential to our business relationship with you. We know how valuable it is, and we are determined to do everything in our power to protect it.

That's why we've adopted this policy, which describes our practices for protecting your information and privacy. Our goal is to be transparent with you. This policy applies to the use and disclosure of any information collected, and the manner in which Archer and its affiliates collect such information, in the course of your business relationship with them. This policy applies for as long as we hold your information, including after the end of our business relationship.

The Privacy Officer is responsible for Archer's privacy practices. If you have any questions about this policy, you can write to him at one of the following addresses:

Privacy Officer

For Archer gestion privée inc.
Christian Boucher, conformite@archer.ca

For Archer Asset Management Inc.
Richard Morin, conformite.ptf@archer.ca  

You can also contact us as indicated in section 9 below, if you have any questions.

2. What type of information we may collect and from whom

2.1. What information we may collect

Identification information

  • Names
  • Date of birth
  • Contact details
  • E-mail address
  • Information on identification (driver's license, passport, social insurance number*)
  • Jobs
  • Bank or investment account number
  • Information we hold about you as an authorized representative, director, officer or shareholder

Information to confirm your identity 

  • Signatures
  • Account information

Financial information 

  • Income, wages and balances
  • Products and investments and their terms and conditions (e.g. term, repayment frequency, limits, rates, maturity, etc.).

Other information

  • Why you do business with us
  • Language and communication preferences
  • Information about persons other than yourself (power of attorney, beneficiaries, your spouse or common-law partner or dependents insured under an insurance product or registered plan, an authorized user of your account, a trusted individual and contact information for a person you believe may be interested in a product or service from companies affiliated with the Archer Group.

*If you provide us with information about another person, we will assume that you are authorized to do so and that you have obtained that person's consent to its collection, use or disclosure for the purposes set out in this policy.

Information on your operations

  • Investment instructions
  • Risk tolerance
  • Investment and planning knowledge and objectives

Information about your health and lifestyle for the purchase of insurance products or services*.

  • Your family's health history
  • Your activities, your behavior, your choices
  • Dangerous travel, sports and leisure activities

*Due to the sensitive nature of health and lifestyle information, it will not be shared for marketing purposes.

Information for training, quality control, identification and security purposes, or to maintain your consent to a transaction

  • History, recording of telephone calls and written communication
  • History of individual meetings

Information on digital interactions (websites and social media sites)

  • Device information (e.g. IP address, VPN, proxies, device type and operating system)
  • Information about your approximate location that is generated using your IP address when you visit our websites.
  • Browsing preferences and habits, such as the pages you visit and use. For more details, please consult our Digital Data Policy.

IMPORTANT: We limit the collection of your information to what is necessary to help us serve you better.

2.2. From whom we may collect your information

We may collect your information directly from you when you communicate or interact with us. We may also collect your information indirectly from the sources listed below. When required, we obtain your consent.

  • people linked to your products and services
  • publicly available sources or records
  • regulatory and self-regulatory bodies
  • companies affiliated with the Archer Group
  • content generated through the use of our websites, mobile applications and social media platforms. For more details, please see our Digital Data Policy.

3. How we use and share your information and with whom

3.1 How we use and share your information

We use and disclose your information for:

  1. identify you, update your information and verify the veracity of the information provided
  2. assess your financial situation
  3. ensure that the advice we offer or that you obtain is suitable for you
  4. establish your investor profile, financial needs and objectives, and investment strategies
  5. establish, manage, administer and maintain the products and services requested
  6. combine the financial information held on you by companies affiliated to the Archer Group in order to generate an overview of the products and services you hold and thus serve you better (see your right to refuse in section 5.2)
  7. to carry out studies and data analysis with a view to generating statistics, improving our products and services and designing new ones, in particular by analyzing the information collected by our website (see your right to refuse in section 5.2).
  8. personalize your customer experience, in particular by analyzing your profile, your transactions and other information (including that collected by our websites) in order to:
    • get to know you better and understand your needs
    • target and personalize products, services and promotions that may be of interest to you and suit your situation
    • better advise you by analyzing your needs and preferences
  9. ipromote products and services that may be of interest to you, offered by companies affiliated with the Archer Group or some of its partners, including personalized advertisements on social media and digital platforms (see your right of refusal in section 5.2)
  10. our day-to-day business and operations
  11. enable due diligence on our operations in anticipation of entering into a business transaction
  12. communicate with you using the contact details you have provided (by post, e-mail, text message, call, social media)
  13. use and communicate certain information where we are authorized to do so by law (see section 4).

3.2. To whom we may disclose your information

It is sometimes necessary to share your information with others for legitimate purposes. For example, this may be required by law, to protect your interests in the event of fraud, to enable you to participate in a program with a partner, or to provide you with services on our behalf. At all times, we are committed to limiting information to that which is strictly necessary, and to obtaining your consent when required.

We ensure the integrity, security and confidentiality of your information.

  • We may share your information with :
    • companies affiliated with the Archer Group, for information that identifies you, for compliance purposes and to simplify the day-to-day management of your accounts.
    • companies affiliated with the Archer Group, for your financial information, in order to serve you better (see your right of refusal in section 5.2)
    • someone acting on your behalf
    • an insurer or agent acting on our behalf
    • a person who holds an account jointly with you or who is otherwise involved in your relationship with us
    • third parties, if we need to disclose your information in connection with legal proceedings
    • a regulatory or governmental authority or self-regulatory organization
    • a person authorized by law to obtain them
    • third parties involved in concluding a business transaction
    • social media and digital platforms with whom we may share your name and contact details (e.g. your email address) to enable us to serve targeted advertising on their platforms (see your right to opt-out in section 5.2)
    • as described below, the service providers we use to perform certain tasks such as producing investment statements, managing loyalty services and performing marketing services on our behalf.

3.3. Service providers

  • We select our service providers with great care. They fall into the following categories:
    • technology services (applications, data center, data storage and backup, hosting services, maintenance and support services)
    • professional services
    • financial services and banking
    • insurance services
    • communication services
    • mail services
    • analytics and marketing services

All suppliers who have access to your information sign a confidentiality agreement with us and agree to use your information only for the purposes stated in the agreement and to provide them with the same level of protection we offer. 

4. When do we need your consent? 

  • We use your information only with your consent or as permitted by law. We obtain your consent to collect, use and disclose your information:
    • when you request a new product or service
    • when we need to use your information for a purpose different from those for which you have already given your consent
    • during specific interactions with us, such as customer service calls or the completion of online forms
  • However, we do not obtain your consent for every interaction with you.
  • In addition, we do not obtain your consent in certain situations provided for by law, for : 
    • investigation of breach of contract or breach of law 
    • prevent, stop or detect fraud 

5. Your rights and how to exercise them

5.1. Right to accept or refuse to provide your information

Your information belongs to you. Subject to legal, commercial or contractual requirements, you have the right to withdraw your consent to the collection, use or disclosure of information. We will process your request as quickly as possible.  

However, certain information is essential for us to provide you with certain products and services. If you refuse to provide it, it may be difficult, if not impossible, to establish or maintain a business relationship with you or even to offer you some of our products. For example, if you do not wish to provide your SIN, we will not be able to offer you products for which it is mandatory, such as a registered product like an RRSP.

5.2. Right to refuse that we use your information for certain purposes You can refuse that we use your information or withdraw your consent

You may refuse to allow us to use your information or withdraw your consent for the following purposes:

  1. a) Subscription to our newsletter

    Companies affiliated with the Archer Group may share information with you that may be of interest to you. You may withdraw your consent to receive such information at any time. There may be a delay before you stop receiving communications from us, including those from a campaign already in progress.

    We may also use your name, e-mail address or other contact information to create personalized audiences on social media and digital platforms. This enables us to display ads tailored to your needs and interests on these platforms. You can opt-out of the use of your information for targeted advertising by changing your preferences in your social media account settings or by contacting us.

    Occasionally, we may contact you to ask if you would like to update your choice to ensure that our records are up-to-date and reflect your current preferences. Please note that if you withdraw your consent to this use, you may still see some of our posts on social media platforms.

    Please note that if you withdraw your consent to this use, you may still see some of our posts on social media platforms.
  2. b) Share your financial information among affiliates of the Archer Group.

    We may share your financial information among affiliates of the Archer Group to facilitate our relationship and simplify our interactions with you. This sharing may include:
    • serve you better by having a complete view of all the products and services you hold within the companies affiliated to the Archer Group (for example, by accessing your financial portrait more quickly when making an appointment for a new product or service)
    • analyze your financial situation to verify your eligibility for offers, promotions and certain products and services that may better suit your needs
  3. c) Collecting and using your digital information on our online services

    With your consent, we may collect your digital information (e.g. device and browsing data) using optional cookies or other similar technologies when you visit our website. This information enables us to measure and analyze traffic to improve your browsing experience. You may opt-out of the collection of this information by clicking on the "Privacy Preference Center" at the bottom of our websites. For more details, see our Digital Data Policy.

How to withdraw your consent

You may at any time withdraw your consent to subscribe to our newsletter (5.2 a)) and your consent to the sharing of your financial information among companies affiliated with the Archer Group (5.2 b)). You can make a request by e-mail to one of the privacy officers whose contact information appears at the beginning of this document. We will process your request as quickly as possible.

You may also refuse the use of cookies on our websites and mobile applications at any time (5.2 c)). To find out how to do this, consult our Digital Data Policy.

What you will continue to receive after withdrawing your consent

You will continue to receive :

  • Regulatory notices we are required by law to send you
  • Information about your current products and services.

You may also continue to receive information about our products and services verbally or in person from our representatives. In fact, some of our representatives have a duty to advise you and will continue to provide you with this information when necessary.

5.3. Right to access your information

You may request access to the information we hold about you, except where restricted by law.

How to consult your information

To consult your information, you must make a request :

  • by e-mail to one of our privacy officers whose contact details appear at the beginning of this document
  • by contacting your advisor

We will process your request within 30 days, or longer if required by law. We will inform you if the deadline is longer than 30 days.

5.4. Right to correct your information

You can and must correct inaccurate information about yourself. In order to provide you with quality service, it is essential that your information be accurate and complete. To this end, we rely on you to help us maintain the quality of the information we hold by informing us of any changes. To make a request, please refer to the procedure identified in section 5.3 above.

6. What are our security measures for storing your information?

6.1. Time-limited conservation

We retain your information, in physical or digital format, for as long as necessary to fulfill the purposes for which the information was collected, or as long as required or permitted by law. The purpose, nature and sensitivity of the information have been taken into account in determining retention periods.

Companies affiliated with the Archer Group are subject to numerous legal obligations regarding the retention of personal information (for example, under securities, tax and anti-money laundering laws). In general, to meet these obligations, your customer profile information (such as your name, address, date of birth) will be retained for the duration of your relationship with us and for a period of seven years following the end of that relationship. In addition, we will retain your transactional information for seven years after completion.

Certain exceptions may apply and require longer retention periods, for example in the case of litigation or claims. In such cases, your information may be retained for up to ten years. When your information is no longer required, we endeavour to destroy it securely.

6.2. Storage locations

Archer affiliates, their service providers and other third parties to whom your information is disclosed under this policy may operate outside Quebec. Your information may therefore be used and stored securely in other provinces.  

6.3. Information security program

We go to great lengths to protect your information against loss, theft, unauthorized access, use or disclosure, and any other breach of security. We have implemented a security program to keep pace with constantly evolving threats to information security. The measures adopted in our security program are : 

  • protect infrastructures through secure access to our premises and secure locations for our equipment, etc. 
  • limit the people who have access to your information. This means that only employees who need to consult your information in the course of their work have access to it. 
  • manage passwords and set up firewalls. 

You have a role to play in protecting your information. We ask you never to divulge your passwords, codes and personal identification numbers. Our employees do not have this information and will not ask you for it.

7. What other conditions accompany this policy

This policy is supplemented by our Digital Data Policy, which explains how we use cookies and similar technologies when you visit our website.

In addition, some products and services come with specific information processing conditions. It is important to take these into account.

8.How can we change this policy 

We may change this policy from time to time. We will notify you by means of a notice appearing on our websites and by any other appropriate means to reach you.

9.How to contact us with a question, comment or complaint

To ask a question or send a comment, please contact us :

  • Contact one of the privacy officers listed at the beginning of this document.
  • Call our customer service center
  • Contact your advisor

To make a complaint, you must contact one of the privacy officers listed at the beginning of this document.