Privacy Policy
Leduc International Inc. Financial Services Privacy Policy
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OUR RESPONSIBILITY
Financial Services Leduc International Inc. (“SFIL”) is responsible for the protection of the personal information it holds, whether its conservation is ensured by it or by a third party whatever the form of the documents (written, graphic, audio, visual). , computerized or other). As such, SFIL takes the necessary security measures to protect your information in a manner proportional to its sensitivity, in accordance with this confidentiality policy (the “Policy”).
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YOUR CONSENT
By visiting or using the SFIL website (the “Site”), or otherwise communicating with us – for example, to obtain services or products – you agree to be bound by this Policy and you consent that your personal information is collected, used, communicated, stored and destroyed in accordance with the terms described therein.
You understand that certain features of our Site or our products and services offered may no longer be accessible or will be restricted following your refusal or withdrawal of your consent to be bound by the Policy.
Personal information of persons under 14 years of age is collected with the explicit and verified consent of the holder of parental authority. -
APPLICATION
The Policy applies to all personal information relating to the persons concerned, including visitors to the Site, applicants for our products and services, our customers, partners, investors and our employees.
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PURPOSE OF THE POLICY
This policy aims to protect any personal information held by SFIL and its representatives in the context of their work or by third parties.
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INFORMATION WE COLLECT
Personal information is that which concerns a natural person and which allows, directly or indirectly, to identify him or her. As part of our commercial practice, we may collect:
- Your identification information: First and last names, Date of birth, Postal address, Telephone number: home, cell and office, Email address, Social insurance number, national identification number, Copy of identity documents, including a copy of your driving license and passport;
- Your current and previous professional information: the jobs, activities and background of the persons concerned for the purposes of the residence or immigration application or any financial product offered;
- Your financial information: copy of bank statements, account numbers, proof of net assets, monthly securities brokerage account statements, tax returns;
- Contact information.
Only personal information necessary to achieve a specific objective identified in connection with our mission may be collected, even if the person concerned consents. Consent is given expressly when it concerns sensitive information and when the request is made in writing, it is presented separately from any other information communicated to the person concerned.
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THE PURPOSES OF THE COLLECTION
We request personal information from you for the following purposes, as well as other purposes permitted by law:
- Establish and confirm your identity,
- Communicate with you,
- Provide and manage the products and services you request from us,
- Understand your financial service needs,
- Determine your eligibility in order to recommend financial products and services adapted to your situation,
- Offer the job and keep the person employed,
- Obtain services and maintain relationships with partners, issue invoices, administer accounts, process payments and fulfill contractual obligations, including with banking institutions in the context of direct debit,
- To borrow on behalf of clients from a financial institution to make the eligible investment,
- For SFIL’s internal needs, including to manage its relationships with our employees, our job candidates, our partners and third parties who perform mandates, contracts or services for us,
- To manage finances: accounting of transactions, collection of income or disbursements of expenses,
- Ensure the proper functioning of SFIL products and services,
- Ensure that the brokerage accounts of employees and companies of the group do not carry out transactions or operations which are prohibited by the OCRI or which could indicate conflicts of interest,
- Improve the Site and better meet your needs,
- Answer any questions you may have,
- Collaborate with regulatory bodies,
including the OCRI and the Quebec Bar, - Meet the requirements of provincial legislation regarding the protection of personal information.
- Represent investor clients before the Ministry of Immigration, Francisation and Integration (“MIFI”).
SFIL ensures that personal information is only used for the purposes for which it was collected, for compatible purposes or when the use is clearly for the benefit of the person concerned.
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CONNECTION COOKIES (COOKIES)
We use cookies to help you navigate efficiently and perform certain functions. You will find detailed information about all cookies under each consent category below.
The cookies that are categorized as “Necessary” are stored on your browser as they are essential for enabling the basic functionalities of the site.
We also use third-party cookies that help us analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you. These cookies will only be stored in your browser with your prior consent.
You can choose to enable or disable some or all of these cookies but disabling some of them may affect your browsing experience. -
SAFETY MEASURES
SFIL applies very strict security measures to protect your personal information against any unauthorized access, use, communication, modification, loss, theft, or any other breach of information security. The information collected is protected by reasonable computer security measures given its sensitivity.
We have various cybersecurity systems in place to protect your information electronically and keep physical copies under lock and key in our office. Physical and material security measures include:
- offices with controlled access and locked filing cabinets,
- access cards,
- a classification of personal information making it easier to find,
- restricting access to your personal information to only those who need to have access to it in the context of their duties,
- signature of confidentiality commitment by employees with access to personal information,
written contractual obligations with third parties who must have access to your personal information, requiring them to protect, through security measures, the confidentiality and security of your personal information and to use it only for the purposes of the contract, of the mandate or service they perform.
IT security measures include:
- the use of passwords and firewalls,
- restricted access to our data processing and storage rooms,
- a regular review of our security practices,
- a regular upgrade of our technological system,
- secure network and secure hosting,
- anti-virus software,
- multi-factor authentication via the Financial Markets Authority.
These various security measures are also the subject of various internal training and awareness raising, as needed.
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ACCURACY OF INFORMATION
SFIL ensures that the personal or sensitive information it collects is kept up to date, accurate and complete. To do this, its employees must notably record the last dates on which the information was corrected, modified, added or removed.
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RETENTION OF PERSONAL INFORMATION
Personal or sensitive information is securely destroyed when the purpose for which it was collected has been fulfilled or anonymized in order to be used for serious and legitimate purposes, all in accordance with our retention schedule.
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RIGHTS OF ACCESS AND RECTIFICATION
Any person concerned by personal information may have free access to it, within the limits provided by law, and request a copy for a reasonable fee of which they are informed in advance. It may also request that inaccurate, incomplete, ambiguous or unauthorized personal information be rectified by law.
To exercise the rights of access and rectification, the person concerned must prove their identity as a person concerned. The request must be sent to the Personal Information Protection Officer by email or by post to the contact details listed in article 14 of the Policy.
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COMMUNICATION OF PERSONAL INFORMATION TO THIRD PARTIES
SFIL employees may have access to personal information held by SFIL, if this is necessary to carry out their duties.
Any communication of personal information to a third party generally requires the consent of the individuals concerned. SFIL may, however, communicate personal information, without the consent of the persons concerned, in particular to its agents, consultants, external auditors, tax specialists, financial institutions, immigration agents, to the MIFI, to the Canadian Investment Regulatory Organization, to officials and service providers who need this information as part of their mandate or contract.
Any communication of personal information without the consent of the persons concerned must be subject to specific approval of SFIL’s personal information protection manager.
SFIL may thus communicate to third parties the personal information it holds when this is necessary for the exercise of a mandate or the execution of a contract to:
- Commercial partners and third parties with whom SFIL maintains relationships to offer you products and services (including software designers providing data processing and document management services), as well as financial institutions for obtaining a loan to make an eligible investment,
- A financial institution, confidentially and only as part of the transfer of a right to receive, make a payment or allow us to offer you the products and services requested,
When personal information is communicated within the framework of a mandate or a service or business contract, SFIL ensures that the following conditions are respected:
- The mandate or contract is given in writing;
- This mandate or contract must at least provide: (a) the measures that the third party must take to ensure the protection of the confidential nature of the information entrusted to it, (b) that the personal information entrusted to the third party is only used in the exercise of its mandate or the execution of its contract, (c) that the third party undertakes not to retain the personal information entrusted by SFIL after the end of its mandate or its contract, (d) that the third party undertakes to notify the person responsible for the protection of personal information of SFIL of any violation or attempted violation of the confidentiality obligations incumbent on him and (e) that the third party undertakes to allow the person responsible for the protection of personal information of SFIL to carry out any verification relating to this confidentiality.
It is possible that your personal information will be communicated outside Quebec as part of our activities. These cases are limited and are mainly used to pay immigration agents located outside of Canada.
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WITHDRAWAL OF CONSENT
You can modify or withdraw your consent to the collection, use and communication of personal information concerning you at any time by sending a written notice to the person responsible for access and protection of personal information. You understand that certain features of the Site or certain of our products and services may no longer be accessible or will be restricted following the withdrawal of your consent relating to this Policy.
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PRIVACY FACTOR ASSESSMENT (PIA)
SFIL carries out an EFVP of the persons concerned, in particular before undertaking any acquisition, development and overhaul project of its IT system involving personal information and before communicating personal information to an outside person or organization. of the province.
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CONTACT DETAILS OF THE PERSONAL INFORMATION CONTROLLER AND HANDLING OF COMPLAINTS
Any person affected by personal information collected, used, communicated or retained by SFIL may file a complaint with the Personal Information Protection Manager in the event of failure to comply with the obligations provided for in the Policy. The complaint must indicate the nature of the alleged facts, the name of the person(s) involved, the date on which the incident occurred, as well as the expectations regarding the outcome of the complaint.
SFIL reviews all privacy-related complaints and takes appropriate action to resolve them.
Marie-France Leduc
Responsible for the protection of personal information,
4150 Sainte-Catherine West, Suite 328, H3Z 2Y5, Westmount
[email protected]
