Lapointe Financial Group (Lapointe Financial Group Inc.) acts as an intermediary, either between life and health insurers and independent advisors or between mutual funds (mutual fund companies) and mutual fund dealer representatives who are attached to Lapointe Financial Group Inc.
In carrying out its responsibilities, Lapointe Financial Group must collect, through representatives or advisors, personal and confidential information relating to their clients that is necessary for the performance of its tasks.
Lapointe Financial Group is committed to protecting the personal information collected from clients. This policy explains the collection, use and disclosure practices of personal information with respect to customers, as well as the measures adopted to ensure that it is treated appropriately.
The policies and practices we have put in place have been developed based on their compliance with the principles set out in the laws applicable in Quebec to ensure the protection of personal information and its confidentiality. More specifically, the Act respecting the protection of personal information in the private sector (QSR Chapter P-39.1) is applicable, as well as the related regulations, and Lapointe Financial Group is committed to respecting these principles.
The term "personal information" means:
Personal information is any information that concerns a physical person and makes it possible to identify them. So this definition refers to any information that would identify you such as: your name, address, telephone number, e-mail address, fax number or any other information that can be used to communicate with you as well as financial information about you or your spouse, information related to your occupation and that of your spouse as well as information concerning your credit, your financial instructions or health.
This concept does not apply to information relating to companies and other legal persons.
A. INFORMATION COLLECTED
We collect personal information in accordance with applicable laws and in an ethical manner. We only collect information that is necessary and useful, directly or indirectly, to perform our duties in order to enable us to perform our duties and responsibilities.
B. 10 PRIVACY PRINCIPLES
PRINCIPLE 1: OUR RESPONSIBILITY TO THE CLIENT
We are responsible for all personal information under our control, including all information entrusted to a third party for processing, storage or other purposes.
Accordingly, we are required to protect the confidentiality of the personal information to which we have access.
Our policies and procedures for protecting this information are strict and we have designated individuals to ensure compliance with these policies and procedures.
All our employees have adhered, as a condition of employment, to ethical principles, one of the fundamental principles of which is to maintain at all times the confidentiality, security and privacy of the information in each client's files.
Also, on an ongoing basis, we ensure that our staff receive adequate and relevant training and that they are regularly informed of changes to our company's procedures regarding the management and protection of your personal information.
PRINCIPLE 2: IDENTIFYING PURPOSES FOR COLLECTING INFORMATION
When you deal with one of our advisors (in insurance of persons) or one of our dealer representatives (mutual fund), they ask you for personal information for various purposes:
- To verify your identity and prevent fraud;
- To ensure that you fully understand your financial services needs;
- To check if a product or service is suitable for you;
- To establish your eligibility for products or services in order to offer them to you;
- To register for and administer any product or service you have requested;
- And finally, to meet the requirements of legislation or regulation.
PRINCIPLE 3: YOUR CONSENT
When opening a mutual fund account or signing a life and health insurance proposal, by signing the appropriate documents, you certify that you consent to the collection, use and disclosure of personal information.
It is your right, if you so wish, to object to the collection, use and disclosure of your personal information. You may also withdraw your consent at any time thereafter, subject to legal or contract restrictions and reasonable notice. In many cases, the collection, use and disclosure of personal information is necessary for the proper management or administration of your records or for the provision of ongoing services related to your file. In these circumstances, you should be aware that we may be forced to close your file or stop offering you a product or service.
You may terminate your consent at any time if:
- you give reasonable notice in writing to that effect;
- we are not legally required to obtain, use or disclose personal information;
- this does not prevent us from performing our contract to which we have committed ourselves to you;
PRINCIPLE 4: LIMITING THE COLLECTION OF YOUR PERSONAL INFORMATION
We only collect the information that is necessary and necessary to process your file. We may ask you for the following information:
- Social Insurance Number (SIN) – For tax and other government purposes, including opening an income-generating account and a registered retirement income investment, in order to meet the requirements of the Canada Revenue Agency. We may use your SIN for administrative purposes, such as to match your personal information, or as an internal identification number to distinguish you from customers who have a name similar to yours.
- Financial Information – To ensure that the advice we offer you and the investments you purchase are right for you so that you get to know you well.
- Health Information – To determine your eligibility for certain insurance products. - Contact information – For example your name, address, telephone number or email address.
- In some cases, you may decide not to give us certain information. However, in such a case, we may not be able to provide you with the product, service or information you request in cases where applicable law requires us to obtain such information.
PRINCIPLE 5: LIMITING USE, DISCLOSURE AND RETENTION
Your personal information must not be used or disclosed for purposes other than those for which it was collected, unless you consent or are required by law. We must retain personal information only as long as necessary to fulfill the identified purposes. The destruction of this information is done in a secure manner in order to respect its protection in order to ensure its confidentiality.
Under no consideration and under no circumstances do we sell or give lists of our customers to other companies for their own use.
In order to properly carry out the mandate entrusted to us, we may pass on to third parties the personal information obtained about you, in particular in the following cases:
- we have obtained your consent to this effect;
- we pass on your personal information to any other organization with which we have business relationships in order to comply with and execute your requests;
- a securities regulator or other regulatory body has required it;
- we are required or authorized to do so by law.
We only keep records containing your personal information for as long as it is required for our business relationships, in accordance with our internal document retention policies or legal and regulatory standards. These records will be kept by your advisor or mutual fund dealer with whom you normally do business, by Lapointe Financial Group's Compliance Department or by our service providers.
Rigorous procedures for the retention of your personal information are applied and we will eliminate personal information that Lapointe Financial Group no longer needs for the specified purposes.
We may disclose personal information to legal or regulatory authorities in the event that we suspect money laundering activities, insider trading, manipulative or deceptive business practices or other criminal activities, to detect and prevent fraud or to meet the requirements of legislation or regulation of government bodies, regulators or other self-regulatory organizations. We may also disclose personal information to comply with a legal obligation (for example, court order) or to protect our assets (for example, for the collection of overdue accounts). When we need to share personal information for these reasons, we open a file that specifies what information was disclosed, when, to whom and why.
PRINCIPLE 6: ACCURACY OF YOUR INFORMATION
We are committed to maintaining the accuracy of personal information and ensuring that it is complete and up-to-date. We attempt to take all reasonable steps to maintain their accuracy. If you notice any errors in our data or if your information is changed, you must immediately notify your advisor with whom you are dealing or Lapointe Financial Group so that we can make the necessary changes. We will make the necessary changes to your file if you determine that the personal information it contains is incomplete, inaccurate or ambiguous.
We will do our best to inform those to whom we have provided information of these changes as soon as possible.
If we do not agree to make the changes you request, you can challenge our decision. Please refer to Principle 10 below for information on how to file a complaint.
To access your personal information, to correct personal information, to make a request for information or to make a complaint, please contact us in writing by sending your request to the address set out in Principle 10.
PRINCIPLE 7: OUR PRIORITY: THE SECURITY OF YOUR PERSONAL INFORMATION
We apply very strict security measures to protect your personal information from unauthorized access, regardless of the format in which we hold it. We strive to adapt our security measures to technological advances.
Methods of protection include:
- physical security measures, such as controlled access desks and locked filing cabinets;
- electronic and technical security measures for computerized personal information, such as the use of passwords, database encryption and personal identification numbers;
- organizational processes such as restricting access to your personal information to a selected group of individuals;
- contractual obligations with third parties who must have access to your personal information, obliging them to protect the confidentiality and security of your personal information.
We have established a full range of security controls to protect personal information from unauthorized use, access, modification, copying, destruction and disclosure, and from loss or theft.
On our websites, cookies or other information tracking mechanisms may be used to improve the functionality or security of the sites or to provide the user with a more personalized view of the site. It should be noted that cookies cannot, under any circumstances, access the files or data on your computer.
PRINCIPLE 8: TRANSPARENCY
We need to make available to you information about our policies and practices for managing your personal information.
We may from time to time make changes to our privacy rules or to our measures in place to ensure the security of that information. If necessary, we will inform you, as required by law.
PRINCIPLE 9: YOU HAVE ACCESS TO YOUR PERSONAL INFORMATION
You may have access to your file if you make a written request to the Chief Privacy Officer at Lapointe Financial Group. This right of access and modification includes, among others:
- The right to consult your file free of charge;
- The right to obtain a copy of your file for a reasonable fee;
- The right to have incomplete, inaccurate or equivocal information corrected.
If you want to view or verify personal information or find out who we have disclosed it to, you can ask us to do so. We may ask you for specific information to enable us to search for and provide you with this information. Depending on the nature of your request, you may also have to pay a small reproduction or research fee, but we will notify you first. In some cases, we may not be able to give you certain information we hold about you in accordance with applicable law. Where applicable, we will inform you of the reasons that prevent us from giving you access to this particular information.
PRINCIPLE 10: INQUIRIES AND COMPLAINTS
You may contact us to request information or make a complaint about our privacy policies and practices.
We are committed to responding promptly and accurately to all your questions and concerns regarding the confidentiality and security of your personal information and our privacy policies and procedures.
In the event of a complaint on your part about the exercise of your rights set out in this document, your file will be handled by the office of the person in charge of the protection of personal information at Lapointe Financial Group, who will inform you of the procedure to follow. Each complaint will be investigated. If the latter is justified, the particular situation will be corrected and we will inform you. If the issue raised by your complaint requires a change to our policies and procedures, we will act accordingly.
For any request or complaint, please contact us in writing at the following address:
Lapointe Financial Group Inc,
715 Rue de la Création,
QC, G9B 0Z8