Privacy Policy

1. Welcome

Welcome to the Privacy Policy for https://capintel.com/ (or the “Site”), operated by CapIntel Inc. (hereafter referred to as “CapIntel”, “we”, “us”, and “our”). Your privacy is very important to us. This Privacy Policy explains how CapIntel collects, uses and discloses personal information with respect to your use of and interactions with Site and our portfolio and fund comparison services (the “Services”) and through other interactions with us.

We may change certain parts of this Privacy Policy from time to time, so be sure to check this Privacy Policy regularly. We will indicate at the top of this Privacy Policy when it was most recently updated.

2. How do you collect personal information?

We collect personal information from you when you provide information directly to us, for example, when you contact us, register an account, purchase Services, run reports or make inquiries to our webmaster.

We may also collect personal information indirectly from third parties, such as service providers who process payments related to your subscription for our Services.

As set out below, we also collect personal information of your clients that you provide to us or authorize us to collect in order to provide the Services (“Third Party Data”).

3. What kind of personal information do you collect and how do you use it?

We collect and use personal information for the following purposes:

Information we collect and use when we provide Services to our customers:

• Third Party (Retail Client) Data – We collect personal information about our customers’ retail clients in order to provide the Services, including to prepare and send investment comparison proposals, reports and related information to our customers and their clients. This information may include client first and last name, the client’s investment holdings and any other information provided by our customers that may be relevant to our provision of the Services. Third Party Data is stored by us and our service providers on servers located in Canada. Our customers are responsible for providing all necessary notices, obtaining all necessary consents and otherwise complying with applicable privacy laws with respect to the collection, transfer and use of Third Party Data by us to provide the Services.
• Registering and Administering your Account – When you create an account with us, we require certain information, including your first and last name, business email address, company name, company mailing address and a password that you create. We use this information to create and administer your account, including to communicate with you about your account. We may also collect your photograph if you wish to include it on your proposals. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.
• Enforcing our Agreements: We may monitor use of the Service by our customers’ employees or other authorized users for the purposes of detecting fraud, enforcing our Terms of Use, enforcing the terms of our agreements, or as otherwise required or permitted by applicable laws.
• Understanding our Customers and Enhancing our Services – We may generate aggregated, non-identifiable data and use such information to monitor and improve the Services and to help us determine what types of products and services are best suited to our customers. We may also generate and share aggregated insights with our customers (for example, most searched funds across our platform).
• Support Services: We may collect and use certain information (such as name, business email address, business phone number and query, usage information) when we provide support services to our customers by phone, email or within the Services, and as otherwise required to administer, troubleshoot, enhance and manage our Services.

Information we collect and use through our website and other interactions:

• Visiting the Site: You do not have to register to visit our Site, however, we collect certain personal information when you visit our Site. Please see ‘Do you automatically collect technical data, and why?’ below for detailed information regarding the personal information we collect when you visit our Site, and the choices you have with regards to that collection.
• Marketing Communications: We may offer you the ability to sign-up to receive marketing and promotional communications from us, sign-up for a webinar or download a report, publication or other resources, in which case we collect certain information (such as first and last name, business name, business email address or business phone number). We use this information to send you the communications you have requested to receive. You can unsubscribe from our email communications at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the ‘Contact Us and Product Support’ section below. Please note that you may continue to receive transactional or account-related communications from us.
• When you Contact Us – When you contact us with a comment, question, feedback or complaint, you may be asked for information that identifies you, such as your name, mailing address, email address or telephone number, along with additional information we need to help us promptly answer your question or respond to your complaint. We may retain this information to assist you in the future and to improve our customer service and service offerings.
• Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our Site.
• Employment: If you apply for a job with us, we may collect certain personal information about you (such as information that would be contained in a resume, cover letter, or other employment-related materials). We use this information for the purpose of processing, evaluating and responding to your application.

4. Do you automatically collect technical data, and why?

Like many websites, we automatically collect technical data when you visit and use our Site.

IP Addresses and similar data: We may collect your IP address when you visit our Site to help us diagnose problems with our main computers, to administer the Site and system, to report aggregated information to our customers, and to audit the use of our Site. In limited circumstances, we may use IP addresses to help us verify that you are eligible to obtain the Services and, where we feel it is necessary to enforce compliance with our Terms of Use or to protect our Services, Site, users, customers, Site visitors or others. We also collect related information such as page requests, browser type, operating system and average time spent on our Site. We use this information to help us understand our Site activity and to monitor and improve our Site and Services

Cookies and similar technologies: We use “cookies”, scripts, pixel tags, etags, web beacons and other similar technologies on certain pages of our Site. These automatically collect data from a Visitor and transfer this information to the Visitor’s hard drive. Cookies help us recognize repeat Visitors, personalize the Site and communications and tailor content to match particular interests. We also use these technologies to track Site usage trends and patterns.

• Opt out of cookies. You are always free to set your browser to notify you when you receive a cookie or to decline cookies and you can delete them from your computer. If you decline “cookies” or delete them from your computer, you will still be able to access our Site, but you may find that some areas do not work as smoothly as when cookies are enabled on your system.

Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Site (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Site. These third parties may use cookies and other tracking technologies. For more information about Google Analytics or to prevent the storage and processing of this data (including your IP address) by Google, you can download and install the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can also obtain additional information on Google Analytics’ data privacy and security at the following links:

• https://policies.google.com/technologies/partner-sites and
• https://support.google.com/analytics/topic/2919631

5. Do you share personal information?

As a matter of practice, we do not disclose, trade, rent, sell or otherwise transfer Third Party Data, except as set out in this policy or in our agreements with our customers.

Service Providers: We may share personal information with third party service providers who assist us in providing and administering the Site and our Services. Third parties may assist us with services such as processing payments, data hosting, sending communications, and providing marketing, analytics and advertising services. These third parties that process personal information on our behalf are contractually obligated to safeguard information and only use the information provided to them for the purposes outlined in this Privacy Policy. Our service providers may be located in Canada, the United States or other jurisdictions; however, Third Party Data is never handled by service providers outside of Canada.

Partners: It is possible CapIntel (including its present or future subsidiaries, joint ventures or any combination therefore) may transfer or assign personal information as a result of, or in connection with a proposed or completed merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, liquidation or other business transaction.

Legal and Compliance: We and our Canadian, U.S. and other foreign service providers may disclose personal information to government, regulatory and/or law enforcement agencies (i) in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of detecting, suppressing or preventing fraud, (ii) if we believe the disclosure is legally required, appropriate in connection with an investigation of improper or illegal conduct in connection with our Site and Services, or (iii) as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities. Personal information may also be disclosed when necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

6. Other websites and your information

Our Site may be linked from another website, or have links to other websites such as social media platforms. These links are not intended as an endorsement of or referral to the linked websites. This Privacy Policy only relates to our collection and use of personal information and we are not responsible for the privacy policies and practices of other third party websites, including from any provided links. If you would like information on any other party’s privacy policy, you should contact that party directly, and we encourage you to do so.

7. Security, storage and retention of personal information

CapIntel employs reasonable measures to protect and ensure the security of personal information from unauthorized use, access, disclosure, alteration, destruction or loss.

We retain personal information for as long as necessary or relevant for the listed purposes in this Privacy Policy, or as required to meet any applicable legal and retention obligations and, with respect to Third Party Data, in accordance with our agreements with you.

8. How you can access, update and modify your information

If we receive a request from an individual to access or update personal information we maintain on behalf of a customer, we will direct that individual to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

If you have created a CapIntel account, you can also update or make changes to certain personal information by logging into your account.

9. How to opt-out of receiving promotional communications

In the event you wish to unsubscribe from receiving promotional email communications from CapIntel, you may opt-out by:

• Removing yourself by clicking “unsubscribe” at the bottom of an email we send you,
• Informing an agent who has contacted you by phone that you wish to unsubscribe, or
• Contact us at: support@capintel.com or as set out below.

If you opt-out of receiving marketing-related emails communications from us, we may still send you important transactional and administrative messages, such as notifications regarding your account or subscription to our Services, or as otherwise consistent with applicable law.

You may also contact us at support@capintel.com to opt-out of the sharing of your information with business partners for marketing purposes.

10. Contact Us and Product Support

To contact us with questions about this Privacy Policy, the treatment of personal information by us or our service providers or other product inquiries, send us an email at privacy@capintel.com and write “Privacy Policy” in the subject line.

Still Need Help? You may contact us at any of the following:

Mailing Address

Chief Technology Officer

140 Yonge Street, Suite 200

Toronto, ON

M5C 1X6

Email

support@capintel.com

If you have any questions regarding the personal information we process on behalf of one of our customers, we encourage you to first contact the customer directly and/or review their applicable privacy policy. If you signed-up to receive marketing communications from one of our customers and now wish to unsubscribe, please contact the customer directly.

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