Confidentiality and privacy policy

October 2025

 

Table of contents

  1. Why a privacy policy?
  2. What type of information we may collect and from whom

2.1. What information can we collect.

2.2. From whom we may collect your information.

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

3.1 How we use and disclose your information.

3.2. To whom we may disclose your information.

3.3. Service providers.

  1. When do we need your consent?
  2. What your rights are and how to exercise them.

5.1. Right to accept or refuse to provide your information.

5.2. Right to access your information.

5.3. Right to have your information corrected.

  1. What security measures we use to store your information.

6.1. Shelf life.

6.2. Storage locations.

6.3. Information security program.

  1. How can we change this policy.
  2. In the event of a breach of confidentiality of personal data.
  3. How to reach us with a question, comment or complaint.

 

 

1. Why a privacy policy?

The personal information (hereinafter referred to as "information") you entrust to us is essential to the performance of our various mandates (accounting, insurance, investments). It is therefore very important, and we do everything in our power to protect it.

The following procedure describes the firm's practices to protect your information and privacy. We want to do our job as transparently as possible.

This policy applies to the collection, use and retention of any information you entrust to us in the course of our business relationship. This policy applies from the moment we collect your information and does not have an expiration date.

The Privacy Officer is responsible for implementing this policy. If you have any questions about this policy, please contact us at our e-mail address: info@monetori.ca

 

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

2.1. What information we may collect

 

  • Names
  • Date of birth
  • Civil status
  • Contact
  • E-mail address
  • Information on identification (driver's license, passport, social insurance number)
  • Jobs
  • Information we hold about you as an authorized representative or director.
  • Any financial information required to carry out the mandate
  • Income, wages and balances
  • Products and investments and their terms and conditions (e.g. term, repayment frequency, limits, rates, maturity, etc.).
  • Insurance policies (life, disability, critical illness)
  • Financial loans and their terms and conditions (e.g. term, repayment frequency, limits, rates, maturity, etc.).
  • Credit reports and ratings
  • Professional and financial background

 

  • Other information
  • Why you do business with us
  • Language and communication preferences
  • Information about people other than yourself (power of attorney, beneficiaries, your spouse or common-law partner or dependents, an authorized user of your file) *.

*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.

2.2. From whom we may collect your information

We may collect your information from you or from an authorized person on file.

We may also collect your information indirectly and from sources, your consent will be required for the collection of information through the following sources:

  • Financial or lending institutions, insurers (when we need to verify the accuracy of the information provided)
  • Government institutions, such as Revenu Québec and the Canada Revenue Agency
  • Brokers or others involved in securities or other transactions
  • Credit reporting and assessment agencies
  • Publicly available sources or registers
  • Regulatory and self-regulatory bodies

 

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:

  • Update your information;
  • Assess your financial situation and creditworthiness;
  • Personalize your customer experience, get to know you better and understand your needs;
  • Target and personalize the services that might interest you and suit your situation;
  • To enable due diligence on our operations in preparation for the conclusion of a business transaction;
  • Use and disclose certain information where required by law (see section 4).

 

3.2. Who we may share your information with

Sometimes it may be necessary to share your information with others. This may be required by law or to prevent fraud. In all cases, we are committed to limiting the information we share with others and to obtaining your consent if necessary.

We ensure the integrity, security and confidentiality of your information. Under no circumstances do we sell customer lists to third parties.

We may share your information with :

  • A person acting on your behalf or at your request, such as a broker or securities transfer agent;
  • A financial institution, lender, credit insurer or credit reporting agency;
  • An insurer or agent acting on our behalf;
  • A merchant, a partner with whom we do business to offer optional products and services, a payment system, a payment card network, a clearing or settlement system;
  • 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 the conclusion of a commercial transaction;
  • As described below, the service providers we use to perform certain tasks.

3.3. Service providers

Our service providers are carefully selected. Here are the categories they fall into:

  • Technology services (applications, data center, data storage and backup, hosting services, maintenance and support services);
  • Professional services;
  • Financial services and banking;
  • Insurance 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 that we offer.

4. When do we need your consent?

We obtain your consent at the very beginning of our business relationship through the start-up meeting. This consent will remain valid throughout our business relationship (accounting and/or insurance and/or investments).

We will not ask for your consent in certain situations provided for by law:

  • When you have to comply with a court order or other binding request;
  • When investigating a breach of contract or law;
  • When the firm wants to 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 is confidential and part of your private life. You may, at any time, withdraw your consent to the collection, use or disclosure of this information. Simply contact us in writing, indicating your refusal.

However, in order to serve you, certain information is essential. Without this information, it may be difficult, if not impossible, for us to provide you with the service you require.

5.2. Right to access your information

You may ask to see the information we hold about you at any time, except where the law places certain limits on the request.

To view your information, simply contact us directly by e-mail or telephone.

 

5.3. Right to have your information corrected

In order to offer you quality service, it is essential that your information be complete and up-to-date. We rely on you to contact the person in charge of your file to advise them of any changes.

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

6.1. Shelf life

 

Accounting

Members of the Ordre des CPA du Québec et du Canada are subject to numerous legal obligations regarding the retention of their clients' personal information (for example, under banking, tax and anti-money laundering laws).

In order to meet these obligations, information relating to your file will be kept for the duration of your relationship with the firm and for a period of seven years following the end of that relationship.

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

Investments

Members of the Investment Industry Regulatory Organization of Canada (IIROC) are also subject to numerous legal obligations regarding the retention of their clients' personal information.

To meet these obligations, personal information is retained only as long as necessary for regulatory purposes or as required by law.

 

Insurance

All representatives who are members of the Chambre de la sécurité financière (CSF) are required to maintain the confidentiality of personal information they collect as representatives, on behalf of their firm, in the course of their practice.

In order to meet these obligations, information relating to customer files and the documents used to create them must be kept ... for a minimum period of five (5) years following the latest of these three events:

  • definitive closure of the customer's file;
  • the date of the last service rendered to the customer; or
  • expiry without renewal or replacement of the last product sold to the customer.

6.2. Conservation sites

Your information will be stored in digital format. The firm stores all your files and documents in the Microsoft Azure digital environment (Azure Storage), which offers advanced security features and meets compliance standards such as CSA STAR, ISO, SOC, PCI DSS, HITRUST, FedRAMP, DoD and others. Data provided via the mobile application is stored in a cloud environment, namely Google cloud, in a data center located here in Montreal.

6.3. Information Security Program

Protecting your information is one of our top priorities. That's why we have procedures in place to protect your information from loss, theft, unauthorized access, use or disclosure.

A security program is in place to monitor potential threats to information security.

 

  • We limit who has access to your information; only employees and subcontractors working on the file have access;
  • We protect access to our software with :
    • unique passwords
    • double authentication for each employee and
    • firewalls;

7. How to modify this policy

This policy is subject to change. In the event of policy modification, a mention will be made on our website.

 

8. In the event of a breach of confidentiality of personal data

In the event of a breach of confidentiality, the Commission and the individual(s) concerned will be notified.

The incident is assessed to determine whether it could cause serious harm to those involved. Measures are then put in place to reduce the risks and prevent similar incidents in the future.

All this is, of course, recorded in the register of privacy incidents.

 

 

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

If you have a question, comment or complaint, please contact the firm or the person in charge using one of the following methods:

  • Send an e-mail to info@monetori.ca
  • Call our reception desk;

To file a complaint, please send us a written document either to our e-mail address.