Forthlane Partners Inc. (“Forthlane”, “we”, “us”, “our”) is committed to safeguarding the personal information we collect, use and disclose in the course of operating our business, in accordance with the laws and regulations under applicable privacy legislation in Canada.
This Privacy Statement sets out in general terms how we collect, use, disclose and protect the personal information of our clients, other individuals and our website users (“you”). By providing personal information to us (whether via our website, client portal, by email, in person or over the phone), you agree to the practices set out in this Privacy Statement.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the bottom of this page. We encourage you to review this Privacy Statement whenever you visit our website to stay informed of how we are processing personal information.
Under applicable privacy legislation, Forthlane is responsible for the personal information in our possession or control. This includes personal information we receive directly, such as from individual clients or other individuals, and personal information we receive indirectly from clients or others. This Privacy Statement does not apply to, and Forthlane is not responsible for, any third-party websites which may be accessible through links from our website. If you follow a link to any of these third-party websites, they will have their own privacy policies. You should review these policies before you submit any personal information to such third-party websites
1. What is personal information?
Canadian privacy legislation defines “personal information” broadly as any information about an identifiable individual. In general, personal information does not include any information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, title or position, employer, business telephone number or business e-mail address.
2. What personal information do we collect?
We collect personal information by fair and lawful means and, wherever appropriate, directly from the individual. In the course of operating our business, we may collect and process different types of personal information. Such personal information may include:
contact information (e.g. name, email address and telephone number);
marketing information (e.g. meal preferences, event feedback and survey responses);
financial information (e.g. bank account or asset portfolio information);
recruitment information (e.g. education and employment history or details of professional memberships);
client identification verification information (e.g. passport number or evidence of beneficial ownership);
special categories of personal information (e.g. ethnic origin, political opinions or religious beliefs); and
any other personal information provided.
When an individual visits our website, we may use a browser feature called a ‘cookie’ to collect information about such visit, including information about the duration of the visit, pages viewed, operating system the visitor uses and the domain name of the website from which the visitor came. A cookie is a small data file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. We will not be able to identify individual visitors unless a visitor specifically informs us of his or her identify by submitting personally identifying information, such as by registering for a mailing list or sending us correspondence from the website. We may use information collected by cookies for the purpose of: (i) tailoring content that we share with you; (ii) to authenticate you, enable access to information and otherwise administer the website and (iii) for analytical purposes to better understand digital interactions with Forthlane. Visitors can reset their browsers to notify them when they have received a cookie or to refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
We do not knowingly collect information from children or other persons who are under 16 years old.
3. How do we use personal information?
Forthlane collects, uses and discloses personal information for the primary purpose of operating our business and providing clients with wealth management services and other related services, including for the following purposes (the “Purposes”):
to establish and manage client relationships, including performing services and carrying out obligations under any agreements between you and us;
to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, process payments and evaluate credit standing;
to contact and communicate with clients and other individuals to better understand our service and marketing requirements;
to distribute our publications and invitations to events to individuals who have consented to receiving these;
for recruitment purposes to consider the hiring of individuals as employees or consultants of Forthlane;
to facilitate the use of our website and respond to respond to requests for information from visitors to our website;
to develop and manage our business, operations and service offerings;
to maintain, develop and manage our document management systems and databases; and
as permitted by, and to comply with, applicable legal or regulatory requirements such as anti-money laundering laws.
4. With whom do we share your personal information?
Forthlane will not share your personal information with third parties other than in the following circumstances or for the following purposes:
in connection with normal business operations to open, maintain, administer or service client accounts, including without limitation the provision of services to clients (including by third-party service providers who provide website, hosting, maintenance and other services to us) and the provision of back office administrative services;
to legal counsel for the purpose of obtaining legal advice;
to any law enforcement agency or other governmental agency, if required to do so by law or in the good faith belief that such action is necessary to comply with applicable laws; or
in the event of an acquisition, merger, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
5. When and how do we obtain your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.
6. How do we ensure the privacy of your Personal Information when dealing with third parties?
To the extent we enter into arrangements with service providers, agents and contractors who we have engaged to store, handle or process personal information on our behalf, we will require such third-party services providers – by contractual or other means – to observe the intent of this Privacy Statement and provide comparable privacy protection while the information is processed or handled by them. Such service providers only receive information that is reasonably necessary for them to perform their functions.
7. How long and where do we keep personal information?
We will only keep personal information for as long as reasonably necessary to fulfill the relevant purposes set out in this Privacy Statement and in order to comply with our legal and regulatory obligations.
We will keep the personal information that we collect at our head office in Toronto, Ontario or the data servers of our service providers within Canada and the United States.
8. How can you review your Personal Information that we have collected, utilized or disclosed?
If you wish to request access to your personal information in custody or control of Forthlane, please make your request in writing to our Privacy Officer at the address listed in Section 14 below. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your personal information. Any such identifying information shall be used only for this purpose. In some circumstances, we may not provide access to your personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information or if it is otherwise not properly the subject of an access request.
9. How do you know that the Personal Information we have on you is accurate?
We will attempt to ensure that your personal information is kept as accurate, complete and up-to-date as possible. We will not routinely update your personal information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your personal information, when required.
10. What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information.
11. How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner in respect of this time limit.
12. Are there any costs to you for requesting information about your Personal Information or our privacy practices?
We will not charge any costs for you to access your personal information in our records without first providing you with an estimate of the approximate costs, if any.
13. What safeguards have we implemented to protect your Personal Information?
We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate physical, organizational, contractual and technological safeguards in an effort to protect your personal information from loss or theft, unauthorized access, disclosure, copying, use or modification. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit or provide to us, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards. If you believe personal information has been compromised, please contact our Privacy Officer at the address listed in Section 14 below.
14. How do you contact us regarding access to your personal information or our privacy practices?
All comments or questions about our privacy practices should be forwarded to our Privacy Officer as follows:
Attn: Privacy Officer
Forthlane Partners Inc.
145 Adelaide St. West, 2nd Floor
By e-mail: email@example.com
Updated: May 8, 2019