Nalmont Capital Privacy Policy
Nalmont Capital Inc. (the “Firm”, “us” or “Nalmont”) is committed to protecting your personal information. The purpose of this Privacy Policy is to explain our practices with respect to the collection, use, store and communication of your personal information.
This Privacy Policy applies when you interact with us or use our website or services, when you consult our written or electronic communications, when you contact us for information or when you provide your personal information to us. It explains how we use, store and communicate the personal information we collect, as well as your rights regarding the personal information we hold regarding you.
Please read this Privacy Policy carefully. By submitting your personal information to us after we present this Privacy Policy to you, we presume that you consent to the collection, use and disclosure of your personal information for necessary purposes as described in this Privacy Policy, as revised from time to time.
Should you have any questions or concerns in connection with these policies contact The Privacy Officer as listed in the “Contact Us” section.
What is Personal Information?
“Personal information” is information that directly or indirectly identifies an individual. This information may include your name, mailing address, e-mail address and telephone number.
Personal information is sensitive when it gives rise to a reasonable expectation of privacy, for example, your personal financial information.
How does Nalmont Collect my Personal Information?
Normally, we collect your personal information directly from you. In particular, we collect it using the following means:
- When you communicate with us by phone, email or by contact forms available on our website;
- When you voluntarily provide us with it, for example, when you submit a subscription form;
- When you request documents from us; and
- When you enter into a commercial or investment relationship with us.
What Personal Information does Nalmont Collect?
We only collect the personal information that we require to offer you our products and services. As such, we may collect the following information for these necessary purposes:
- To provide you with the services, support and information you request as a visitor to our website:
- First and last name
- Email address
- Information provided when communicating with us (for example, your telephone number)
- Usage data
- To provide you with ongoing services, support and information you request as our client:
- First and last name
- Email address
- Personal financial information
- To satisfy our obligations in accordance with legal and industry regulations, including tax reporting:
- First and last name
- Date of birth
- Address
- Social Insurance Number
- To operate, maintain, improve and offer the necessary functionalities of our website:
- IP Address
- Information concerning your device and browser
- Date, time and duration of your visits
- Pages consulted and browsing history
We may also need to collect your personal information in order to:
- Prevent cyberthreats and fraud.
- Respond to requests, warrants and orders from courts and other bodies.
- Protect your rights and interests as well as our own.
- Collaborate in legal proceedings or investigations.
To Whom is my Personal Information Communicated?
Nalmont may, from time to time, disclose your personal information to external sources such as credit agencies, other financial institutions and other parties who provide services to the Firm, such as IT partners, data management service providers, auditors, lawyers, etc. We may also rely on external sources, such as credit agencies, to collect personal information about you.
In particular, we require that external sources maintain the confidentiality of your personal information and keep your personal information secure. We also require that they only use your personal information for the limited purposes for which it is provided.
When our external sources no longer need your personal information for those limited purposes, we require that they dispose of it. We do not authorize external sources to disclose your personal information to unauthorized parties or to use your personal data for their direct marketing purposes.
If we otherwise intend to disclose your personal information to an external source, we will identify that source and the purpose of the disclosure and obtain your consent where required by law.
In the event of a change of ownership, sale, amalgamation, liquidation, reorganization or acquisition of Nalmont, in whole or in part, your personal information may be transferred as part of the transaction, in accordance with applicable legal requirements.
In certain situations, your personal information may be collected, used or disclosed by us without your consent. These situations include: collection and use of publicly available information specified by regulation; disclosure to legal counsel for the purposes of obtaining advice; collection or use that is clearly in your interests in situations that we cannot obtain your consent in a timely way; use and disclosure to investigate a breach of an agreement or a contravention of a law; disclosure for the collection of a debt that you owe to us; use and disclosure in an emergency that threatens your life, health or security; disclosure to comply with a subpoena, warrant or court order, or to otherwise comply with applicable law, including securities regulatory authorities.
What Rights Do I Have Regarding my Personal Information?
You have the following rights regarding the personal information we hold regarding you:
- Access: You may request access to the personal information we hold regarding you.
- Rectification: You may request that your personal information be corrected or, in certain circumstances, deleted.
- Withdrawal of Consent: You may withdraw your consent to the use or communication of your personal information at any time by contacting us using the contact details provided in the “Contact Us” section below. However, before implementing the withdrawal of your consent, we may require proof of your identity. Please be aware that withdrawing your consent in certain circumstances may cause us by regulation, to be unable to administer your account, or we may no longer be able to provide you with certain products or services.
- In certain circumstances and Canadian jurisdictions, you may have a right to the portability of your personal information collected by us. Please contact our Privacy Officer for more information about your right.
How Long is my Personal Information Kept?
We retain your personal information for as long as necessary to fulfill the purposes for which we collect it, as demanded by regulatory requirements, or for other legitimate purposes such as data recovery, dispute resolution or respecting contractual obligations.
How is my Personal Information Kept Safe?
We have implemented physical, organizational, contractual and technological security measures to protect your personal information and other data from loss or theft, unauthorized access, disclosure, copying, use, or disclosure and modification, such as:
- physical measures (e.g., locked filing cabinets and restricted access to offices);
- organizational measures (e.g., security clearances and limiting access on a “need-to-know” basis); and
- technological measures (e.g., the use of passwords and encryption).
We have taken actions to ensure that only Nalmont’s employees who need to access your personal information in the course of their duties have access to it.
Despite these measures, no method of information transmission or information storage is 100% secure or error free, and we cannot guarantee security. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any information that you provided to us has been compromised), please contact us immediately.
Where is my Personal Information Kept?
Your personal information is currently stored in the province of Québec Canada. For Quebec residents, it is possible that your personal information will be communicated outside Quebec. If need be, it may be stored and processed in any country in which we use third-party service providers, such as France. In the latter case, your personal information may be transferred to countries outside your country of residence, which may have different privacy rules than your country. While this personal information is outside your country, it is subject to the laws of the country in which it is located and may be disclosed to governments, courts or law enforcement or regulatory agencies of that other country and in accordance with the laws of that other country. However, our practices regarding your personal information will at all times be governed by this Policy.
Contact Us
If you have any questions about how Nalmont collects, uses or communicates your personal information or to exercise your rights, please contact the Privacy Officer at: privacy@nalmontcapital.com
Our Privacy Officer is responsible for responding to requests for access or rectification, information and any complaints you may have regarding our practices with respect to your personal information.
Update
We will update this Policy from time to time to reflect the changes in our practices, our technology, our legal obligations and other factors. If we make major changes to this policy, for example, to comply with new legal requirements, we will notify you 30 days in advance so that you can make an informed choice about your use of our services.
Nalmont encourages you to periodically review this policy for any changes. Any changes will be effective upon posting of the revised privacy policy, and your continued use of this website will be subject to the privacy policy then in effect.
Last Update: October 2024