Privacy Policy

Advisor Terminal is responsible for the personal information under its control and has designated a Privacy Officer accountable for our compliance with this Policy and applicable Canadian privacy laws, including PIPEDA and relevant provincial legislation.

1.1 Roles of Advisor Terminal

Advisor Terminal may act as both a Data Processor and a Data Controller, depending on the nature of the services provided:

• Data Processor: When acting as a Data Processor, Advisor Terminal processes personal data on behalf of clients and follows their instructions.
• Data Controller: When acting as a Data Controller, Advisor Terminal determines the purposes and means of processing personal data.

We collect personal information for the following purposes:

• Provision of Services: To provide and maintain our services, including the Licensed Software.
• Account Management: To create and manage your user account.
• Communication: To communicate with you regarding updates, notifications, and responses to your inquiries.
• Transaction Processing: To process payments and fulfill transactions.
• Personalization: To personalize your user experience and improve our services.
• Compliance: To comply with legal obligations and enforce our terms.
• Security: To protect against fraud and unauthorized access.

2.1 Types of Data Collected

We may collect various types of data from users, including:

• Contact Information: Full name, email address, phone number, mailing address.
• Financial Information: Payment details, bank account information, billing information.
• Usage Data: IP addresses, browser type, device identifiers, operating system information.
• Professional Information: Job titles, company names, employment history where relevant.

We obtain your informed consent for the collection, use, and disclosure of your personal information, except where inappropriate. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.

3.1 Cookie Policy and User Consent

Use of Cookies:

We use both session-based and persistent cookies on our website to:

• Maintain Security: Authenticate your details while you navigate our site.
• Enhance User Experience: Recognize returning users and improve user experience.
• Analyze Usage: Collect aggregate information to better understand website usage patterns.

User Consent and Opt-Out:

Users may opt out of non-essential cookies through our Cookie Management Tool, which allows you to customize your cookie preferences at any time.

3.2 Cookie Opt-Out Process

To manage your cookie preferences, adjust your browser settings or access our Cookie Management Tool located on our website. Disabling non-essential cookies may impact certain functionalities of our services.

We collect personal information only by fair and lawful means and limit the amount and type of personal information collected to that which is necessary for the identified purposes.

4.1 Personal Information

• Identification Information: Full name, date of birth.
• Contact Information: Email address, telephone number, mailing address.
• Authentication Information: User credentials (username, password).
• Financial Information: Payment details, billing address.

4.2 Non-Personal Information

• Technical Data: Browser type and version, device information, operating system.
• IP Address: Internet Protocol address used to connect your device to the Internet.
• Website Usage Data: Pages visited, time spent on the site, clickstream data.

5.1 Use of Personal Information

We use personal information only for the purposes identified at the time of collection or as permitted by law.

5.2 Disclosure of Personal Information

We may disclose your personal information under the following circumstances:

• Service Providers: To third-party service providers who assist us in operating our business, provided they comply with privacy standards comparable to our own.
• Legal Requirements: To comply with legal obligations, court orders, or regulatory requests.
• Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets, with appropriate safeguards in place.

5.3 Data Retention

We retain personal information only as long as necessary to fulfill the identified purposes or as required by law. Data is retained for 30 days after account termination, after which it is permanently deleted unless otherwise requested.

We make reasonable efforts to ensure that personal information is accurate, complete, and up-to-date. Users are encouraged to review and update their personal information through their account settings or by contacting us.

6.1 Right to Access and Correct Data

Users have the right to access their personal data and request corrections if the data is incomplete or inaccurate. All access requests must be submitted in writing to our Privacy Officer.

We implement appropriate physical, organizational, and technological measures to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification.

Security Measures Include:

• Encryption: Data encryption in transit and at rest.
• Access Controls: Restricted access to personal information on a need-to-know basis.
• Security Software: Protection against unauthorized access and malware.
• Employee Training: Regular training on privacy and data security practices.

We make readily available to individuals specific information about our policies and practices relating to the management of personal information. This Policy is accessible on our Website, and copies can be requested from our Privacy Officer.

9.1 Access Rights

You have the right to access your personal information under our control, subject to certain legal exceptions. To request access, please contact our Privacy Officer.

9.2 Correction of Personal Information

If you identify any inaccuracies in your personal information, you may request correction by contacting us. We will promptly correct or annotate the information as appropriate.

You may address any concerns regarding our compliance with this Policy or applicable privacy laws by contacting our Privacy Officer. We will investigate all complaints and respond within a reasonable timeframe.

11.1 Types of Cookies Used

• Essential Cookies: Necessary for the functioning of the Website.
• Functional Cookies: Enhance the functionality and performance of the website. They remember your preferences and settings without tracking activity.
• Performance/Analytics Cookies: Collect information about website usage, including visitor statistics and page performance.
• Social Media Cookies: Enable social media integration and sharing capabilities.
• Marketing Cookies: Help determine relevant products and services for users.

11.2 Managing Cookies

You can manage cookie preferences through browser settings or our Cookie Management Tool. Note that disabling certain cookies may impact website functionality.

Our Website may contain links to third-party websites or services not operated by Advisor Terminal. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies before providing any personal information.

Your personal information may be transferred to and processed in countries outside of Canada, including the United States. We take steps to ensure that any such transfers comply with applicable privacy laws and that your information receives the same level of protection as it would in Canada.

We may engage third-party subprocessors to process personal information on our behalf. We ensure that all subprocessors provide sufficient guarantees to implement appropriate technical and organizational measures in compliance with Canadian privacy laws.

In the event of a data breach involving personal information that poses a real risk of significant harm, we will notify the affected individuals and the Office of the Privacy Commissioner of Canada as soon as feasible.

15.1 Incident Response Protocol

• Detection and Assessment: Identify and assess the breach to determine the scope and impact.
• Containment and Mitigation: Take immediate steps to contain the breach and mitigate potential harm.
• Notification: Notify affected individuals within seventy-two (72) hours of discovering the breach.
• Post-Incident Review: Conduct a thorough review to improve security measures and prevent future breaches.

We may update this Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be effective when we post the revised Policy on our Website. We will provide notice of material changes by email or through the Website.

17.1 Access Rights

You have the right to access your personal information held by Advisor Terminal. To request access, please contact our Privacy Officer at privacy@advisorterminal.com.

17.2 Right to Erasure

You may request the deletion of your personal data, subject to certain legal exceptions. Requests must be submitted to our Privacy Officer and will be handled within thirty (30) days.

17.3 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.

If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact: